Where to place the UKCA marking

Legislation is now in force which enables the UKCA marking to be placed on a label affixed to the product or on a document accompanying the product until 11pm on 31 December 2027. This means that as of 1 January 2028, in most cases, you must affix the UKCA marking to the product itself or to the packaging.

In some cases, for example, where the product is too small, the UKCA marking can be affixed to the dataplate, packaging, a label affixed to the product or accompanying documentation. Please consult the sector specific legislation that applies to your products for more information.

The UKCA marking must be clearly visible, legible and indelible when you affix it to the product (or permitted alternatives). There are also rules about the size and dimensions of the UKCA marking (see below).

UKCA markings must only be placed on a product by you as the manufacturer, your authorised representative (where permitted in the relevant legislation), or if you are marketing the products under your name or trademark (for example, where you will take the responsibilities of the manufacturer, including affixing the UKCA marking).

When affixing the UKCA marking, you take full responsibility for conformity with the requirements of the relevant UK legislation.

You must not place any marking, sign or inscription which is likely to mislead any other person as to the meaning or form of the UKCA marking or affix any marking which would impair the visibility, legibility and meaning of the UKCA marking.

The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation.

A product may have additional markings and marks, as long as they:

· fulfil a different function from that of the UKCA marking or other recognised conformity markings (where permitted)

· are not likely to cause confusion with the UKCA marking or other recognised conformity markings (where permitted)

· do not reduce the legibility and visibility of the UKCA marking or other recognised conformity markings (where permitted)

Both the CE and UKCA markings can be placed on a product so long as the relevant (EU or GB respectively) rules are met, neither prevents the other being clearly seen and the requirements of both GB and EU legislation are met.

Accompanying documents

What form your accompanying document should take and how long it needs to be kept for depends on the product’s specific circumstances. For example, if a product is transferred in the course of a commercial activity (in a business-to-business or business-to-consumer transaction), the business supplying the product will be obliged to verify that the product bears the UKCA marking, in accordance with the relevant legislation.

It is the responsibility of the manufacturer to ensure that the technical documentation and other records relating to conformity assessment procedures are prepared in (or translated to) English regardless of if the product is UKCA or CE marked. They must also provide (in English) with the product itself or as a batch:

· the UKCA marking (if legislation permits the marking to be on an accompanying document)

· the UK Declaration of Conformity if UKCA marking the product

· the EU Declaration of Conformity if CE marking the product

· all relevant product instructions and safety information as the legislation requires

It is the responsibility of the importer to ensure the manufacturer has:

· drawn up the relevant technical documentation and instructions for use in English

· affixed the relevant conformity marking

· fulfilled their identification obligations of including their name and address in line with relevant guidelines

Each individual product will not necessarily need an accompanying document if moving through the supply chain as a batch. For example, when 1,000 units are moving from distributor A to distributor B, one accompanying document should be sufficient, if the information that must accompany the UKCA marking applies to all the units.

However, if distributor B were to then break the units up and supply them to separate distributors C, D, and E, each of these batches would need to be accompanied by the documents outlined above. This principle continues to apply as the units move through the supply chain towards the end user.

Before making a product available, to another distributor or to an end user, the distributor must ensure that:

· each product is marked with the UKCA marking (or the UKCA marking is on a label or document accompanying the product, where that is permitted)

· the manufacturer and importer have complied with their duties to label the product with their name and contact details

· instructions and safety information accompanies the product - they must be in clear, legible and easily understandable English