Home What Does Brexit Mean for Electrical and Electronic Product Restricted Substance Compliance?

What Does Brexit Mean for Electrical and Electronic Product Restricted Substance Compliance?

Press Release: November 12, 2020

The UK government has published guidance to help manufacturers and importers placing electrical and electronic (EE) products onto the UK market after the end of the Brexit transition arrangements on December 31, 2020.


From January 1, 2021, EE products that are currently subject to CE marking should bear the new UKCA (Conformity Assessment) mark. A one-year transition period has been granted until January 1, 2022, during which the CE mark will still be accepted, with some exemptions. After this date, products offered onto the UK market must carry the UKCA mark. It should be noted, the UKCA mark is not recognized in the Europe Union.  


The procedure for conformity assessment in the UK will be similar to that for the CE mark, but with the following differences:

  1. January 1, 2021 – authorized representatives or responsible persons in the EU will no longer be recognized. Instead, a UK-based authorized representative or responsible person must be assigned for the UKCA mark
  2. UKCA mark can only be granted by a UK approved conformity assessment body
  3. UK Declaration of Conformity (DoC) – while the requirements are basically the same as for the EU DoC, the relevant UK legislation and UK designated standards should be listed instead of those cited in the Official Journal of the EU


The UKCA mark must be applied to all EE products that currently bear a CE mark.


Stakeholders should be aware, at the current time, the UK has no plans to diverge from other EU restricted substance requirements – REACH, POPs, food contact materials, etc.


SGS Electrical and Electronic Product Services

SGS’s global network of accredited testing laboratories and specialized teams of local experts offer a range of services to manufacturers and retailers in the electronics industry. They understand regulations and standards for every product and target market and can help reduce risk, improve efficiency, and ensure compliance. Learn more about SGS’s Electrical and Electronic Product Services.


SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full Brexit – What will happen to the restricted substances requirements of your manufactured EE products? SafeGuardS. 


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For further information contact:


Tiffany Tsui

Technical Services Executive

Tel: 2774 7160

Email: [email protected]

Website: www.sgs.com/ee 

LinkedIn: sgs-consumer-goods-&-retail


About SGS

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 89,000 employees, SGS operates a network of over 2,600 offices and laboratories around the world.

Notes to editors

For more information, please contact:

Ben Christie

Tel: +441892711240

Email: [email protected]

Visit the newsroom of: Ben Christie