# /news-insights/what-is-ce-marking-ukca-marking-eu-uk-guide  —  What Is CE Marking and UKCA Marking? EU and UK Guide
# https://o1.eu/news-insights/what-is-ce-marking-ukca-marking-eu-uk-guide
# Operator One — Merchant of Record for European marketplaces.

## Metadata
- Canonical URL: https://o1.eu/news-insights/what-is-ce-marking-ukca-marking-eu-uk-guide
- Published: 2026-09-13
- Publisher: Operator One (https://o1.eu)

## Summary
CE and UKCA marking explained: who affixes it, the EU and UK law behind it, conformity routes, the 10-year file duty and how marketplaces check it.

## Full article
By Operator One Editorial — 13 September 2026

## Key takeaways

- Under Regulation (EC) No 765/2008 Article 30(1), only the manufacturer or its authorised representative affixes the CE marking; no authority issues it and there is no "CE certificate" to apply for in most consumer categories.

- The EU Declaration of Conformity and technical documentation must be kept for 10 years under the Low Voltage Directive 2014/35/EU Article 6(3), and the importer keeps a copy of the declaration for 10 years under Article 8(8).

- Under Regulation (EU) 2019/1020 Article 4(2), a product in scope needs one of four EU-established operators responsible for it; an EU importer satisfies this alone.

- Great Britain continues to recognise CE marking: UK SI 2024/696, in force from 1 October 2024, removed the planned expiry, and UKCA remains an alternative.

- Marketplaces ask for proof: bol stops new assortment without manufacturer data, Kaufland can hide offers with missing or incorrect CE marking, and Zalando rejects articles without a CE label photo.

## What it is

CE marking is the marking by which the manufacturer indicates that a product conforms with the applicable requirements of the EU harmonisation legislation that provides for its affixing, as defined in Regulation (EC) No 765/2008 Article 2(20). UKCA marking is the Great Britain equivalent, a conformity marking affixed by the manufacturer under UK product regulations for products placed on the market in England, Scotland and Wales.

Neither marking is an approval. The European Commission states that a CE marking does not indicate that a product has been approved as safe by the EU or by another authority, and that it does not indicate the origin of a product either. By affixing it, the manufacturer takes responsibility for the product's conformity, under Regulation (EC) No 765/2008 Article 30(3). For related terms, see the compliance glossary (https://o1.eu/compliance-glossary).

## The legal basis

The general principles of CE marking are in Article 30 of Regulation (EC) No 765/2008 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0765). Article 30(2) says the CE marking may only be affixed to products for which specific EU harmonisation legislation provides for it, so a product outside that legislation must not carry it. Article 30(5) prohibits markings likely to mislead third parties about the meaning or form of the CE marking. Annex II sets the graphic: proportions must be respected when the mark is resized, and the vertical dimension may not be less than 5 mm unless the sector legislation says otherwise.

The CE marking obligation itself comes from the product act. The European Commission lists 31 legislative acts aligned with the New Legislative Framework; examples that require CE marking include the Low Voltage Directive 2014/35/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035), the Radio Equipment Directive 2014/53/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0053) and the Toy Safety Directive 2009/48/EC (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0048).

Responsibility in the EU supply chain is set by Regulation (EU) 2019/1020 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020) Article 4, which requires an EU-established manufacturer, importer, authorised representative or fulfilment service provider for products under the acts listed in Article 4(5). Article 4(4) requires that operator's name and contact details, including a postal address, on the product, packaging, parcel or an accompanying document. For products in the scope of the General Product Safety Regulation (EU) 2023/988 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0988), which applies from 13 December 2024, Article 16(1) requires an EU responsible person and Article 16(3) adds an electronic address.

In the UK, the Product Regulation and Metrology Act 2025 (https://www.legislation.gov.uk/ukpga/2025/20) received Royal Assent on 21 July 2025 and gives the Secretary of State power to make product regulations, including on recognition of EU rules.

## Who it applies to

The manufacturer carries the CE work. Under Directive 2014/35/EU Article 7(1), the obligation to design and build the product and the drawing up of technical documentation cannot form part of an authorised representative's mandate. Under Article 7(2), the mandate must at least allow the representative to keep the declaration and technical documentation for 10 years, provide information on reasoned request, and cooperate on corrective action. Under Regulation (EU) 2019/1020 Article 5(2), the representative provides a copy of its mandate in an EU language specified by the authority.

