Placing manufactured goods on the market in Great Britain from 1 January 2021
What you need to do to comply with regulations on manufactured goods you place on the GB market from 1 January 2021.
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
For current information, read: CE marking
You can also read about the transition period.
This guidance is about placing manufactured goods on the market in Great Britain (GB). Great Britain is England, Wales and Scotland.
There’s different guidance if you’re:
If you have already placed your good on the UK market (or in an EU country) before 1 January 2021, you do not need to do anything.
Businesses are encouraged to be ready for full implementation of the new UK regime as soon as possible after 1 January 2021. However, to allow businesses time to adjust, CE marked goods in scope of this guidance that meet EU requirements (where these match UK requirements) can continue to be placed on the GB market until 1 January 2022 where EU and UK requirements remain the same. This includes goods which have been assessed by an EU recognised notified body. There are some exceptions to this guidance, highlighted below.
Check which rules apply
What you will need to do from 1 January 2021 depends on the type of goods you’re placing on the market.
Most of this page covers goods often known as new approach goods.
There are different rules for:
- goods regulated under the old approach
- goods covered by national rules (non-harmonised)
- certain other goods, such as medical devices and civil explosives
Speak to your solicitor or trade association if you are unsure which regulatory framework applies to your goods.
Old approach goods
You must follow different rules if you’re placing the following goods on the UK market:
Goods covered by national rules (non-harmonised)
You must make sure that your goods meet UK rules. You’ll need to do this even if they were previously sold in an EU country.
Check the UK product safety rules to find out what you need to do.
Other goods
There are also special rules if you’re placing the following goods on the UK market:
- medical devices
- rail interoperability constituents
- construction products
- civil explosives
- products requiring ecodesign and energy labelling
Check if you need to change your conformity assessment or marking
You need to use a conformity mark if you’re placing certain goods on the UK market. Before 1 January 2021 you can do this using the CE mark or other appropriate mark (such as the wheel marking or Pi mark).
From 1 January 2021, the UKCA mark will be the conformity assessment marking for Great Britain for most goods currently subject to CE marking.
The CE marking will be accepted in the UK until 1 January 2022 for certain products. You must be ready to use the UKCA marking from 1 January 2022 at the latest, although you should look to use the UKCA marking as soon as possible.
Using the UKCA marking
You will need to use the new UKCA marking immediately after 1 January 2021 if all of the following apply. Your product:
- is covered by legislation which requires the UKCA marking
- requires mandatory third-party conformity assessment
- conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021
This does not apply to existing stock, for example if your good was fully manufactured and ready to place on the market before 1 January 2021.
Contact your solicitor or trade association for advice on whether your good will be affected.
Find out how to use the UKCA marking.
Using the CE marking
CE marking for the GB market
You will be able to use the CE marking until 31 December 2021 if any of the following apply:
- you currently apply the CE marking to your good on the basis of self-declaration
- any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (including a body in a country with which the EU has a relevant mutual recognition agreement)
- the certificate of conformity previously held by a UK approved body has been transferred to an EU-recognised notified body
You can only place CE marked goods that meet EU requirements in Great Britain while UK and EU requirements are the same. This will be the case on 1 January 2021 and there are no UK plans to diverge at this time. Nonetheless you are encouraged to be ready as soon as possible, and by 1 January 2022 at the latest. If the EU changes their rules and you CE mark your goods based on new EU rules which are different from the requirements in the UK, you will no longer be able to use the CE marking in the UK. This will be the case even if the change happens before 1 January 2022.
Find out how to use the CE marking.
CE marking for both the GB and EU market
The UKCA marking will not be recognised on the EU or Northern Ireland markets. Products currently requiring a CE marking for sale in the EU will continue to need a CE mark.
You will not need to take any action from 1 January 2021 if either of the following apply:
- you self-declare the conformity of your good against the regulations
- you voluntarily use a testing or notified body to test against European or international standards
You may need to take additional action if your good needs third-party conformity assessment.
Check whether your UK notified body is taking steps that help you continue to export to the EU without needing to find a new EU notified body.
If not, you may need apply for a new certificate from an EU notified body. Your existing notified body should provide another body of your choice information relating to your conformity assessments in order to facilitate this.
Speak to your testing body or solicitor for advice on how conformity processes for your good will be affected.
Find out how to use the CE marking.
Using both the CE and UKCA marking
Goods can carry both the CE and UKCA markings so long as they are fully compliant with both UK and EU regulations.
