UKCA marking post‑Brexit: A guide for UK construction & manufacturing

UKCA vs CE marking: What’s the difference?

The UKCA marking is the new product mark required to show that certain goods comply with UK rules, replacing the EU’s CE mark for Great Britain. It covers essentially all products that previously needed CE marking — from machinery to construction materials — and is used when those goods are placed on the market in England, Scotland or Wales. An important distinction is that the UKCA mark is only valid in the UK — it is not recognised by EU/EEA countries, so exporters must still use the CE mark for EU markets. Conversely, products in Great Britain will in time require UKCA marking and no longer accept CE marking (transitional allowances aside). Northern Ireland (NI) remains subject to EU product rules under the Withdrawal Agreement, so CE marking continues in NI, with an additional UKNI mark used if a UK-approved body is involved.

In practice, the technical requirements behind UKCA and CE marks are currently the same. The UK government carried over all existing EU product standards into UK law at the end of the Brexit transition, meaning a product that meets EU harmonised standards will meet the equivalent UK “designated standards”. The difference lies in oversight and labelling: UKCA conformity assessments are done by UK-approved bodies (instead of EU notified bodies), and the product is marked “UKCA” instead of “CE”. Over time, UK and EU standards may diverge, but as of now the UKCA mark indicates compliance with essentially identical standards to CE — only under a UK regulatory framework.

Impact on the construction & manufacturing sectors

For the UK construction and manufacturing sectors, the shift to UKCA marking has introduced new administrative hurdles and costs. Companies that sell products in the UK and EU now face the possibility of duplicate testing and certification: any product that previously needed a CE mark backed by an EU notified body now also needs a UKCA certificate issued by a UK approved body to be sold in Great Britain. This has meant re-certifying many products even though the underlying standards haven’t changed. For example, one insulation manufacturer estimated it must spend about £400,000 on re-testing insulation boards in UK labs to obtain UKCA approval, despite having already tested them to EU standards. Such duplicate conformity assessments and paperwork — new declarations, technical files, labels — create additional cost and complexity for manufacturers and importers.

Capacity concerns

The UK has far fewer approved test bodies than the EU had notified bodies, raising fears of bottlenecks and delays. Industry groups warned that UK testing labs alone couldn’t handle the volume of retesting for all construction products by original deadlines. In some niche areas, no domestic test facility exists for certain standards, meaning those products would have been impossible to certify for UKCA without using EU data. These challenges prompted the government to extend transitional periods and continue accepting CE marks longer than initially planned. As a result, CE-marked products are still accepted in Great Britain at present (2025), but businesses are urged to switch to UKCA as soon as possible to future-proof their market access.

Timeline of implementation 

• 1 January 2021 — UKCA marking becomes available for construction products in Great Britain under the UK Construction Products Regulation (UK CPR).
• Originally planned: 1 January 2023 — UKCA marking was set to become mandatory, replacing CE marking for all construction products sold in Great Britain.
• Updated deadline: 30 June 2025 — CE marking will continue to be accepted in Great Britain until this date.
• From 1 July 2025 — UKCA marking is expected to become mandatory for construction products covered by designated standards in Great Britain.

Key construction product groups affected

Certain product categories in construction and manufacturing have been particularly affected by the UKCA transition:

• HVAC systems: Heating, ventilation, and air conditioning equipment (e.g. boilers, heat pumps, ventilation units) that required CE marking under EU directives now require UKCA marking for the UK market. This spans electrical and gas-fired HVAC appliances, which must comply with UK versions of regulations — such as machinery safety, gas appliance safety, and electromagnetic compatibility rules — and bear the UKCA label.
• Precast concrete & masonry: Structural precast concrete elements and masonry units — beams, slabs, blocks, etc. — that were previously CE-marked under harmonised European standards must now be UKCA-marked to be sold in Great Britain.
• Structural steel components: Fabricated steelwork and metal components used in structures — e.g. steel beams, frames, connectors — were subject to CE marking (notably under EN 1090 for structural steel). Under the UK regime, such products must carry UKCA marking to show compliance with the equivalent UK standard and assessment by a UK approved body.

Role of environmental product declarations and life-cycle assessments in UKCA marking

Although the transition from CE to UKCA marking does not directly change environmental product declaration (EPD) and life-cycle assessment (LCA) requirements, these sustainability assessments remain crucial. An EPD is a third-party verified document detailing a product’s environmental impacts across its life-cycle, derived from an LCA. While UKCA marking focuses on safety and performance compliance, EPDs complement this by addressing environmental performance.

Regulatory and market trends are increasingly prioritising transparency. The EU’s revised Construction Products Regulation (CPR) is set to integrate environmental criteria like carbon footprint into CE marking. Similarly, the UK’s proposed Part Z aims to make embodied carbon reporting mandatory. While UKCA does not currently require EPDs, manufacturers investing in them will be better positioned for future sustainability regulations.

Beyond regulation, market demand for EPDs is growing. Architects, engineers, and contractors increasingly require EPDs for project tenders, while certifications such as BREEAM and LEED reward products with EPDs. The UKCA mark does not convey environmental data, making EPDs essential for demonstrating sustainability credentials. As construction moves towards net-zero goals, EPDs and LCAs will remain integral to compliance and market access, regardless of product conformity marking.