Guides / UKCA vs CE marking · Updated 30 September 2026

UKCA vs CE marking: a guide for importers from the EU

Clearing customs is only half the job. If you import regulated products from the EU into Great Britain, you also need the right conformity marking and your own details on the product. Here is what GOV.UK says today.

This guide is also available in Polish.

Why marking matters when you import from the EU

Customs clearance and product compliance are two separate gates. A CDS import declaration gets your goods released at the border, but it does not prove that the product may legally be sold in Great Britain. For many manufactured goods, that second question is answered by a conformity marking: the UK Conformity Assessed (UKCA) marking or the EU's CE marking.

If you buy stock from an EU manufacturer or distributor and bring it into Great Britain, you usually become the importer for product safety purposes as well as for customs. That role carries its own duties, and getting the marking wrong can leave you holding goods you cannot put on sale.

Which products need a conformity marking?

Not everything needs one. GOV.UK's guidance on using the UKCA marking covers more than 20 product types, spanning the so-called new approach goods, aerosols and rail products, and it states plainly that not all products must bear a conformity marking. Whether your product needs one depends on the sector-specific regulations that apply to it.

In practice, the categories most often seen by small importers include toys, electrical equipment, machinery, personal protective equipment and similar manufactured goods. If your product falls within one of the regulated product types, you need to check which marking rules apply before the goods are placed on the GB market. If it does not, a marking may not be required at all, although general product safety duties still apply.

Is CE marking still accepted in Great Britain?

This is the question most EU suppliers ask, and the current answer on GOV.UK is yes for most products. Under The Product Safety and Metrology (Amendment) Regulations 2024, the UK continues to recognise the CE marking, alongside or in place of the UKCA marking, for the Great Britain market.

That means a product legitimately carrying the CE marking can, for most covered product types, be sold in England, Scotland and Wales without also carrying UKCA. Manufacturers may choose to use UKCA instead, or both markings together.

Where the UKCA marking may be placed

For businesses that use UKCA, GOV.UK allows the marking to be placed on a label or in a document accompanying the product, rather than on the product itself, until 11pm on 31 December 2027. After that, the normal affixing rules for the relevant product type apply.

Your obligations as the GB importer

When you bring goods from the EU into Great Britain, the EU is a non-UK source, so the business placing them on the GB market is the importer. The core practical duty set out on GOV.UK is traceability: importers must indicate their name, trade name or trademark, and postal address on the product.

Where that is not possible, for example because the item is too small, the details may be placed on the packaging or in a document accompanying the product. This is easy to overlook when buying finished goods from an EU wholesaler whose packaging only shows the manufacturer's EU address.

• Confirm whether your product falls within a regulated product type that requires a conformity marking.
• Check whether your sector is one of the exceptions with its own rules (construction, medical devices, rail, marine, cableways, transportable pressure equipment, uncrewed aircraft).
• Verify that the product carries a CE or UKCA marking where one is required, and that the manufacturer can support it with the relevant documentation.
• Add your own name, trade name or trademark and postal address to the product, or to the packaging or accompanying document where space does not allow.
• Keep supplier records so that you can answer questions from market surveillance authorities.

These duties sit alongside, not instead of, your customs obligations. You still need an EORI number, a correct commodity code and a valid declaration to clear the goods.

Northern Ireland is different

Northern Ireland follows a different model under the Windsor Framework. EU product rules apply there, and the UKCA marking is not accepted for placing goods on the Northern Ireland market.

Where a sector-specific regulation requires a conformity marking, products placed on the market in Northern Ireland need a CE marking, or a CE and UKNI marking. The UKNI marking is used when a Northern Ireland notified body carries out mandatory third-party conformity assessment. GOV.UK is clear that the UKNI marking is never used on its own: it always accompanies an EU conformity marking such as CE.

The traceability duty is the same in principle: manufacturers and importers must indicate their name, registered trade name or registered trademark, and postal address on the product.

GOV.UK also notes that qualifying products from Northern Ireland can be placed on the Great Britain market under their existing CE or UKNI markings without additional approvals.

A worked example: toys from an EU supplier

Toys are a common case. A UK retailer buying from a German or Polish wholesaler will normally find CE-marked stock, which GOV.UK currently recognises for the GB market. The retailer, as importer, still needs to add its own name and address and check that the manufacturer completed the required conformity procedures. For a product-specific walk-through, including labelling and warnings, see the UKCA and CE rules for imported toys.

Where customs and compliance meet

A customs agent files your declaration, but in most arrangements the product compliance duties stay with you as the importer. If you use direct representation, you remain liable for the declaration too, so it pays to have both sides in order before goods arrive. If you are unsure whether you need help with the customs side, read do you need a customs broker.

Rules in this area have changed several times since 2021. Always check the current GOV.UK guidance for your product type before you ship.

Related guides

• Shipping goods from Poland to Northern Ireland: VAT, XI numbers and EORI

• Statement on origin: claiming zero duty under the UK–EU TCA

• Import VAT evidence: C79 certificates vs postponed VAT statements

Sources

• Using the UKCA marking (GOV.UK)
• Placing CE, or CE and UKNI marked products on the market in Northern Ireland (GOV.UK)

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.