UKCA Marking vs CE: What US Brands Need in 2026

A US consumer electronics brand came to us this year with a range of wireless products, strong US sales and a plan to be live on Amazon UK before Christmas. Every product carried the CE mark. The declarations of conformity (DoCs) referenced EU law only, and none of them addressed UK law.

The short answer: for most consumer electronics covered by the UK's continued recognition regime, a US brand does not need UKCA marking to sell in Great Britain. CE marking remains an accepted route in the UK with no current end date. What stops a UK launch is rarely the mark on the box. It is the paperwork behind it.

That is a common position for US brands, and it is fixable, whichever of UKCA or CE marking the brand chooses. Left alone, it can hold stock at the border, get listings suppressed or leave the brand without a legal presence in the UK or EU when a regulator or marketplace asks. Below is what the rules say, where US brands get caught, and the steps we took.

Is UKCA marking still required in 2026?

UKCA was introduced on 1 January 2021 as the Great Britain replacement for CE. The switchover deadline was pushed back several times, then dropped. The Product Safety and Metrology etc. (Amendment) Regulations 2024 came into force on 1 October 2024 and recognise CE marking in GB indefinitely across 21 product regulations.

Those 21 cover most of what our clients sell: radio equipment, EMC, low voltage electrical equipment, RoHS, toys, machinery and ecodesign. Sector regimes such as medical devices and construction products sit outside it and follow their own rules.

UKCA vs CE marking: the three routes into Great Britain

In practice that gives a brand three routes into GB.

CE only

• What it means: Meet EU requirements, affix CE, sell in GB and the EU
• When we use it: Most consumer electronics, fastest route

UKCA only

• What it means: Meet GB requirements under UK regulations
• When we use it: Rare, GB-only products

CE and UKCA

• What it means: Both marks, backed by an EU and a UK declaration, often combined in one document
• When we use it: Brands wanting one controlled document set for both markets

Northern Ireland continues to follow EU rules, so CE is required there regardless.

One caveat matters. Where a UK designated standard and the EU harmonised standard have drifted apart, a CE-marked product may need extra checks before it is placed on the GB market. For wireless consumer products that gap is small today, but it is worth checking rather than assuming.

UKCA marking requirements: where US compliance files fall short

The mark is the easy part. These are the five gaps we find most often in a US compliance file, and each one has a cost if it surfaces after stock has shipped.

1. EU-only declarations of conformity. A DoC that lists EU directives only is legally workable for the CE route into GB. But it leaves nothing to show if the brand later wants UKCA, and it invites questions from marketplaces, 3PLs and importers who expect to see the UK regulations named.
2. No one in the UK or EU to answer for the product. Since 13 December 2024, Article 16 of the EU General Product Safety Regulation (GPSR) has required an EU-established economic operator responsible for the product. Depending on the supply chain, that can be the manufacturer, importer, authorised representative or a fulfilment service provider. Their details must appear on the product, packaging, parcel or an accompanying document. Article 19 goes further for online sales: the listing itself must show the manufacturer and, for a non-EU manufacturer, the EU responsible person's name, postal address and electronic address. In GB you will often see the phrase "UK responsible person", but for most consumer electronics the role that matters is the importer. The importer has real duties, including checking conformity, documentation and markings, and its name and address must appear on the product, packaging or an accompanying document. A US company shipping straight into Amazon FBA often has neither in place.
3. Connected products and cyber security. If a product falls within the UK's consumer connectable product regime, the Product Security and Telecommunications Infrastructure (PSTI) rules have applied since 29 April 2024. They require no universal default passwords, published vulnerability reporting information and a stated minimum security update period. In the EU, cyber security requirements under the Radio Equipment Directive have applied since 1 August 2025 to defined categories of radio equipment, including internet-connected radio equipment. The Cyber Resilience Act's main requirements follow from 11 December 2027. A DoC written before these dates is unlikely to address them.
4. Out-of-date standards. DoCs are often issued once and never revisited. Standards referenced in older documents may since have been replaced.
5. Producer registrations. WEEE, battery and packaging obligations are separate from product conformity. Producer status has to be established for each country and sales model, and these registrations are usually missing entirely. For UK packaging, our guide to UK packaging EPR explains which business holds the obligation.

