Great Britain (England, Scotland and Wales) recognises CE marking indefinitely for most product groups: the UK government announced the extension in August 2023 and current gov.uk guidance reflects it. UKCA remains a valid alternative and becomes compulsory in specific cases, notably where mandatory third-party conformity assessment was carried out by a UK approved body. The manufacturer answers for the marking, the GB importer for checking it. A freight forwarder can do neither for you.
Why exporters are confused: UKCA was meant to replace CE
After leaving the EU, the United Kingdom introduced its own UKCA mark and set a series of deadlines after which CE alone would no longer be enough on the GB market. Those deadlines moved several times, and every year exporters heard a different version. In August 2023 the government announced that recognition of CE marking would continue indefinitely for most product groups covered by regulations under the Department for Business and Trade, including toys, machinery, electrical equipment, electromagnetic compatibility and pressure equipment.
For an EU manufacturer this means a product lawfully CE-marked for the EU can, in most cases, be shipped to England without a second certification. The word "most" carries the whole sentence. Several sectors sit with other departments and run their own rules and timetables: medical devices, construction products, marine equipment, rail products, transportable pressure equipment, unmanned aircraft systems. If your product falls into one of those groups, the only reliable source is the current sector guidance on gov.uk, not a two-year-old forum thread. If you are only starting to sell across the Channel, read our guide to a first UK export for a small business as well.
What the GB market accepts today: four typical situations
| Situation | What the GB market accepts | Notes |
|---|---|---|
| Most product groups (regulations under the Department for Business and Trade) | CE or UKCA, at the manufacturer's choice | CE recognition extended indefinitely per gov.uk |
| Mandatory conformity assessment carried out by a UK approved body | UKCA only | a UK body's certificate does not entitle you to affix CE; CE requires an EU notified body |
| Sectors with their own rules (medical devices, construction, marine, rail, among others) | per sector rules | separate guidance and transition timetables; check gov.uk for the specific sector |
| Northern Ireland | CE under EU rules | UKCA alone is not sufficient; the Windsor Framework regime applies |
When UKCA is genuinely mandatory
Three scenarios where CE alone will not do. First: the applicable regulations require third-party conformity assessment and that assessment was carried out by a UK approved body. Such a certificate leads to UKCA, not to CE, because CE requires an EU notified body. Second: the product belongs to a sector where UK rules set their own requirements and the indefinite CE recognition does not apply; there the departmental guidance decides. Third, purely commercial: your British customer or retail chain requires UKCA in the contract regardless of what the law would accept.
Nothing prevents a product from carrying both marks if it meets both sets of requirements. Gov.uk guidance also allows the UKCA mark to be placed on a label affixed to the product or in an accompanying document; the details and exceptions are described on the "Using the UKCA marking" page.
Manufacturer, importer, distributor: who answers for what
- The manufacturer runs the conformity assessment, compiles the technical documentation, issues the declaration of conformity and affixes the marking. None of this can be delegated to a haulier or a customs agent.
- The GB importer, the business placing goods from outside the UK on the British market, has duties of its own under gov.uk guidance: check that the manufacturer has done its part and applied the marking, keep a copy of the declaration of conformity and make sure the importer's name and address appear on the product, its packaging or the accompanying documents.
- The distributor must act with due care and must not sell products it knows to be non-compliant.
- Selling without a GB importer, for example direct to consumers, does not erase these duties; it shifts them to another party in the chain. Before you choose a sales model, check on gov.uk who formally places the goods on the GB market in that model.
Marking is product law, not customs clearance
This distinction saves exporters from a false sense of security. The customs declaration, tariff codes, EORI and GVMS are one regime; product conformity and the CE or UKCA mark are another. A consignment without the required marking can clear customs, because the declaration does not verify conformity documents. The problem returns later: market surveillance in GB belongs to the Office for Product Safety and Standards and local Trading Standards, and their tools include sales stops, recalls and mandatory corrective action. At that point the bill covers not just a lost contract but storage, return transport and re-labelling of the whole batch. The border formalities themselves are covered in our pieces on UK customs clearance after Brexit and documents required for exporting to the UK.
What a forwarder can and cannot do for you
- Can: organise transport and customs clearance both ways, plan delivery bookings and handle returns.
- Can: physically re-label goods in the warehouse to your instructions: apply labels you supplied or approved, for example with the GB importer's details, before the goods reach a retail chain. That is how our re-labelling and GS1/SSCC service in Milton Keynes works.
- Can: check before dispatch, against a checklist agreed with you, that the required markings and details are present on the packaging, and hold back a pallet where they are missing.
- Cannot: assess whether your product complies with the regulations, issue or sign a declaration of conformity, or decide for you whether CE or UKCA applies.
- Cannot: take over the manufacturer's or the importer's legal responsibility. It flows from the regulations and does not travel with the goods to the carrier or the warehouse.
How we run this
As a road haulier we move goods between Poland and the United Kingdom and we know where product law meets logistics: we handle customs clearance, run warehouses in Kielce, Legnica and Milton Keynes, and on request we carry out re-labelling and completeness checks of markings to the client's written instructions. We will not replace the manufacturer in conformity assessment, but we will make sure correctly marked goods arrive on time and without surprises at the border. The full route is described on our export to the UK page, and you can discuss a specific shipment through the contact form.