Importers have their own duties. Under Directive 2014/35/EU Article 8, an importer checks that the conformity assessment was carried out, the technical documentation exists and the CE marking is affixed; indicates its own name and postal address on the product; ensures instructions and safety information are in a language consumers easily understand; keeps storage and transport conditions from compromising conformity; and carries out sample testing where appropriate. Appointing an importer or an authorised representative does not move the CE work away from the manufacturer.

A seller can become the manufacturer. Under Directive 2014/35/EU Article 10, an importer or distributor that places a product on the market under its own name or trade mark, or modifies it in a way that may affect compliance, is treated as the manufacturer and takes on all of its obligations. The same logic applies to a Merchant of Record that rebrands or modifies goods.

## How to get it, step by step

- Identify the applicable EU acts. Check the European Commission's New Legislative Framework list and Your Europe pages to find every act that covers the product, for example the Low Voltage Directive 2014/35/EU and Radio Equipment Directive 2014/53/EU. There is no official fee for CE marking and no application to any authority.

- Confirm the essential requirements and standards. Map each requirement to the harmonised standards cited in the Official Journal. For connected radio products, Delegated Regulation (EU) 2022/30 has applied since 1 August 2025, and Implementing Decision (EU) 2025/138 cites the EN 18031 series with restrictions. Buying standards from a national standards body is a private cost, not a CE fee.

- Choose the conformity assessment route. The Low Voltage Directive uses Module A only, with no notified body. Toys and radio equipment need a notified body in defined cases. Find a body in the Commission's NANDO database; notified bodies are designated by Member States and set their own fees by contract. No statutory processing time applies.

- Test and assess the product. Run the tests the standards require, in-house or at an accredited laboratory, and record the results. Where a notified body is involved, it performs only its part of the procedure, such as EU-type examination under Radio Equipment Directive Annex III, and issues a certificate for that part.

- Compile the technical file and sign the EU Declaration of Conformity. Include an adequate analysis and assessment of the risks, drawings, standards applied and test reports. Draw up the declaration following Directive 2014/35/EU Annex IV, translate it into the languages the Member State requires, keep it updated, and retain both documents for 10 years.

- Affix the CE marking and traceability details. Place the CE mark visibly, legibly and indelibly, at least 5 mm high under Regulation (EC) No 765/2008 Annex II, with type or batch identification, the manufacturer's name and postal address, and the importer's details where applicable.

- Cover Great Britain and Northern Ireland. For Great Britain, keep using CE or apply UKCA via self-declaration or a UK Approved Body accredited by UKAS and listed on UKMCAB. For Northern Ireland, use CE, or CE plus UKNI where a UK body performed mandatory third-party assessment. Then upload documents to each marketplace.

## Conformity routes, bodies and timelines by regime

| Regime | Conformity route | Third party | Official fee | Key date |

| Low Voltage Directive 2014/35/EU | Module A, internal production control | None | None published | Documents kept 10 years |

| Radio Equipment Directive 2014/53/EU | Art. 3(2) and 3(3) requirements: Annex II if harmonised standards fully applied, otherwise Annex III or IV; Art. 3(1) always allows Annex II | Notified body for Annex III or IV; number shown next to CE only under Annex IV | None published; body fees by contract | Cybersecurity rules from 1 August 2025 |

| Toy Safety Directive 2009/48/EC | Module A with full harmonised standards; EU-type examination plus Module C in four cases in Art. 19(3) | Notified body in those four cases | None published | Replaced by Regulation (EU) 2025/2509 from 1 August 2030 |

| Machinery Regulation (EU) 2023/1230 | Not in Annex I: Module A. Annex I Part B: Module A only with standards or common specifications covering all relevant requirements, otherwise B plus C, H or G | Required outside the Module A cases | None published | Applies from 14 January 2027 |

| Great Britain (UKCA or CE) | Self-declaration or UK Approved Body; Fast-Track UKCA recognises EU requirements | UK Approved Body where required | None published | UKCA label easement to 11pm, 31 December 2027 |

| Northern Ireland | CE, or CE plus UKNI | EU notified body, or UK body (then UKNI) | None published | UKNI never used alone |

## What happens if you skip it

Penalties are national. Regulation (EC) No 765/2008 Article 30(6) requires Member States to provide penalties for improper use of the CE marking, which may include criminal sanctions for serious infringements, and General Product Safety Regulation Article 44 leaves penalties to Member States as well. Under Regulation (EU) 2019/1020, market surveillance authorities can order withdrawal, recall or a ban on making the product available.

