The UKCA and CE marking situation continues to confuse sellers. The UK government has extended transition deadlines repeatedly, and the technical requirements are quietly diverging. Here’s where things stand.
The Current Situation
Since Brexit, the UK has its own product conformity marking — UKCA (UK Conformity Assessed). Products placed on the Great Britain market are, in principle, required to bear the UKCA mark rather than the CE mark.
However, the UK government has repeatedly extended the transition period. The practical effect is that CE marking is still accepted for most product categories on the GB market, but this acceptance has an expiry date that has been pushed back several times.
For Amazon UK sellers, this creates a confusing landscape. Which mark do you need? Do you need both? What happens when the transition period ends?
CE Marking — What It Covers
CE marking demonstrates conformity with EU harmonised legislation. It’s required for products sold in the European Economic Area (EU + EFTA countries). If you sell on Amazon.de, Amazon.fr, Amazon.it, Amazon.es, or any other EU marketplace, your products must bear the CE mark.
The CE mark requires a Declaration of Conformity referencing EU directives and regulations, testing against EU harmonised standards, technical documentation compiled by the manufacturer, and the CE marking applied to the product in the correct format and dimensions.
UKCA Marking — What It Covers
UKCA marking covers products placed on the Great Britain market (England, Scotland, and Wales). Northern Ireland follows different rules under the Windsor Framework and continues to accept CE marking.
UKCA requirements mirror CE requirements in many areas, but they reference UK-designated standards rather than EU harmonised standards. In most cases, the actual technical requirements are identical or very similar, but the legal references differ.
The UKCA mark requires a UK Declaration of Conformity referencing UK regulations, testing against UK-designated standards, technical documentation, and the UKCA marking applied correctly.
Which Do You Need for Amazon UK?
For Amazon.co.uk specifically, the answer depends on where your products will physically be sold and what transition provisions are currently in effect.
If you’re selling only on Amazon UK and your products will only be distributed within Great Britain, you need UKCA marking (or CE marking while the transition provisions remain in force).
If you’re selling on Amazon UK and EU marketplaces, you need both CE marking (for EU sales) and UKCA marking (for GB sales, once transition ends).
The pragmatic approach most sellers take is to maintain CE marking compliance (which satisfies both EU requirements and current UK transition provisions) and prepare for UKCA as the transition deadline approaches.
Where the Requirements Are Diverging
While the UK initially transposed EU harmonised standards almost identically, the two frameworks are beginning to diverge in some areas. Key differences are emerging in electronic product safety standards, where the UK is adopting updated editions at different timescales, radio equipment requirements where UK and EU spectrum allocation differs, and environmental regulations where the UK is developing its own extended producer responsibility schemes.
For most consumer products, the technical requirements remain very similar. But the gap is widening, and sellers who assume CE and UKCA will always be interchangeable may find themselves caught out.
Practical Steps for Amazon Sellers
Maintain your CE marking documentation as your baseline — this satisfies EU requirements and current UK transition provisions. Build a separate UK Declaration of Conformity referencing UK regulations and UK-designated standards. Monitor the UK government’s timeline for when UKCA marking becomes mandatory. Ensure your product packaging and labels can accommodate both marks when the time comes.
Don’t wait until the last minute. When the transition period ends, sellers without UKCA documentation will face a scramble, and testing laboratories will be backlogged.
Get Your Marking Strategy Right
If you’re unsure whether your current documentation covers both CE and UKCA requirements, or you need help building a compliant technical file, ComplyHive can help. This is core to what we do — 10+ years of hands-on UKCA and CE marking experience across consumer electronics, lighting, electrical products, and more.