This article was published in September 2020

Unlike Great Britain (England, Scotland and Wales) which is set to take onboard the UKCA mark, Northern Ireland is to remain with the EU CE marking system to ensure that it simplifies the case for Ireland as a whole, and to ensure that Northern Ireland is not disadvantaged by having to apply the UKCA mark. However, Northern Ireland does have some variances to the typical EU CE marking, such as the foreseen UK (NI) mark to be used in certain situations where a UK third party conformity body assessment can be used. Further information can be found on the gov.uk website, which provides guidance on the various trade routes to and from Northern Ireland.

To support our work at Conformance Ltd, we have also developed the following matrix to show all potential trade routes. We would like to note that this is subject to change as the UK government defines and agrees the way forward with the EU and is based on information currently published on the UK governments websites.

 

Export of new products (CAB INVOLVED) placed on the market     To
 GB  NI  EU  Non-EU/EEA
From      GB CE mark using EU Notified Body (OK until 1st Jan 2022).

UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022).
N.B. Actual UKCA mark on the product does not need to be attached until 1st Jan 2023.

Either:

CE mark using EU Notified Body, or

CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021.
Not certain - more UK government information to follow.

 
CE mark using EU Notified Body  Local laws apply 
 NI Three options:

UKCA mark (can be used from 1st Jan 2021) using UK Approved Body,

CE mark using EU Notified Body, or

CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021.
Not certain - more UK government information to follow.

Either:

CE mark using EU Notified Body, or

CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021.
Not certain - more UK government information to follow.

 
CE mark using EU Notified Body.  Local laws apply 
 EU
CE mark using EU Notified Body (OK until 1st Jan 2022).

UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022).
N.B. Actual UKCA mark on the product does not need to be attached until 1st Jan 2023.

CE mark using EU Notified Body. CE mark using EU Notified Body. Local laws apply
 Non-EU/EEA

CE mark using EU Notified Body (OK until 1st Jan 2022).

UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022)
N.B. Actual UKCA mark on the product does not need to be attached until 1st Jan 2023.

 

Either:

CE mark using EU Notified Body, or

CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021.
Not certain - more UK government information to follow.

 
CE mark using EU Notified Body. Local laws apply 

 

Export of new SELF
CERTIFIED products placed on the market

To    
 GB  NI EU   Non-EU/EEA
From      GB  

CE mark (can be used up until 1st Jan 2022).

UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022)
N.B. Actual UKCA mark on the product does not need to be attached until 1st Jan 2023.

 

CE mark

 

 

CE mark

 

Local laws apply 
 NI  

Either,

UKCA mark (can be used from 1st Jan 2021), or

CE mark

CE mark  CE mark  Local laws apply 
 EU

CE mark (can be used up until 1st Jan 2022).

UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022).
Actual UKCA mark on product does not need to be attached until 1st Jan 2023.

 
CE  mark CE mark  Local laws apply
 Non-EU/EEA

CE mark (can be used up until 1st Jan 2022).

UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022).
Actual UKCA mark on product does not need to be attached until 1st Jan 2023.

 
CE mark CE mark Local laws apply

 

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