In Germany, the Product Safety Act (ProdSG) § 28(1) nos. 5 and 6 make CE marking breaches administrative offences, and ProdSG § 28(3) caps the fine for those offences at EUR 10,000, while other listed offences reach EUR 100,000. ProdSG § 29, which covers only other specified offences, does not turn these CE marking offences into crimes.

In the UK, gov.uk guidance says enforcement bodies will often let the operator work constructively to bring a product into conformity, and that an operator who fails to cooperate will be obliged to withdraw or recall the product. Under the Electrical Equipment (Safety) Regulations 2016 regulation 51(2), breaching the 10-year retention duties for the declaration and technical file in regulations 7 and 21 is a summary-only offence carrying up to 3 months' imprisonment or a fine.

Documentation gaps also carry GPSR duties for products in its scope: under Regulation (EU) 2023/988 Article 15(4), economic operators must be able to present risk information for 10 years, and under Article 15(5) supplier and customer traceability information for six years.

## How marketplaces check

Marketplaces are under their own deadlines. Under Regulation (EU) 2023/988 Article 22(4), an online marketplace must act on an authority order about a dangerous product within two working days, and under Article 22(8) it must process product safety notices within three working days. Article 22(9) requires marketplaces to let traders display the manufacturer's details, the EU responsible person's name, postal and electronic address, product identification and warnings.

- bol: from 5 March 2026, new assortment missing manufacturer data does not go online, and from 1 April 2026 bol takes existing listings offline in phases where manufacturer data is missing. A bol partner article dated 7 September 2021 told sellers to have CE information available at all times and warned of fines, refusal or removal, adding: "...dat je uit een land buiten de EU komt? Dan dien je een kopie van de EG-verklaring van overeenstemming hebben."

- Kaufland Global Marketplace: documents are supplied in the attributes ce_certificate, safety_guidelines and safety_data_sheet, via routes including the API, CSV import and the Seller Portal. Declarations must be in the language of the country of sale and signed, Kaufland reserves the right to hide offers where CE marking is missing or incorrect, and an EU responsible person is obligatory for manufacturers outside the EU.

- Zalando: watches, articles with batteries, smart accessories, sunglasses and goggles, protective gloves and helmets, and all toys need a photo showing the article and CE label together, as do goalkeeper gloves described as protective, UV-protective apparel and light-up garments. Rejection code ACSREJ_258 means no CE label image was supplied, and ACSREJ_278 means label and article are not recognisable together.

## Frequently asked questions

### Is there a CE certificate I can apply for?

No. Under Regulation (EC) No 765/2008 Article 30(1), only the manufacturer or its authorised representative affixes the CE marking, and no authority issues it. For most consumer categories there is no CE certificate; what exists is the manufacturer's EU Declaration of Conformity and, where a notified body took part, that body's certificate for its part of the assessment.

### Does CE marking mean the EU approved my product as safe?

No. The European Commission states that a CE marking does not indicate that a product has been approved as safe by the EU or by another authority, and that it does not indicate the origin of a product either. It is the manufacturer's own declaration of conformity.

### Can I put a CE mark on any product to look compliant?

No. Regulation (EC) No 765/2008 Article 30(2) allows the CE marking only on products whose EU harmonisation legislation provides for it, and Article 30(5) prohibits markings likely to mislead about its meaning or form. In Germany, ProdSG § 28(3) caps the administrative fine for these CE marking offences at EUR 10,000.

### Must a notified body number appear next to the CE mark?

Only where the legislation requires it. Under the Radio Equipment Directive 2014/53/EU, the notified body number is required only when the full quality assurance route in Annex IV was used, so a product that passed EU-type examination under Annex III legitimately carries no number. The Low Voltage Directive 2014/35/EU uses Module A and involves no notified body at all.

### Can an importer or Merchant of Record take over CE marking?

No. CE marking, conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer under Regulation (EC) No 765/2008 Article 30(1). An importer verifies the file exists, adds its name and postal address and keeps the declaration for 10 years. Under Directive 2014/35/EU Article 10, an importer that sells under its own name or trade mark, or modifies the product, becomes the manufacturer.

