Amazon Comparison
CE Marking vs. UKCA – What Do You Need?
Overview
Since Brexit, Amazon sellers who want to sell in both the EU and the United Kingdom must understand and comply with two separate conformity markings: CE marking for the EU market and UKCA marking (UK Conformity Assessed) for the British market. Although the technical requirements are still largely identical in many areas, these are two legally completely separate systems with different jurisdictions, authorized representatives, and implementation deadlines. For Amazon sellers this means: Those selling only on amazon.de, amazon.fr, or other EU marketplaces only need CE marking. Those also active on amazon.co.uk must additionally meet UKCA requirements – with separate documentation, a UK Authorized Representative, and a separate declaration of conformity.
CE Marking (EU)
The CE marking (Conformite Europeenne) is the conformity mark for products placed on the European Economic Area (EEA) market. It is based on harmonized EU directives such as the Low Voltage Directive (LVD), EMC Directive, Radio Equipment Directive (RED), Toy Safety Directive, and many others. With the CE marking, the manufacturer or importer declares that their product complies with all applicable EU requirements.
Pros
- +Access to 27 EU countries plus EEA: A single CE marking enables sales in all 27 EU member states plus Norway, Iceland, and Liechtenstein – a market of over 450 million consumers.
- +Globally recognized and established: CE marking has been established for decades and is recognized as a quality indicator in many countries outside the EU, which can facilitate market entry in third countries.
- +Extensive infrastructure of testing bodies: There are hundreds of accredited testing and certification bodies (Notified Bodies) across the EU, promoting competition and thus more affordable testing costs.
- +Also applies to Northern Ireland: Under the Northern Ireland Protocol, CE marking continues to apply for products placed on the Northern Ireland market, partially simplifying UK market access.
- +Stable, long-established legal framework: The underlying EU directives and harmonized standards are mature and stable. Companies can count on long-term planning certainty.
Cons
- -Does not apply to Great Britain (England, Scotland, Wales): Since Brexit, CE marking alone is no longer sufficient for the British market. UKCA is additionally required for amazon.co.uk.
- -Increasingly stringent requirements: New EU regulations like GPSR (General Product Safety Regulation), effective from 2024, and expanded EPR obligations (Extended Producer Responsibility) continuously increase the compliance burden for sellers.
- -EU Authorized Representative required for non-EU manufacturers: Manufacturers outside the EU must appoint an Authorized Representative based in the EU, which means additional costs and organizational effort.
- -Complex directive landscape: Depending on the product category, multiple EU directives may apply simultaneously (e.g., LVD + EMC + RoHS + REACH), making documentation and testing complex.
UKCA Marking (UK)
The UKCA marking (UK Conformity Assessed) is the British conformity mark that replaced CE marking for the Great Britain market (England, Scotland, Wales) after Brexit. It covers largely the same product categories as CE marking and is based on EU directives transposed into UK law. For Amazon sellers active on amazon.co.uk, UKCA marking is mandatory.
Pros
- +Access to the British market: UKCA marking is the prerequisite for legally selling regulated products on amazon.co.uk – one of the highest-revenue Amazon marketplaces in Europe.
- +Currently largely identical technical requirements: Since UKCA regulations are based on transposed EU directives, the technical testing requirements are currently still very similar to CE marking.
- +Less competition due to higher entry barrier: The additional UKCA requirements deter some sellers, which can mean less competition on the UK market for well-prepared merchants.
- +Great Britain as an independent, high-purchasing-power market: The UK market offers over 67 million residents with high online purchasing power and is the third-largest e-commerce market globally.
Cons
- -Additional costs for separate certification: Even though technical requirements are similar, a separate UKCA conformity process is required – with its own documentation, test reports, and declarations.
- -UK Authorized Representative required: Non-UK companies must appoint a UK-based Authorized Representative (UK Responsible Person), which causes additional ongoing costs.
- -Uncertainty about future divergence: The UK government can diverge UKCA requirements from EU standards at any time. Future changes could require separate testing and modifications.
- -Only applies to Great Britain, not Northern Ireland: UKCA marking does not apply to Northern Ireland, which continues to fall under the EU legal framework. For the entire UK market, you therefore need both CE (Northern Ireland) and UKCA (GB).
- -Limited number of approved testing bodies: The number of UK Approved Bodies is significantly lower than EU Notified Bodies, which can lead to longer waiting times and higher testing costs.