None of this is exotic. It is simply work that US teams have no reason to know about until a listing is blocked or a shipment is queried.

How we rebuilt one US brand's compliance file

We built compliance into the launch plan from the start. It ran alongside VAT, marketplace set-up and logistics, so nothing waited on anything else.

Step 1: Audit the file, SKU by SKU

We went through every product in the range and mapped every DoC against the regimes that apply: radio equipment, EMC, electrical safety, RoHS and product safety. The declarations were newly issued, yet none of them would have held up.

• Each was an EU-only declaration listing EU directives, with no UK regulations for radio, EMC or electrical safety and no UKCA route.
• The contract manufacturer was named as the manufacturer and had signed with a company stamp, when the brand selling under its own name is the legal manufacturer.
• The same overseas factory was listed as the EU authorised representative, which is not possible: an authorised representative must be established in the EU.
• No GB importer or EU responsible economic operator was identified.
• The signatory name and role, and the place of issue, were blank.
• Environmental rules such as REACH and WEEE sat in the standards table, although they are separate obligations that do not belong on a DoC.

Step 2: Choose the route for Great Britain

Because the products fall under the regulations covered by indefinite CE recognition, CE alone would have been legal. We went a step further and rebuilt each declaration as a combined EU and UK document, issued by the brand as legal manufacturer. It contains the information required for both an EU declaration of conformity and a UK declaration of conformity. Each standard cited was mapped to its GB designated equivalent, so the existing test evidence could support both declarations without re-testing.

Step 3: Put a UK and EU presence in place

We appointed a specialist compliance provider to take on the statutory GB importer role and to act as the EU responsible economic operator under GPSR Article 16. That role goes well beyond providing an address, and it is different from acting as importer of record for customs. Rather than setting up legal entities in both markets, the brand has an established operator on each side of the Channel. Their details were added to packaging and to the online listings, covering GPSR Articles 16 and 19 in the EU and the importer identification rules in GB.

Step 4: Build compliance into the listings

Localised UK listings and A+ content carry the right safety information, warranty terms, manufacturer details and responsible operator details from day one.

Step 5: Line up the rest of the launch around it

UK VAT registration, Amazon KYC and UK listings were completed early. Product data and barcodes went to the 3PL ahead of arrival so stock could be booked in without delay.

UK declaration of conformity: what a combined EU and UK version contains

A combined declaration is one document per product containing the information required for both an EU declaration of conformity and a UK declaration of conformity. Legally they remain two declarations under two regimes. Combining them simply gives the brand one controlled document to maintain. The template we built for this client runs to ten sections:

1. Product: product name, model, SKU, brand and the units covered
2. Manufacturer: legal entity, registered address and country
3. GB importer: name, UK postal address and contact
4. EU responsible economic operator: role (for example authorised representative or importer), name, EU postal and electronic address, company identifier
5. Object of the declaration: what the product is, including frequency band and maximum RF output power for radio equipment
6. Legislation applied: each EU directive paired with its UK regulation
7. Standards applied: each EU harmonised standard, its UK designated equivalent and the test laboratory
8. Notified or approved body: the body used, or why none was needed
9. Marking: which marks appear on product and packaging, and for which market
10. Signature: place and date of issue, name, role and signature

For a typical wireless consumer product, section 6 pairs up like this:

• Radio Equipment Directive 2014/53/EU pairs with the Radio Equipment Regulations 2017 (SI 2017/1206)
• EMC Directive 2014/30/EU pairs with the Electromagnetic Compatibility Regulations 2016 (SI 2016/1091)
• Low Voltage Directive 2014/35/EU pairs with the Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101)
• RoHS Directive 2011/65/EU, as amended by (EU) 2015/863 pairs with the RoHS Regulations 2012 (SI 2012/3032)

The useful part is section 7. Where the relevant EU harmonised standard and GB designated standard remain technically aligned, the same underlying test evidence can usually support both declarations. The standards need to be checked rather than assumed to be equivalent. Where they line up, a combined declaration improves the paperwork without any new testing.