### Is CE marking still accepted in Great Britain?

Yes. UK SI 2024/696, in force from 1 October 2024, removed the planned end date for CE recognition, and gov.uk guidance published 31 March 2026 and updated 21 August 2026 says the UK continues to recognise CE alongside or instead of UKCA. The SI amends a defined list of product regulations, so check that your product's regulations appear in its contents.

### What marking do products need in Northern Ireland?

Northern Ireland follows EU rules: products carry CE, or CE together with UKNI where a UK body carried out mandatory third-party conformity assessment. According to gov.uk, UKNI is never used on its own. Qualifying Northern Ireland goods have unfettered access to the Great Britain market on the same markings.

### Does UKCA marking work in Jersey, Guernsey or the Isle of Man?

No. According to gov.uk, the UKCA marking does not apply in the 3 Crown Dependencies of Guernsey, Jersey and the Isle of Man, and it does not apply in the British Overseas Territories. Check local rules before shipping there.

### Do I need an authorised representative if I already have an EU importer?

Not for Regulation (EU) 2019/1020 Article 4. Article 4(2) lists 4 eligible EU operators, and an EU importer satisfies the requirement alone. Under Article 5(2), an authorised representative, if you appoint one, must supply a copy of its mandate in an EU language the authority specifies.

### What CE rule changes are coming?

The Machinery Regulation (EU) 2023/1230 applies from 14 January 2027. The Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030 and replaces the EU Declaration of Conformity with a digital product passport; toys placed on the market under Directive 2009/48/EC before that date may stay available. The Construction Products Regulation (EU) 2024/3110 also replaces the previous framework in stages.

## Where a Merchant of Record carries this obligation

When Operator One acts as Merchant of Record (https://o1.eu/merchant-of-record) and imports the goods, it is the EU importer, and therefore the EU responsible economic operator under Regulation (EU) 2019/1020 Article 4(2) and, for GPSR products, Article 16 of Regulation (EU) 2023/988. For harmonised electronics the obligation attaches through Article 4 of Regulation (EU) 2019/1020 together with the sector importer article, such as Radio Equipment Directive Article 12. Because an EU importer satisfies Article 4 alone, no separate authorised representative is needed for that purpose.

CE marking, conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer under Regulation (EC) No 765/2008 Article 30(1). As importer, Operator One verifies that the file exists, adds its name and address, keeps the declaration for 10 years and runs corrective action if a product is found non-compliant. Listings show the client as Brand and Operator One as the seller. To check a product line, contact (https://o1.eu/contact) the team.

Sources: Regulation (EC) No 765/2008 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0765); Regulation (EU) 2019/1020 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020); Regulation (EU) 2023/988 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0988); Directive 2014/35/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035); Directive 2014/53/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0053); Regulation (EU) 2025/2509 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2509); Regulation (EU) 2023/1230 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230); European Commission, CE marking (https://single-market-economy.ec.europa.eu/single-market/ce-marking_en); gov.uk, Using the UKCA marking (https://www.gov.uk/guidance/using-the-ukca-marking); gov.uk, Using the UKNI marking (https://www.gov.uk/guidance/using-the-ukni-marking); UK SI 2024/696 (https://www.legislation.gov.uk/uksi/2024/696/contents/made); ProdSG § 28 (https://www.gesetze-im-internet.de/prodsg_2021/__28.html).

## FAQ (structured)
Q: Is there a CE certificate I can apply for?
A: No. Under Regulation (EC) No 765/2008 Article 30(1), only the manufacturer or its authorised representative affixes the CE marking, and no authority issues it. For most consumer categories there is no CE certificate; what exists is the manufacturer's EU Declaration of Conformity and, where a notified body took part, that body's certificate for its part of the assessment.

Q: Does CE marking mean the EU approved my product as safe?
A: No. The European Commission states that a CE marking does not indicate that a product has been approved as safe by the EU or by another authority, and that it does not indicate the origin of a product either. It is the manufacturer's own declaration of conformity.

Q: Can I put a CE mark on any product to look compliant?
A: No. Regulation (EC) No 765/2008 Article 30(2) allows the CE marking only on products whose EU harmonisation legislation provides for it, and Article 30(5) prohibits markings likely to mislead about its meaning or form. In Germany, ProdSG § 28(3) caps the administrative fine for these CE marking offences at EUR 10,000.

