Your eyes and hands in India · Est. 2019 · Replies within one working day

What is UKCA marking, and how does it differ from CE?

UKCA is Great Britain's own conformity mark. As of October 2026, GB still recognises CE marking for most products, including machinery, so many machines can enter GB with CE alone.

· 3 min read · Creston & Co

UKCA (UK Conformity Assessed) is the conformity marking for goods placed on the market in Great Britain: England, Scotland and Wales. It was created after Brexit to replace CE marking for the GB market.

In practice, CE marking has not been replaced. As of October 2026, UK government guidance says the UK continues to recognise CE marking alongside or in place of UKCA, under amendment regulations made in 2024.

How the two marks differ

  • CE marking shows conformity with EU law. UKCA shows conformity with GB law, which for machinery is the Supply of Machinery (Safety) Regulations 2008 as they apply in GB.
  • Where third-party assessment is needed, CE relies on an EU notified body and UKCA on a UK approved body.
  • The technical requirements have so far been very close, and the designated standards in GB largely mirror the EU's harmonised standards.
  • Each mark needs its own declaration: an EU declaration of conformity for CE, and a UK declaration for UKCA.

What changes in January 2027

The EU's new Machinery Regulation applies from 20 January 2027. That raises a question: will GB accept machines CE marked under the new EU rules?

In its response of 25 February 2026, the UK government said it intends to legislate to continue CE recognition for machinery in GB. Draft regulations to do this were laid before Parliament in June 2026, intended to apply from 20 January 2027. Check legislation.gov.uk for whether they have been made before you rely on them.

Northern Ireland follows different rules. Under the Windsor Framework, EU machinery law applies there, so CE marking is required for the NI market.

The government has also said that GB rules cannot simply copy the EU text. It intends to update the GB machinery regulations in a way that stays compatible with EU requirements, with UK conformity assessment and UKCA kept in place. Details may change, so check the current guidance on gov.uk before each new order.

What this means for an Indian machine

If your machine is properly CE marked and you sell into GB, CE alone is usually enough for now. If you or your customer prefer UKCA, the manufacturer can add it, but only with a UK declaration and, where needed, a UK approved body.

Either way, the manufacturer remains responsible for conformity, and the importer has duties too. GB workplace rules may also add requirements for the user, separate from the product rules. Confirm your position with the Office for Product Safety and Standards guidance, an approved body or a UK compliance adviser. Our guide to CE marking for machinery covers the EU side.

Next step

We check plates, declarations and manuals against the machine before it leaves India. To review a machine for the UK market, book a free sourcing review.

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