# CE Marking vs. UKCA: What Changed After Brexit

After Brexit, selling electronics in both Europe and the UK means two marks,
two declarations, and two sets of paperwork. This short breaks down exactly
what differs and what you can reuse.


## Transcript

### The situation

If you sell electronics in Europe and the UK, you used to need one mark. After Brexit, you need two. Here is what actually changed and what you can reuse.

### CE vs. UKCA at a glance

CE marking still covers all 27 EU states — your test reports, technical file, and self-declaration remain valid there. UKCA covers Great Britain only: England, Scotland, and Wales. It shares CE's requirements, but the legal basis is now UK law, not EU directives. Higher-risk products need a UK Approved Body instead of an EU Notified Body, and non-UK companies need a UK Responsible Person.

### What you can reuse

Good news: the same test data usually supports both marks — one EMC campaign, two sets of paperwork. You still need a separate UK Declaration of Conformity and a UKCA label. Northern Ireland stays on CE under the Windsor Framework. UKCA is a documentation exercise.

Tags: CE marking, UKCA, Brexit, UK compliance