From 1 January 2021 the essential requirements and standards that can be used to demonstrate conformity with them for UKCA marked goods will be the same as they are now. That means that if your goods is currently made to the technical requirements necessary for CE marking then it will be made to the same technical requirements that will exist for UKCA marking from 1 January 2021. However, the conformity assessment bodies that test them may need to be different.
Appoint an authorised or responsible person in the UK
Authorised representatives and responsible persons based in the EU will no longer be recognised in Great Britain from 1 January 2021.
If you need to (or choose to) use an authorised representative or responsible person, they will need to be based in the UK for products being placed on the GB market.
Check whether your legal responsibilities are changing
Manufacturers
Your legal obligations will remain largely unchanged from 1 January 2021.
UK distributors and suppliers
You’ll need to confirm whether you or your supplier will become an ‘importer’ after 1 January 2021.
You’ll become an importer if you’re the one bringing goods into the UK from outside the UK and placing them on the market in Great Britain.
You’ll need to make sure:
- goods are labelled with your company’s details, including your company’s name and a contact address (until 31 December 2022 you can provide these details on the accompanying documentation rather than on the good itself)
- the correct conformity assessment procedures have been carried out and that goods have the correct conformity markings
- the manufacturer has drawn up the correct technical documentation and complied with their labelling requirements
- you maintain a copy of the declaration of conformity for a period of 10 years
- goods conform with the relevant essential requirements
More information
Existing stock
Existing stock that has been fully manufactured and conformity marked can still be placed on the GB market after 1 January 2021 with existing markings and notified body numbers. This is true even if this would otherwise not be the case.
For example, a product covered by a UK certificate of conformity, and which would normally need UKCA marking after 1 January 2021, can still be sold in the UK with a CE marking so long as it is from pre-existing stock fully manufactured before 31 December 2020.
Relevant UK and EU legislation
The table below lists the current EU legislation for specific goods, and the title of the corresponding UK legislation.
Contact
Email goodsregulation@beis.gov.uk if you have goods regulation questions.
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Guidance
Placing manufactured goods on the EU market from 1 January 2021
What you need to do to comply with regulations on manufactured goods you place on the market from 1 January 2021.
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
For current information, read: CE marking
You can also read about the transition period.
This guidance is about placing manufactured goods on the EU market.
There’s different guidance if you’re:
If you’ve already placed your goods on the market in an EU country (or in the UK) before 1 January 2021, you do not need to do anything.
Check which rules apply
What you will need to do from 1 January 2021 depends on the type of goods you’re placing on the market.
Most of this page covers goods known in the EU as new approach goods, which can use the CE marking.
There are different rules for:
- goods regulated under the old approach (such as chemicals, medicines and vehicles)
- non-harmonised goods covered by national legislation
Speak to your solicitor or trade association if you are unsure which regulatory framework applies to your goods.
Old approach goods
You must follow special rules if you’re placing these goods on the EU market.
Check the European Commission’s website for the latest information.
Non-harmonised goods
You must make sure that your goods meet the requirements of the first EU or EEA country in which you are placing them on the market.
Check the national regulations of the relevant EU/EEA country to find out what you need to do.
Check if you need to change your conformity assessment
You will not need to change your conformity assessment for exports to the EU if:
- you self-declare the conformity of your good against the regulations
- any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (whether based in the EU or in a country with which the EU has a mutual recognition agreement)
- the certificate of conformity previously held by a UK body has been transferred to an EU-recognised notified body
- you voluntarily use a testing body (including UK bodies) to test against European or international standards
Find out how to use the CE marking.
UK conformity assessment
From 1 January 2021 any mandatory conformity assessment will need to be carried out by an EU-recognised conformity assessment body. This includes both EU based bodies and bodies in countries with which the EU has concluded a mutual recognition agreement.
UK conformity assessment bodies will no longer be able to carry out mandatory conformity assessment for products being placed on the EU market unless agreed in negotiations.
Speak to your testing body or solicitor for advice on how conformity processes for your good will be affected from 1 January 2021.
Appoint an EU-recognised notified body
Check whether your UK notified body is taking steps of its own, so that you can continue to export to the EU without needing to find a new EU notified body yourself.
If not, you will need to either:
- get your products reassessed by an EU notified body
- arrange for information held by your existing notified body to be transferred to an EU notified body so they can issue you a new certificate
Certificates and documentation
If you transfer your existing certificate to an EU notified body then you will need to update the 4-digit notified body number on your products. You will not need to do this for products already on the market or which were manufactured before the transfer took place.
You will eventually need separate certificates for the UK and EU. You should speak to both your existing and new body to make arrangements that mean you will be covered for both markets in the future. If you transfer your certificate to the EU without doing this you may not be able to continue selling your goods in the UK from 1 January 2022 without having your product reassessed. This process may take a long time so you should start now.
