From the Desk of Lewis Bass

Welcome back to another edition of ‘Ask Lewis Bass,’ where we tackle your most pressing engineering and compliance questions. Today, we’re diving into a topic that’s becoming increasingly relevant: UKCA marking. This week we help answer Steven’s questions about UKCA compliance now that his company is shipping an automation system to Scotland for the first time since Brexit. Let’s get into it.

Question:

Hi Lewis Bass,

We’re working on a cutting-edge automation system that we’re shipping to Scotland, and we’ve been told it needs UKCA marking. We’re familiar with CE marking, but the UKCA marking process is new to us. What do we need to do to ensure compliance before shipping?

Asked by Steven in Roseville, MI

Lewis Bass:

Hi Steven,

Since Brexit, the UK has implemented its own product conformity marking—UKCA (UK Conformity Assessed)—which is now required for most goods placed on the market in Great Britain (England, Scotland, and Wales). If you’re used to CE marking, you’ll find that UKCA is largely similar, but there are some critical differences you need to account for.

The UKCA mark replaces the CE mark in Great Britain, but it does not apply in Northern Ireland (which still follows CE marking with some exceptions). The UK has essentially carried over most of the existing EU directives, but UKCA compliance requires that manufacturers or importers maintain documentation and conformity assessments in line with UK-specific regulations. This can mean working with a UK-approved body instead of an EU-notified one for certain types of certifications.

When we work with our clients for UKCA marking compliance, we follow the exact same steps listed out below to ensure that all scope is accounted for:

1. Determine Applicability – First, verify whether your automation system falls under UKCA requirements. Many categories, including electrical and electronic equipment, machinery, and pressure systems, require it.
2. Technical Documentation & Conformity Assessment – Similar to CE marking, you’ll need a technical file that includes design specifications, risk assessments, test reports, and user instructions. If your product requires third-party certification, you must use a UK-approved body.
3. UK Declaration of Conformity – Instead of the EU Declaration of Conformity, you’ll need to draft a UK Declaration of Conformity, which references relevant UK legislation rather than EU directives.
4. Labeling – Ensure your product carries the UKCA mark in a visible, legible, and permanent manner. If your product was previously CE marked and already in the market before the transition period ended, it might still be valid under certain grandfathering rules—but check to be sure!
5. Local Representation – If your company is based outside the UK, you may need an authorized representative or importer within Great Britain to handle compliance responsibilities.

If you’re also selling the same product in the EU, you’ll likely need to maintain both CE and UKCA markings, as they are now separate regulatory systems. That means dealing with two sets of documentation, potential testing with different approved bodies, and ensuring the correct labels are applied depending on the market.

A Final Note

Do you need help navigating UKCA compliance? At Lewis Bass, we’ve guided companies through international regulatory challenges, ensuring their projects meet all necessary standards. Get in touch, and let’s make sure your shipment to Scotland is smooth sailing!

 

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