Q: Must a notified body number appear next to the CE mark?
A: Only where the legislation requires it. Under the Radio Equipment Directive 2014/53/EU, the notified body number is required only when the full quality assurance route in Annex IV was used, so a product that passed EU-type examination under Annex III legitimately carries no number. The Low Voltage Directive 2014/35/EU uses Module A and involves no notified body at all.

Q: Can an importer or Merchant of Record take over CE marking?
A: No. CE marking, conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer under Regulation (EC) No 765/2008 Article 30(1). An importer verifies the file exists, adds its name and postal address and keeps the declaration for 10 years. Under Directive 2014/35/EU Article 10, an importer that sells under its own name or trade mark, or modifies the product, becomes the manufacturer.

Q: Is CE marking still accepted in Great Britain?
A: Yes. UK SI 2024/696, in force from 1 October 2024, removed the planned end date for CE recognition, and gov.uk guidance published 31 March 2026 and updated 21 August 2026 says the UK continues to recognise CE alongside or instead of UKCA. The SI amends a defined list of product regulations, so check that your product's regulations appear in its contents.

Q: What marking do products need in Northern Ireland?
A: Northern Ireland follows EU rules: products carry CE, or CE together with UKNI where a UK body carried out mandatory third-party conformity assessment. According to gov.uk, UKNI is never used on its own. Qualifying Northern Ireland goods have unfettered access to the Great Britain market on the same markings.

Q: Does UKCA marking work in Jersey, Guernsey or the Isle of Man?
A: No. According to gov.uk, the UKCA marking does not apply in the 3 Crown Dependencies of Guernsey, Jersey and the Isle of Man, and it does not apply in the British Overseas Territories. Check local rules before shipping there.

Q: Do I need an authorised representative if I already have an EU importer?
A: Not for Regulation (EU) 2019/1020 Article 4. Article 4(2) lists 4 eligible EU operators, and an EU importer satisfies the requirement alone. Under Article 5(2), an authorised representative, if you appoint one, must supply a copy of its mandate in an EU language the authority specifies.

Q: What CE rule changes are coming?
A: The Machinery Regulation (EU) 2023/1230 applies from 14 January 2027. The Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030 and replaces the EU Declaration of Conformity with a digital product passport; toys placed on the market under Directive 2009/48/EC before that date may stay available. The Construction Products Regulation (EU) 2024/3110 also replaces the previous framework in stages.

## Steps (structured)
1. Identify the applicable EU acts: Check the European Commission's New Legislative Framework list and Your Europe pages to find every act that covers the product, for example the Low Voltage Directive 2014/35/EU and Radio Equipment Directive 2014/53/EU. There is no official fee for CE marking and no application to any authority.
2. Confirm the essential requirements and standards: Map each requirement to the harmonised standards cited in the Official Journal. For connected radio products, Delegated Regulation (EU) 2022/30 has applied since 1 August 2025, and Implementing Decision (EU) 2025/138 cites the EN 18031 series with restrictions. Buying standards from a national standards body is a private cost, not a CE fee.
3. Choose the conformity assessment route: The Low Voltage Directive uses Module A only, with no notified body. Toys and radio equipment need a notified body in defined cases. Find a body in the Commission's NANDO database; notified bodies are designated by Member States and set their own fees by contract. No statutory processing time applies.
4. Test and assess the product: Run the tests the standards require, in-house or at an accredited laboratory, and record the results. Where a notified body is involved, it performs only its part of the procedure, such as EU-type examination under Radio Equipment Directive Annex III, and issues a certificate for that part.
5. Compile the technical file and sign the EU Declaration of Conformity: Include an adequate analysis and assessment of the risks, drawings, standards applied and test reports. Draw up the declaration following Directive 2014/35/EU Annex IV, translate it into the languages the Member State requires, keep it updated, and retain both documents for 10 years.
6. Affix the CE marking and traceability details: Place the CE mark visibly, legibly and indelibly, at least 5 mm high under Regulation (EC) No 765/2008 Annex II, with type or batch identification, the manufacturer's name and postal address, and the importer's details where applicable.
7. Cover Great Britain and Northern Ireland: For Great Britain, keep using CE or apply UKCA via self-declaration or a UK Approved Body accredited by UKAS and listed on UKMCAB. For Northern Ireland, use CE, or CE plus UKNI where a UK body performed mandatory third-party assessment. Then upload documents to each marketplace.