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Brexit transition implications for HazLoc Products

31 October 2020

The UKCA mark is the new product marking required for products being placed in the United Kingdom. It covers most products that previously required CE Marking, including products used in Hazardous Locations. Save costs and time with UL through combined testing to receive IECEx, ATEX and UKCA marks to enter EU and U.K. markets.

UKCA mark timeline and transition period

The UKCA (UK Conformity Assessed) mark will apply to most goods currently subject to the CE marking (products covered by the following Directives/Regulations, e.g., LVD, EMCD, GAR, Machinery, ATEX, RoHS and RE-D). The UKCA mark can be used from January 2021. However, to allow businesses time to comply with the new requirements, CE marking can still be used until Jan. 1, 2022, provided that the requirements for the EU and U.K. legislation will continue to be the same.

Starting Jan. 1, 2022, the U.K. government will no longer recognize the CE marking for U.K. market access. Products bearing both the CE marking and UKCA mark will be acceptable as long as they comply with the relevant U.K. rules. The UKCA mark will need to be used immediately after Jan. 1, 2021, if the product is only marketed in United Kingdom and is covered by legislation that requires the UKCA mark and mandatory third-party certification by a UK Conformity Assessment Body.

Implications for products used in Hazardous Locations

The UKCA mark will also apply to Products used in Hazardous Locations which are currently subject to the CE marking. Electrical products for Usage in Zone 0 and 1 and non-electrical for Zone 0 will require a certificate from an approved UKCA body. A Manufacturing Quality Audit will also be required from a UKCA approved Body. (UL International (UK) Ltd Approval for UKCA is currently pending and expected to be confirmed in time for January 2021.)

Certificates issued from UL International Demko A/S (Notified Body Number: 0539) will be unaffected and still valid for use in the EU. This includes projects managed from the U.K. 

An additional UKCA Declaration of Conformity (DoC) will be required for products bearing the UKCA mark, which differs from the EU DoC in the following ways:

- "EU" references removed
- Any references to EU legislation are replaced with U.K. statutory requirements (as an example. Directive 2014/34/EU is replaced with SI 2016 No. 1107)
- Reference to Notified Body is replaced with Approved Body
- Reference to Notified Body numbers will need to change to Approved Body numbers

Trusted expertise to help you bring products to UK and EU markets

UL has the global reach and expertise to support market access needs during every step of the Brexit transition by combining testing and certification, global scope and localized knowledge with real-time market expertise to help reach target markets in the U.K. and the European Union.

Save costs and time through a combined testing to receive IECEx, ATEX certificates and UKCA mark to enter EU, U.K. and other markets around the world. Get the conversation started on how UL can support you so your products continue to comply with U.K. and EU requirements.


UL International (UK) Ltd
Shaun Wilson
Telephone: +441256674719

For further information about Brexit and the transition period, visit

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