EU and UK notified bodies are required to share information when requested by a certificate holder. This will help facilitate the issuing of new certificates of conformity where needed.
Appoint an authorised or responsible person
Authorised representatives and responsible persons based in Great Britain will no longer be recognised by the EU from 1 January 2021.
If you’re required to, you will need to appoint an authorised representative or responsible person based in the EU, EEA or Northern Ireland.
From 16 July 2021 you will need to appoint an authorised representative based in the EU or EEA if you sell goods without using an importer or fulfilment service provider. For example if you sell online and ship directly to the end user.
Check whether your legal responsibilities are changing
Manufacturers
Your legal obligations will remain largely unchanged from 1 January 2021.
EU-based distributors
If you have an EU based distributor they will become an ‘importer’ from 1 January 2021.
They will need to make sure:
- goods are labelled with their address and either your details or your EU, EEA or Norther Ireland-based authorised representative’s details (including your company’s name and a contact address or registered trademark)
- the correct conformity assessment procedures have been carried out and that goods have the correct conformity markings
- you, as the manufacturer, have drawn up the correct technical documentation and complied with the labelling requirements
- they maintain a copy of the declaration of conformity for a period of 10 years
- goods conform with the relevant essential requirements
EU-based fulfilment service providers
From 16 July 2021, if you use an EU-based fulfilment service provider, they will need to request certain compliance information from you, and goods will need to be labelled with their details.
They may ask that you appoint an authorised representative who can fulfil these obligations instead.
More information
This guidance is based on information published by the European Commission. For the latest updates on the EU’s requirements please consult the European Commission’s website.
Contact
Email goodsregulation@beis.gov.uk if you have goods regulation questions.
Guidance
Placing manufactured goods on the EU market from 1 January 2021
What you need to do to comply with regulations on manufactured goods you place on the market from 1 January 2021.
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
For current information, read: CE marking
You can also read about the transition period.
This guidance is about placing manufactured goods on the EU market.
There’s different guidance if you’re:
If you’ve already placed your goods on the market in an EU country (or in the UK) before 1 January 2021, you do not need to do anything.
Check which rules apply
What you will need to do from 1 January 2021 depends on the type of goods you’re placing on the market.
Most of this page covers goods known in the EU as new approach goods, which can use the CE marking.
There are different rules for:
- goods regulated under the old approach (such as chemicals, medicines and vehicles)
- non-harmonised goods covered by national legislation
Speak to your solicitor or trade association if you are unsure which regulatory framework applies to your goods.
Old approach goods
You must follow special rules if you’re placing these goods on the EU market.
Check the European Commission’s website for the latest information.
Non-harmonised goods
You must make sure that your goods meet the requirements of the first EU or EEA country in which you are placing them on the market.
Check the national regulations of the relevant EU/EEA country to find out what you need to do.
Check if you need to change your conformity assessment
You will not need to change your conformity assessment for exports to the EU if:
- you self-declare the conformity of your good against the regulations
- any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (whether based in the EU or in a country with which the EU has a mutual recognition agreement)
- the certificate of conformity previously held by a UK body has been transferred to an EU-recognised notified body
- you voluntarily use a testing body (including UK bodies) to test against European or international standards
Find out how to use the CE marking.
UK conformity assessment
From 1 January 2021 any mandatory conformity assessment will need to be carried out by an EU-recognised conformity assessment body. This includes both EU based bodies and bodies in countries with which the EU has concluded a mutual recognition agreement.
UK conformity assessment bodies will no longer be able to carry out mandatory conformity assessment for products being placed on the EU market unless agreed in negotiations.
Speak to your testing body or solicitor for advice on how conformity processes for your good will be affected from 1 January 2021.
Appoint an EU-recognised notified body
Check whether your UK notified body is taking steps of its own, so that you can continue to export to the EU without needing to find a new EU notified body yourself.
If not, you will need to either:
- get your products reassessed by an EU notified body
- arrange for information held by your existing notified body to be transferred to an EU notified body so they can issue you a new certificate
Certificates and documentation
If you transfer your existing certificate to an EU notified body then you will need to update the 4-digit notified body number on your products. You will not need to do this for products already on the market or which were manufactured before the transfer took place.
You will eventually need separate certificates for the UK and EU. You should speak to both your existing and new body to make arrangements that mean you will be covered for both markets in the future. If you transfer your certificate to the EU without doing this you may not be able to continue selling your goods in the UK from 1 January 2022 without having your product reassessed. This process may take a long time so you should start now.