Comparison Table
| Criterion | CE Marking (EU) | UKCA Marking (UK) |
|---|---|---|
| Geographic scope | 27 EU member states plus EEA countries (Norway, Iceland, Liechtenstein) and Northern Ireland. Over 450 million consumers. | Great Britain (England, Scotland, Wales) – not Northern Ireland. Approximately 60 million consumers in GB. |
| Legal basis | Harmonized EU directives and regulations (e.g., LVD 2014/35/EU, EMC 2014/30/EU, RED 2014/53/EU, Machinery Regulation 2023/1230). | EU directives transposed into UK law (Retained EU Law). Currently still largely identical but may diverge in the future. |
| Testing and certification bodies | EU Notified Bodies – hundreds of accredited bodies across the EU. Competitive market with comparatively affordable prices. | UK Approved Bodies – significantly fewer bodies available. Testing by EU Notified Bodies is not automatically recognized. |
| Authorized Representative | EU Authorized Representative based in the EU required for non-EU manufacturers. Must be indicated on the product or packaging. | UK Responsible Person based in Great Britain required for non-UK companies. Separate appointment needed even if an EU Authorized Representative already exists. |
| Initial testing costs | Varies widely by product category: EUR 500-5,000 for simple products, EUR 5,000-25,000 for complex electronics or medical devices. | Similar cost range as CE, but tends to be 10-30% more expensive due to fewer testing bodies. Often existing CE test reports can be partially utilized. |
| Northern Ireland rules | CE marking continues to apply fully in Northern Ireland under the Windsor Framework. Products with CE marking may be sold in Northern Ireland. | UKCA marking does not apply to Northern Ireland. For the Northern Irish market, CE or the special UKNI mark (in combination with CE) is needed. |
| Transition periods and acceptance | No transition period – CE is the established standard in the EU. No changes due to Brexit for the EU market. | The UK government has extended the transition period multiple times. Currently, GB still accepts CE marking for most products until end of 2027, but sellers should switch to UKCA early. |
| Amazon relevance | Mandatory for all regulated products on EU Amazon marketplaces (DE, FR, IT, ES, NL, SE, PL, BE). Amazon increasingly enforces CE compliance more strictly. | Mandatory for regulated products on amazon.co.uk. Amazon increasingly demands proof of UKCA conformity and UK Responsible Person for listings. |
Our Recommendation
For Amazon sellers selling in both the EU and Great Britain, there is no way around both markings. Our recommendation: Start with CE marking as it covers the larger market and forms the basis for UKCA. Many test reports and technical documentation can be reused for the UKCA process, reducing additional costs. Make sure to appoint both an EU Authorized Representative and a UK Responsible Person. At SpaceGoats, we support our clients in navigating both compliance systems and connect them with reliable testing service providers and authorized representatives in the EU and Great Britain.
Frequently Asked Questions
Is my CE marking sufficient to sell on amazon.co.uk?
Currently (as of 2026), the UK government still accepts CE marking for most product categories until the end of 2027 as a transitional measure. This means you can sell on amazon.co.uk with CE for now. However, we strongly recommend preparing UKCA marking early, as the deadline is final and Amazon can tighten requirements at any time.
Can I reuse my CE test reports for UKCA marking?
In many cases yes, as long as the technical requirements are still identical. The test reports themselves can serve as a basis, but you need a separate UKCA declaration of conformity referencing UK regulations (Retained EU Law) instead of EU directives. If a UK Approved Body is required for certification (for products needing third-party testing), they can often recognize existing test results.
What is a UK Responsible Person and do I need one?
The UK Responsible Person is the British equivalent of the EU Authorized Representative. If your company is not based in Great Britain, you must appoint a UK Responsible Person who acts as the point of contact for UK market surveillance authorities. This person must be indicated on the product or packaging. There are specialized service providers that assume this role for EUR 500-2,000 annually. Amazon increasingly requires proof of a UK Responsible Person for listings on amazon.co.uk.
Which product categories actually require CE or UKCA marking?
Not all products require CE or UKCA marking – only those falling under a regulated product category. Typical examples include: electronic devices (LVD, EMC), radio and Bluetooth products (RED), toys (Toy Safety Directive), personal protective equipment (PPE), machinery, medical devices, and construction products. Products like textiles, furniture without electrical components, or plastic kitchen utensils typically don't fall under CE/UKCA requirements but are subject to other regulations like REACH or the food contact regulation.
What happens if I sell on Amazon without correct marking?
The consequences can be severe. Amazon can deactivate your listing without warning or suspend your entire seller account. Additionally, market surveillance authorities may take action: recall orders, fines, and in severe cases criminal consequences. In the EU, fines can reach several hundred thousand euros depending on the country and violation. In Great Britain, similar penalties apply through the Office for Product Safety and Standards (OPSS). Furthermore, as the party placing the product on the market, you are liable for damages caused by non-compliant products.
Will CE and UKCA requirements continue to diverge in the future?
This is likely, but the pace of divergence is hard to predict. The UK government has the right to set its own standards that differ from EU regulations. In some areas like AI regulation or sustainability requirements, different approaches are already emerging. For Amazon sellers this means: Plan long-term with two separate compliance processes and budget accordingly. The investment in both markings secures access to both markets regardless of how regulations evolve.