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# UKCA Marking for Wearables and Smart Accessories: Complete GB Compliance Guide

Smartwatches, fitness trackers, smart rings, AR glasses, and hearables entering the Great Britain market face a multi-regulation compliance stack: Radio Equipment Regulations for wireless functions, SAR testing for body-worn transmitters, PSTI Act cybersecurity requirements for connected devices, and battery producer obligations. This guide maps every obligation so nothing slips through.

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## Applicable UK regulations for wearables

### Radio Equipment Regulations 2017

UKCA

Virtually all wearables include Bluetooth, Wi-Fi, or ANT+ — all require RER compliance

### EMC Regulations 2016

UKCA

All electronic wearables must demonstrate electromagnetic compatibility

### Electrical Equipment (Safety) Regulations 2016

UKCA

Devices with mains-connected chargers, or USB-C charging above 5V/2A thresholds, may need LVD coverage

### UK Battery and Accumulator Regulations 2009

Producer registration (not a mark)

All wearables with built-in or replaceable batteries trigger producer registration obligations

### PSTI Act 2022

Statement of Compliance

Smartwatches and fitness trackers with internet/Bluetooth connectivity sold to consumers require a Statement of Compliance

### UK RoHS Regulations 2012

No separate mark — built into UKCA declaration

Restriction of hazardous substances in electrical/electronic equipment — applies to the wearable device and charging accessories

## SAR testing for body-worn devices

What SAR measures: Specific Absorption Rate (SAR) measures the rate at which radio frequency energy is absorbed by the body. Expressed in watts per kilogram (W/kg).

UK SAR limits for body-worn devices: 2.0 W/kg averaged over 10g of tissue (head and trunk); 4.0 W/kg averaged over 10g (limbs). These are the same limits used in the EU.

SAR testing standard: EN 50566 (BS EN 50566) for body-worn devices including wearables; EN 62209-1/2 for mobile phones. Testing must be conducted at the minimum separations distance specified in your product documentation.

When SAR testing is required: Any wearable transmitting above certain power thresholds and worn in direct contact with the body. Most Bluetooth wearables require SAR testing — check the specific standard's thresholds.

SAR in technical documentation: SAR test reports, the separation distance assumption, and the SAR values achieved must be documented in the technical file and stated in user instructions.

## Common compliance pitfalls and fixes

✗ Assuming low transmit power = no SAR testing needed

✓ SAR testing obligation is determined by the specific standard's thresholds, not just by whether the device is 'low power'. Many Bluetooth wearables require SAR even at low power.

✗ Missing PSTI Statement of Compliance for smartwatches

✓ PSTI Statement of Compliance must be issued before placing on the GB market. It must be accessible to consumers and OPSS enforcement officers.

✗ Treating wearable charger as exempt from LVD

✓ USB-C chargers operating above the LVD voltage threshold trigger separate safety standards. Test the charger to EN 62368-1 or EN 60065 as applicable.

✗ Single UKCA Declaration missing all applicable regulations

✓ One Declaration of Conformity can cover multiple regulations but must explicitly list each regulation, the essential requirements met, and the designated standards applied for each.

✗ Not registering as a battery producer

✓ Wearable manufacturers and importers must register with a UK-approved compliance scheme for battery producer obligations, even if the battery is non-removable.

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## Frequently asked questions

### Do smartwatches that pair only via Bluetooth (no Wi-Fi, no cellular) need PSTI compliance?

Yes. Bluetooth is an in-scope connectivity technology under PSTI. Any consumer smartwatch or fitness tracker with Bluetooth connectivity requires a Statement of Compliance covering the three minimum security requirements: no universal default passwords, a published vulnerability disclosure policy, and a defined minimum software update support period. The device does not need to be directly internet-connected — Bluetooth connectivity is sufficient to trigger PSTI.

### Can I use the same RF test reports for UK and EU wearable compliance?

In most cases, yes. GB-designated standards for wearable radio equipment (EN 300 328 for Bluetooth, EN 301 489-17 for EMC, EN 50566 for SAR) are technically identical to the EU harmonised standards. A single set of test reports performed against these standards at an accredited laboratory supports both CE marking for the EU and UKCA marking for GB. Always verify the current GB-designated standards list, as standards are periodically updated.

### What labeling is required on a wearable product sold in Great Britain?

The product or its packaging must carry: the UKCA marking (or CE marking while accepted); the UK Responsible Person's name and address (required for non-UK manufacturers); a unique identification number if applicable; the manufacturer's name, trademark, and contact address; the country of origin; model/type/batch/serial number; and any specific information required by the applicable regulations (e.g., maximum SAR value for radio devices).

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Every standard, document, and test that applies — free, no account required.

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Educational resource only. Compliance responsibility remains with the manufacturer, importer, or UK Responsible Person. Verify current UK regulations before placing products on the GB market.