EU & UK compliance of Electronic devices from 1 January 2021

23rd February 2021 | News
As TechWorks members will be aware, the transition period following the UK’s departure from the EU ended on 31 December 2020, at which point the new EU-UK Trade and Cooperation Agreement came into force. This article provides information for those members who are suppliers of electronic goods to the EU and/or UK and focuses on the specific areas of EMC, Radio Equipment and Low Voltage Directives and the equivalent UK regulations.

Previously, CE marking showed that the manufacturer has checked that their products meet EU safety, health and environmental requirements and has also provided an indication of product’s compliance with EU legislation.However, the EU-UK Trade and Cooperation Agreement does not include any Mutual Recognition of conformity assessment between the EU and UK. Therefore, the UK Govt has introduced its own “UK Conformity Assessed” or UKCA marking.

The UKCA mark is not accepted on the EU market and, after a transition period, the CE mark will not be accepted on the GB market (England, Scotland & Wales). There are different rules in place for the Northern Ireland market.

For equipment on the market in GB (not NI) then UKCA marking is required; however, in most cases it will be possible to continue using CE marking until the end of 2021. From the beginning to 2022 it will be necessary to use UKCA marking instead of CE marking and complete a Declarations of Conformity (DoC) to UK Regulations; Electromagnetic Compatibility Regulations 2016Radio Equipment Regulations 2017Electrical Equipment (Safety) Regulations 2016. As for the equivalent EU Directives (EMCD, RED & LVD) it will be permissible for manufacturers to self-declare compliance to these regulations. Testing (e.g. for EMI/EMC) will continue to use EN standards. However, over time, there are expected to be separate UK standards though these are likely (at least in the first instance) to be harmonised with the EU.

For equipment manufactured in the UK and placed on the market in the EU then CE marking continues to apply, as the EU does not recognise the UKCA mark. In this scenario, testing should continue to be to EN standards, in accordance with the relevant EU Directives.

There are separate regulations concerning manufactured equipment placed on the Northern Ireland market. In this scenario, CE marking continues to apply; however, it is also possible to use UKNI marking. See the specific guidance here: placing goods on the Northern Ireland market.

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