EU and UK notified bodies are required to share information when requested by a certificate holder. This will help facilitate the issuing of new certificates of conformity where needed.
Appoint an authorised or responsible person
Authorised representatives and responsible persons based in Great Britain will no longer be recognised by the EU from 1 January 2021.
If you’re required to, you will need to appoint an authorised representative or responsible person based in the EU, EEA or Northern Ireland.
From 16 July 2021 you will need to appoint an authorised representative based in the EU or EEA if you sell goods without using an importer or fulfilment service provider. For example if you sell online and ship directly to the end user.
Check whether your legal responsibilities are changing
Manufacturers
Your legal obligations will remain largely unchanged from 1 January 2021.
EU-based distributors
If you have an EU based distributor they will become an ‘importer’ from 1 January 2021.
They will need to make sure:
- goods are labelled with their address and either your details or your EU, EEA or Norther Ireland-based authorised representative’s details (including your company’s name and a contact address or registered trademark)
- the correct conformity assessment procedures have been carried out and that goods have the correct conformity markings
- you, as the manufacturer, have drawn up the correct technical documentation and complied with the labelling requirements
- they maintain a copy of the declaration of conformity for a period of 10 years
- goods conform with the relevant essential requirements
EU-based fulfilment service providers
From 16 July 2021, if you use an EU-based fulfilment service provider, they will need to request certain compliance information from you, and goods will need to be labelled with their details.
They may ask that you appoint an authorised representative who can fulfil these obligations instead.
More information
This guidance is based on information published by the European Commission. For the latest updates on the EU’s requirements please consult the European Commission’s website.
Contact
Email goodsregulation@beis.gov.uk if you have goods regulation questions.
Food and drink labelling changes from 1 January 2021
How food and drink producers, manufacturers, retailers and suppliers must change labels from 1 January 2021.
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
For current information, read: Food labelling and packaging
You can also read about the transition period.
Exporting to the EU
The EU has issued guidance on labelling changes required from 1 January 2021.
Check with your EU importer how the EU’s new labelling requirements affect your products.
Food products placed on the EU market before 1 January 2021 can continue to be sold, distributed or transferred in the EU without labelling changes. In EU law, ‘placed on the EU market’ means they’re:
- held in the EU for the purpose of sale, including offering for sale or any other form of transfer, whether free of charge or not
- sold, distributed or transferred to the EU in another way
Food business operator (FBO) address
Pre-packaged food and caseins must have an EU address for the FBO or EU importer on the packaging or food label.
EU organic logo
You must not use the EU organics logo from 1 January 2021 unless:
- your UK control body is authorised by the EU to certify UK goods for export to the EU
- the UK and the EU agree to recognise each other’s standards (called ‘equivalency’)
Contact your control body to stay up to date.
If the UK does not reach an equivalency deal with the EU, you cannot export organic food or feed from the UK to the EU.
You can continue to use your UK organic control body logo.
Read more about trading and labelling organic food from 1 January 2021.
EU emblem
You must not use the EU emblem on goods produced in the UK from 1 January 2021 unless you have been authorised by the EU to do so.
EU health and identification marks
On products of animal origin (POAO), you must replace the EU oval health and identification marks with new UK health and identification marks.
Country of origin labels
UK food must not be labelled as origin ‘EU’ from 1 January 2021.
Goods sold in the UK
EU health and identification marks
You can continue to use the EU oval health and identification mark on products of animal origin (POAO) produced and sold in the UK until 1 January 2021.
From 1 January 2021, you must use the new UK health and identification marks for POAO to clearly show the UK product has been subjected to strict health and welfare checks.
Read the Food Standards Agency’s guidance on the new health and identification marks.
Food business operator (FBO) address
You must include a UK address for the FBO on pre-packaged food or caseins sold in the UK. If the FBO is not in the UK, include the address of your importer.
EU organic logo
You must not use the EU organic logo on any UK organic food or feed from 1 January 2021, unless either:
- your control body is authorised by the EU to certify UK goods for export to the EU
- the UK and the EU agree to recognise each other’s standards (called equivalency)
Contact your control body to stay up to date.
You can continue to use your approved UK organic control body logo.
Find out more about trading and labelling organic food from 1 January 2021.
Country of origin for mixed foods and eggs
Some foods must be labelled with the specific country or countries of origin.
You must continue to include this from 1 January 2021.
You can label the food as EU origin if it’s from a remaining member state.
Food produced in the UK must not be labelled as ‘EU origin’ from 1 January 2021.
You can read about egg marketing standards from 1 January 2021
Minced meat
You must change references to the EU with UK when the label does not list each country of origin. For example, ‘origin EU and non-EU’ changes to ‘origin UK and non-UK’.
