UK RoHS Compliance: CE and UKCA Marking

The United Kingdom left the European Union on January 31, 2020, and the transition period ended on December 31, 2020. Since then, different RoHS market-access rules have applied in Great Britain and Northern Ireland.

In Great Britain—England, Scotland and Wales—electrical and electronic equipment is regulated under the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012, S.I. 2012/3032, as amended.

For RoHS purposes, manufacturers can currently use either CE or UKCA marking when placing compliant electrical and electronic equipment on the Great Britain market. The UK government has extended recognition of CE marking indefinitely where the applicable EU and Great Britain requirements remain aligned.

Who is Affected by UK RoHS?

Northern Ireland follows the EU RoHS framework as it applies under the Windsor Framework. Products placed on the Northern Ireland market must bear the CE marking and satisfy the applicable EU RoHS requirements.

UK RoHS applies to manufacturers, authorised representatives, importers and distributors that place in-scope electrical and electronic equipment on the Great Britain market or make it available there.

The responsibilities of each economic operator differ. Manufacturers must evaluate product compliance, prepare the required technical documentation, issue a Declaration of Conformity and apply the appropriate marking. Importers and distributors also have verification, traceability and recordkeeping obligations.

Separate market-access and marking rules apply in Northern Ireland.

What is the Difference Between EU and UK RoHS?

UK RoHS and EU RoHS remain closely aligned in terms of product scope, restricted substances, concentration limits and assessment at the homogeneous-material level. However, they are separate legal regimes, and their exemptions or other requirements may diverge over time.

The principal marking rules are:

Target market	Accepted RoHS marking	Main condition
Great Britain	CE or UKCA	The product must satisfy all applicable Great Britain RoHS requirements, including the relevant exemptions.
Northern Ireland	CE	The product must satisfy EU RoHS requirements as they apply in Northern Ireland.
European Union or EEA	CE	The product must satisfy EU RoHS requirements.

According to the current UK government RoHS guidance, CE marking will continue to be accepted indefinitely for RoHS in Great Britain where EU and Great Britain requirements remain aligned. There is therefore no December 2024 deadline requiring businesses to replace CE marking with UKCA marking.

Products may carry both CE and UKCA markings when they satisfy the requirements of both regimes. In that case, manufacturers must prepare either separate Declarations of Conformity or a declaration that references both sets of requirements.

When the UKCA route is selected, the mark may be applied to a label, packaging or accompanying documentation until December 31, 2027, where permitted. From January 1, 2028, it should generally be affixed directly to the product.

These rules concern RoHS. Other legislation applying to the same product may have different marking or conformity-assessment requirements.

How to Comply with UK RoHS?

Manufacturers placing electrical and electronic equipment on the Great Britain market must:

Determine whether the equipment falls within the scope of UK RoHS;
Verify restricted substances at the homogeneous-material level;
Confirm compliance with the applicable concentration limits and exemptions;
Prepare and retain appropriate technical documentation;
Issue the relevant Declaration of Conformity;
Apply either CE or UKCA marking for the Great Britain market; and
Maintain the required product, manufacturer and importer traceability information.

For products intended for Northern Ireland or the European Union, manufacturers must follow the applicable EU RoHS requirements and use CE marking.

A CE-marked product can be placed on the Great Britain market only when it also satisfies the applicable Great Britain RoHS requirements, including any market-specific exemptions. CE recognition should not be interpreted as automatic compliance where the two regimes have diverged.

The Future of UK RoHS

UK RoHS and EU RoHS remain broadly aligned, but amendments to substance restrictions, exemptions, documentation requirements or product scope may be adopted separately. Companies selling products in both markets should therefore monitor the two regimes independently and maintain documentation appropriate to each target market.

Enviropass monitors UK, EU and international product environmental requirements and can help manufacturers assess their products, review supplier documentation, prepare technical files and develop targeted RoHS testing strategies.