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# UKCA Self-Declaration: When You Can Self-Certify and When You Need a UK Approved Body

UKCA marking follows the same modular conformity assessment logic as CE marking, which means for most electronics products, you can self-declare without engaging a third party. But the rules differ by product category, and getting the assessment route wrong is a costly mistake. This guide gives you a clear read on when you can sign off yourself — and when you can't.

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At a glance

Mark

UKCA

Self-declaration

Most products (Module A)

UK Approved Body

Required for high-risk categories

Declaration

UKCA DoC mandatory

## How UKCA conformity assessment works

### UKCA and the module system

UKCA conformity assessment follows the same modular structure as CE marking — Module A through Module H1 — inherited from the EU's New Legislative Framework. The specific modules available for a given product are determined by the applicable UK statutory instrument (SI), not by a single universal rule. Manufacturers must identify the correct SI for their product category and read its Schedule to understand which conformity assessment routes are permitted.

### When self-declaration (Module A) is permitted

The majority of consumer electronics, IT equipment, radio equipment, and general-purpose industrial devices can use Module A — internal production control — for UKCA. Under Module A, the manufacturer compiles the technical file, tests the product against applicable designated standards, signs a UKCA Declaration of Conformity, and applies the UKCA mark without any third-party involvement. No UK Approved Body is required for this route.

### When a UK Approved Body is mandatory

Higher-risk product categories require third-party conformity assessment by a UK Approved Body. These include pressure equipment covered by the UK PED equivalent, lifts, personal protective equipment (for the higher-risk PPE categories), certain medical devices, and some radio equipment categories. The requirement is specified in the applicable UK statutory instrument — manufacturers should check the relevant SI's conformity assessment Schedule rather than assuming the EU directive's notified body requirement carries over identically.

### UK Approved Bodies vs EU Notified Bodies

UK Approved Bodies are accredited by UKAS, the United Kingdom Accreditation Service. EU Notified Bodies that were approved before January 1, 2021 were grandfathered as UK Approved Bodies under transitional arrangements, but this applied on a time-limited basis and for specific scope. For new third-party assessment requirements, manufacturers must use a UK Approved Body with current UKAS accreditation for the relevant product category. EU Notified Body certificates issued after the Brexit transition period do not substitute for UK Approved Body assessments.

## Steps to UKCA self-declaration

01

Identify the applicable UK legislation (statutory instrument) for your product — search the HSE, OPSS, or MHRA UKCA guidance pages for the SI that replaced the EU directive for your product category; common examples include the Electromagnetic Compatibility Regulations 2016, the Radio Equipment Regulations 2017, and the Electrical Equipment (Safety) Regulations 2016.

02

Read the conformity assessment module requirements in the applicable SI — check the Schedules to the SI for the list of permitted modules and whether any module requires third-party UK Approved Body involvement; note that some SIs specify different modules depending on the risk level or design of the product.

03

For Module A self-declaration: compile the technical file including product description, design drawings, component specifications, applicable designated standards, test reports, and risk assessment; perform the required testing against the applicable UK designated standards; sign the UKCA Declaration of Conformity referencing the applicable UK legislation, the manufacturer's UK or overseas address, and the designated standards applied.

04

Apply the UKCA mark to the product and its packaging — the mark must meet the minimum size requirements (5mm height minimum) and must not be accompanied by any other marking that could mislead users; the UKCA mark can be placed alongside the CE mark during the period when CE marks remain valid for GB, but check the current transition status for your product category.

05

Retain the technical file for 10 years from the date the last unit of the product was placed on the GB market — OPSS and other market surveillance authorities may request the technical file during market surveillance; the UKCA Declaration of Conformity must be made available to the market surveillance authority on request and may also need to be supplied to distributors.

## Frequently asked questions

### Can I use CE test reports for UKCA self-declaration?

Yes, in most cases test reports generated against EU harmonised standards can be used to support UKCA self-declaration, provided those standards have been designated as UK designated standards under the applicable UK statutory instrument. Most EU harmonised standards were adopted as UK designated standards at the point of Brexit. Manufacturers should verify that the specific standard edition used in testing is designated in the UK — OPSS publishes the list of UK designated standards — before relying on existing CE test reports for UKCA.

### Is CE marking still accepted in Great Britain?

CE marks were accepted in Great Britain under transitional arrangements, but this acceptance has been phased out progressively by product category. As of 2025, the position varies by product type — some categories have already passed their CE transition deadline and now require UKCA only for new products placed on the GB market, while others still retain a transitional period. Manufacturers should check the specific end date for their product category on the OPSS UKCA guidance pages rather than assuming a single universal deadline.

### What is the difference between a UK Approved Body and a UK Conformity Assessed (UKCA) body?

These terms are sometimes used interchangeably but refer to different things. A 'UK Approved Body' is an organisation officially approved by the UK government and accredited by UKAS to carry out third-party conformity assessment for specific product legislation — they play the same role as EU Notified Bodies. 'UK Conformity Assessed' (UKCA) is the name of the marking regime itself, not a type of body. When a product requires third-party assessment for UKCA marking, that assessment must be performed by a UK Approved Body.

### How long must I keep UKCA technical documentation?

Under most UK product legislation, the technical file must be retained for 10 years from the date the last unit of the product was placed on the GB market. This clock starts from the final production run, not from when the product was first launched. The UKCA Declaration of Conformity must also be kept for the same 10-year period and must be available to market surveillance authorities on request. OPSS can inspect technical files during market surveillance exercises and can issue compliance notices where documentation is inadequate.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions.

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