Fruit and vegetables
You must replace references to the EU with UK on the label for mixes of UK fruit and vegetables. For example, ‘a mix of EU and non-EU origin’ changes to ‘a mix of UK and non-UK origin’.
If you’re part of the Approved Trader Scheme, you must remove the EU emblem from your UK food labels. You can use the replacement UK label instead.
Olive oil
From 1 January 2021, if your extra virgin or virgin olive oil is a blend of oils from different countries, the label must contain one of the following:
- a list of each country of origin
- the statement “blend of olive oils from more than one country” or similar wording
- the name of the trading block to which a regional trade agreement applies, for example ‘blend of olive oils of European Union origin’
Honey blends
If you place honey on the UK market before 1 January 2021, it can stay on the market using the old origin wording (‘blend of EU honeys’, ‘blend of non-EU honeys’ or ‘blend of EU and non-EU honeys’) if the label was accurate.
From 1 January 2021, if you place a blend of honeys from different countries on the UK market you must reflect that UK honey is no longer EU honey.
For example, if a UK honey is blended with an EU honey you cannot continue to use ‘blend of EU honeys’. The label must say ‘blend of EU and non-EU honeys’, ‘blend of honeys from more than one country’, or similar wording.
Beef and veal
Your label must state ‘Origin: non-UK’ if the animal your beef or veal came from was born, reared or slaughtered outside of the UK and EU.
You should replace ‘live import into the EC’ with ‘beef from a live import into the UK’ where you do not know the origin country of the animal.
Eggs
You should mark eggs from non-EU countries that do not meet UK egg trade regulations as ‘Non-UK standard’ rather than ‘Non-EC standard’.
Geographical Indication (GI) logo
GI-protected food or drink products (except wine or spirits) must use the relevant UK logo.
The logo use is optional for GI-protected wine or spirits.
The UK will set up its own GI schemes from 1 January 2021. You’ll have 3 years from the launch of the UK schemes to adopt the relevant UK logo on food and agricultural product packaging.
Find out more about protecting food and drink names from 1 January 2021.
Trading and labelling organic food from 1 January 2021
How rules for producing, processing, labelling and trading organic food will change from 1 January 2021.
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
For current information, read: food labelling and packaging.
You can also read about the transition period.
Law and standards changes from 1 January 2021
The UK will have its own laws for the production, processing, labelling and trading of organic food and feed from 1 January 2021.
Organic standards will remain similar to the EU’s.
Food and feed registered as organic in the EU will continue to be accepted as organic in the UK.
The EU will decide whether to continue accepting food and feed registered in the UK as organic.
Certificates and labels
You will still need to be certified by an approved UK organic control body if you grow, process or import organic food for trade within the UK.
Organic food you produce, process, sell or import must be labelled with details of your organic control body.
Displaying logos
You must not use the EU organic logo on any UK organic food or feed from 1 January 2021, unless either:
- your control body is authorised by the EU to certify UK goods for export to the EU
- the UK and the EU agree to recognise each other’s standards (called equivalency)
Contact your control body to stay up to date.
You can continue to use your UK organic control body logo. Read the guidance on importing organic food or feed to find out the restrictions on organic produce imports.
Find out about food labelling changes from 1 January 2021.
Importing organic food
You will no longer use the EU’s Trade Control and Expert System New Technology (TRACES NT) when importing organic food and feed.
You will use a manual UK organic import system until a new digital system is in place from 1 January 2021.
All imports from non-EU countries (known as third countries) must have a certificate of inspection (CoI).
Exporting organic food to the EU
You will not be able to export organic food or feed to the EU, unless either:
- your UK control body is authorised by the EU to certify UK goods for export to the EU
- the UK and the EU agree to recognise each other’s standards (called equivalency)
Contact your control body to stay up to date.
Exporting organic food to non-EU countries
Some non-EU countries may require an export certificate for each consignment. You should check with the country you’re exporting to.
Trading rules should stay the same for countries that accept UK goods without an equivalency arrangement (an agreement to accept each other’s standards).
The EU has equivalency arrangements with some non-EU countries and the UK is negotiating trade agreements to continue trading with these countries from 1 January 2021. The Department for Environment, Food and Rural Affairs (Defra) will contact importers and food manufactures if any trade agreements change.
Different exporting rules may apply if equivalency is not agreed between the UK and non-EU countries from 1 January 2021. Contact the exporting control body in the country you’re importing food from. Defra will publish any changes in this guide.
Last updated 25 September 2019 + show all updat