The UK left the EU on January 31, 2020 at midnight. The transitional period started on February 1 and ends December 31, 2020. This transitional period may be extended. During this period, the UK continues to apply EU law (but will have no say over it). The CE mark applies.

Negotiations about the future relationship between the UK and EU (after the transitional period ends) started in early March 2020. The outcome is anyone’s guess and can vary between mutual recognition with free circulation of products and no agreement at all. The latter requiring products to be designed, (3rd party) tested and (self) certified to EU and (still to be released) UK regulations and standards.

Manufacturers, who use a UK Notified Body (NB) and/or a UK Authorized Representative (AR) should switch without undue delay to an EU based NB and/or EU AR to maintain access to the EU market. Reserve as applicable space on product labeling for the UKCA mark.

Manufacturers, who use an EU NB and/or an EU AR should start looking into setting up a UK AR and building up relationships with (still to be) UK recognized equivalents of EU NB’s and 3rd party test facilities to maintain access to the UK market. Reserve as applicable space on product labeling for the UKCA mark.