UK and EU Standards Are Diverging – What Businesses Need to Know

A new bulletin from the Office for Product Safety and Standards (OPSS) and the Department for Business and Trade (DBT) confirms an increasing gap between UK designated standards and EU harmonised standards. This regulatory shift is particularly important for businesses selling products in Great Britain, as it affects the recognition of CE marking and compliance requirements.

What’s Changing?

Previously, products carrying the CE mark were automatically accepted in the UK, as EU harmonised standards and UK designated standards were aligned. However, as regulatory lists evolve independently, certain restrictions are no longer identical between the two regions. As a result, CE marking will only be valid in Great Britain if the UK and EU standards remain fully aligned. Otherwise, additional steps may be required to ensure compliance with UK regulations.

Implications for Market Access

For companies that trade in both the UK and the EU, this divergence means that a single compliance process may no longer be sufficient. Businesses must verify whether their products still meet UK requirements or if additional testing and certification are needed. In cases where EU and UK standards differ, UK Conformity Assessed (UKCA) marking may be required instead of, or in addition to, CE marking.

Key Considerations for Businesses

• Review UK Designated Standards: Ensure your products comply with the latest UK regulations.
• Assess CE Mark Validity: The CE mark is only automatically recognised in GB if the relevant standards remain aligned.
• Plan for UKCA Marking: Where standards diverge, UKCA certification may be necessary to continue selling products in Great Britain.

With UK and EU standards evolving separately, businesses should stay informed about regulatory changes to avoid compliance risks and market access issues.