[Home](/)/[Resources](/resources)/CE to UKCA Transition UKCA TransitionPost-Brexit # CE to UKCA Transition: Converting Your CE Technical File for the GB Market Most CE-marked products can be prepared for UKCA without starting from scratch. The test reports, risk assessments, and technical drawings are almost always reusable. What changes is the regulatory reference framework — the declaration, the designated standards citations, the conformity body, and the responsible person entity. This guide gives you a precise checklist of what needs updating and what can stay. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fce-to-ukca-transition) ## What stays the same ✓Test reports: GB-designated standards are technically identical to EU harmonised standards for most product categories. A single set of test reports typically satisfies both CE and UKCA. ✓Risk assessment: Same methodology (EN ISO 12100 for machinery, IEC 62368-1 for AV/IT equipment). No need to repeat the risk assessment. ✓Product description, drawings, and BOM: These are product-specific and do not change based on the marking regime. ✓User manual content: The technical content remains the same. Only the regulatory references and conformity marking information need updating. ✓Conformity assessment module: Self-assessment (Module A equivalent) remains available for the same product categories in both CE and UKCA frameworks. ## What must change for UKCA ### Declaration of Conformity → UK Declaration of Conformity The UK DoC must reference UK regulations (e.g., 'Radio Equipment Regulations 2017' not 'Radio Equipment Directive 2014/53/EU'), cite GB-designated standards, and be signed by a person with the authority to sign for the UK-placing entity. ### EU harmonised standards → GB designated standards references While the standard numbers are usually identical, the official references in your documentation should say 'GB designated standard' not 'EU harmonised standard'. List them from the UK government's designated standards register. ### EU Notified Body → UK Approved Body (where third-party assessment applies) If your CE marking involved a Notified Body for type-examination or quality assurance, you must engage a UK Approved Body for UKCA. The EU Notified Body's certificate does not automatically transfer. ### EU Authorised Representative → UK Responsible Person Non-UK manufacturers must appoint a UK Responsible Person (with a UK address) rather than an EU Authorised Representative. The UK Responsible Person role and obligations differ slightly from the EU AR role. ### UKCA marking affixation The UKCA marking must be affixed instead of (or in addition to) CE marking. The UKCA mark has specific proportions — minimum height 5mm with proper aspect ratio. The mark must remain on the product for its economic life. ### Northern Ireland: CE marking continues For products placed on the Northern Ireland market, CE marking continues to apply under the Windsor Framework provisions. UKCA marking is not required or accepted for NI-covered harmonised goods in the same way. ## Transition timeline Week 1Audit existing CE technical files — identify which products and which regulations are in scope for UKCA conversion Week 1–2Cross-reference test reports against current GB-designated standards list — flag any standard references that have been superseded or amended Week 2–3Draft updated UK Declaration of Conformity for each product — update regulatory references from EU to UK frameworks Week 3–4If Approved Body involvement is needed: identify a UK Approved Body and initiate engagement (allow 4–8 weeks for any assessment) Week 4–5Update user manuals and labeling artwork — update conformity marking references and UK Responsible Person details Week 5–6Register UK Responsible Person with manufacturers' documentation systems and update product registration with distributors/retailers Week 6+Begin using updated labels and documentation for GB-bound shipments. Retain CE-marked versions for EU and NI shipments. ## Learn this properly, not just for one product In-depth courses and books that teach the process — not a one-off answer you'll need to look up again next time. [Start the course — $149](/courses/01-ce-marking-for-electronics-engineers)See your free roadmap [Prefer to read? Get the book — $24.99](/books/01-ce-marking-for-electronics-engineers) ## Frequently asked questions ### Is there a deadline to complete the CE to UKCA transition? The UK government has confirmed that CE marking will continue to be accepted indefinitely in Great Britain for most product categories. There is currently no published deadline requiring manufacturers to switch to UKCA. The Government reviews this policy periodically. However, some product categories (e.g., construction products) have different timelines. Monitor the OPSS and specific sector guidance on gov.uk for your product category. ### Can I use the same Declaration of Conformity for CE and UKCA? Technically yes — some manufacturers issue a single combined document covering both CE and UKCA. However, be careful: the EU Declaration of Conformity and UK Declaration of Conformity have different legal requirements and reference different regulatory frameworks. Many compliance professionals recommend separate documents to avoid confusion and errors. If combining them, clearly differentiate which sections apply to EU (CE) and which to GB (UKCA). ### What if my product uses a harmonised standard that no longer appears on the GB designated standards list? If a standard you used for CE marking is not on the current GB-designated standards list, applying it does not give presumption of conformity for UKCA. You must either: (a) use an alternative GB-designated standard that covers the same risks, or (b) demonstrate conformity by other technical means and document this in your technical file. In practice, most EN standards remain on both the EU harmonised and GB-designated lists. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/01-ce-marking-for-electronics-engineers)[Prefer to read? Get the book — $24.99](/books/01-ce-marking-for-electronics-engineers) Related guides * [UKCA Marking: Complete GuideComplete guide to UKCA marking for the Great Britain market: requirements, timeline, costs, GB vs NI differences, and how to tr…](/guides/ukca-marking) * [UK Approved Body vs EU Notified BodyComplete guide to UK Approved Bodies vs EU Notified Bodies: what changed after Brexit, which products require third-party asses…](/guides/uk-approved-body-vs-notified-body) * [UK Conformity Assessment RoutesComplete guide to UK conformity assessment routes for UKCA marking: when self-declaration (internal production control) is perm…](/guides/uk-conformity-assessment-routes) * [UK Designated StandardsComplete guide to UK designated standards for UKCA marking: how designated standards differ from harmonised standards, where to…](/guides/uk-designated-standards) * [Selling to the UK from the EU After BrexitComplete guide for EU-based companies selling to the UK after Brexit: customs duty and import VAT, UK product safety compliance…](/guides/uk-selling-from-eu) Educational resource only. UKCA compliance responsibility remains with the manufacturer, importer, or UK Responsible Person. Verify current UK regulations and designated standards before market entry.