What changed for the brand

The brand now goes to market fully compliant in both the UK and the EU, on the test evidence it already had. Every product moved from a declaration that would have failed its first challenge to a combined EU and UK declaration issued by the brand as legal manufacturer, with the right economic operator identified in each market.

• The full range is in transit, with UK availability planned ahead of peak season.
• Every product has a combined EU and UK declaration, a GB importer and an EU responsible economic operator, ready for any marketplace or regulator request.
• The same file carries straight into the EU roll-out. EU VAT registrations are already under way.

The commercial point is simple. Compliance done early costs a few weeks of desk work. Compliance done late costs a Christmas.

UKCA and CE marking checklist for US brands entering the UK

Before you book freight, check that you can answer yes to each of these:

• Every SKU has a current DoC, and you know which regulations it names.
• You have decided between CE, UKCA or both for GB, and why.
• You have identified the correct economic operator for each market: the GB importer where required, and the EU Article 16 responsible economic operator. Their details appear on the product, packaging or documentation, and on the online listing, as applicable.
• You have checked whether connected products fall within PSTI in the UK and the RED cyber security requirements in the EU, and planned for the Cyber Resilience Act from December 2027.
• The standards in your DoCs are the current editions.
• WEEE, battery and packaging producer status is established, with registrations in place, for each country and sales model.
• Your listings carry the same safety, manufacturer and responsible operator details as your packaging.

If any of those is a no or a maybe, that is exactly the work we do. We take US brands into the UK and EU and handle compliance, VAT, marketplaces and logistics as one plan, so launch dates hold. Book a 30-minute call and we will tell you plainly where your file stands.

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Frequently Asked Questions

Do I need UKCA marking to sell in the UK?

For most consumer electronics, no. Since 1 October 2024, CE marking has been recognised in Great Britain indefinitely across 21 product regulations, including radio equipment, EMC, low voltage electrical equipment, RoHS, toys, machinery and ecodesign. Sector regimes such as medical devices and construction products follow their own rules, and Northern Ireland continues to require CE.

Is CE marking still valid in the UK?

Yes. The Product Safety and Metrology etc. (Amendment) Regulations 2024 came into force on 1 October 2024 and recognise CE marking in Great Britain indefinitely across 21 product regulations. A product can also carry both the CE and UKCA marks, backed by an EU and a UK declaration, which are often combined in one document.

Does a CE-marked product need re-testing for the UK?

Usually not. Where the EU harmonised standard and the GB designated standard remain technically aligned, the same test evidence can usually support both a UK and an EU declaration. The standards need to be checked rather than assumed to be equivalent, because where they have drifted apart a CE-marked product may need extra checks before it is placed on the GB market.

Who is responsible for a product in the UK if the brand is based in the US?

For most consumer electronics, the role that matters in Great Britain is the importer. The importer must check conformity, documentation and markings, and its name and address must appear on the product, packaging or an accompanying document. A US company shipping straight into Amazon FBA often has no GB importer in place.

Does PSTI compliance apply to my product?

The PSTI rules apply if your product falls within the UK's consumer connectable product regime. Since 29 April 2024, those products must have no universal default passwords, published vulnerability reporting information and a stated minimum security update period. A DoC written before that date is unlikely to address them.

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References

1. Hogan Lovells - Outside but aligned: CE marking to remain indefinitely recognised in the UK
2. GOV.UK - UK government announces extension of CE mark recognition for businesses
3. GOV.UK - Placing UKCA or CE marked products on the market in Great Britain