Direct answer: CE marking is still enough to place a luminaire on the Great Britain market. Since 1 October 2024, CE recognition has been extended indefinitely for 21 product regulations covering electrical safety, EMC, ecodesign, RoHS and radio equipment, so a compliant CE-marked fixture with an EU Declaration of Conformity needs no UKCA mark. What CE does not give you is the UK energy label, a UK-established importer named on the product, a UK declaration citing designated British standards, UK REACH cover or UK WEEE producer registration. Those five items sit outside the EU file, and they are where shipments actually stall.
What changed on 1 October 2024, and what it did not change
The Product Safety and Metrology etc. (Amendment) Regulations 2024 were made on 23 May 2024 and came into force on 1 October 2024. They removed the expiry date on CE recognition in Great Britain for the regulations covering electrical equipment, EMC, ecodesign, RoHS and radio equipment. You may mark with CE, with UKCA, or with both, provided the product meets the requirements of the route you choose.
Two limits matter. The extension is unilateral: a UKCA-only product still cannot enter the EU, and for sectors outside the 21 regulations UKCA remains the only route. Northern Ireland is a separate market: it follows EU rules under the Windsor Framework, so CE is required there, and where a UK-approved body did the assessment the UKNI mark accompanies CE. UKNI is never used alone, or for GB and EU goods.
| Requirement | European Union | Great Britain |
|---|---|---|
| Safety mark | CE under LVD 2014/35/EU | CE (recognised indefinitely) or UKCA under SI 2016/1101 |
| Energy label | EU label, EU flag, QR to EPREL | UK label, Union Flag, SI number printed, QR to your own information sheet |
| Declaration | EU DoC citing harmonised EN standards | EU DoC accepted with CE, or UK DoC citing designated BS EN standards |
| Chemicals | EU REACH, ECHA | UK REACH, HSE – separate registration ledger |
| Waste electronics | National WEEE registers (Stiftung EAR, ADEME) | UK WEEE producer registration plus compliance scheme |
The UK energy label is not the EU label with a different flag
The Ecodesign for Energy-Related Products and Energy Information (Lighting Products) Regulations 2021 took effect on 1 October 2021 and re-based light source labelling on the A-to-G scale. The UK label carries a Union Flag instead of the EU flag, English only, and the supplier name, model identifier, energy class, consumption in kWh per 1,000 hours, and a QR code.
One field catches almost every first-time exporter: the label must also print the SI number of the regulations themselves. EU artwork re-used for Britain is wrong twice – wrong flag, wrong legal reference – even when the class and the kWh figure are correct, and the typefaces and colour values are specified too.
The QR code does not point at a government register. Great Britain has no supplier-facing database equivalent to EPREL for light sources, so the code has to resolve to a product information sheet you publish on a publicly accessible page. That page joins your technical file and has to stay live for the life of the model.
Dealers carry their own duties: the label must be visible at the point of sale, and distance selling needs the class arrow alongside the product. Rescaled stickers were allowed until 1 April 2023 for pre-October 2021 stock – that window has closed, so old artwork in a distributor’s warehouse is now a finding, not a transition.
Who signs as the UK importer, and why your factory cannot
The Electrical Equipment (Safety) Regulations 2016 define an importer as a business established in the UK that places equipment on the GB market from outside the UK. A Chinese factory cannot hold that role, and neither can an EU entity. Sell direct to British end users from China and someone in Britain must be importer of record, with their name, registered trade name or trade mark and a postal address marked on the equipment.
Two formal softenings exist, both time-limited. Importer details may go on the packaging or an accompanying document where marking the equipment is impossible, or where the goods come from the EEA or Switzerland and are placed on the GB market before 31 December 2027. Separately, a UKCA mark may sit on a label or accompanying document rather than the product until the same date. Neither survives 2028.
The importer’s duties are not ceremonial: verify that conformity assessment was done and a technical file exists, confirm the marking and the declaration, ensure instructions in easily understandable English, keep the declaration and file for ten years, and act on complaints. That is why some British distributors now refuse the role and ask for a UK subsidiary or a mandated representative instead.
An authorised representative is a separate appointment and must be established in the UK – GB or Northern Ireland, not outside it. It takes on the manufacturer’s information duties by mandate; it does not remove liability, and it is not an importer.
| Route into Britain | Who is the importer | What must be printed | Practical consequence |
|---|---|---|---|
| UK subsidiary buys and resells | Your own UK company | Your UK name and postal address on the product | Full control of the file; you also inherit ten-year retention and recall duties |
| British distributor imports | The distributor | Distributor name and address, on product or – until 2027 – on packaging | Fewer obligations for you, but the distributor may demand a UK DoC and test reports before ordering |
| Direct B2B or online from China | The British buyer, in law | Buyer’s details, which you usually cannot print | Unworkable at retail scale; buyers price the risk in or walk away |
The paperwork that is not in your EU file
Three documents do not translate. The first is the declaration: a UK DoC must cite designated standards, meaning the BS EN versions on the government’s designated list, not the EN numbers on your EU DoC. A BS EN that is not designated gives no presumption of conformity, however reputable the test report behind it.
The second is UK REACH, a separate regime run by HSE rather than ECHA. Substances were notified through the downstream user import notification route, and full registration deadlines were originally set at 27 October 2026, 2028 and 2030; a 2026 amending instrument pushed those to 27 October 2029, 2030 and 2031. Confirm the current position on HSE before relying on a date, because guidance pages and amending instruments have not always moved together.
The third is UK WEEE: producer registration with the environmental regulator, membership of a producer compliance scheme, and distributor take-back where you sell direct. Registration in Germany or France does nothing for a British obligation. Our comparison of WEEE and EPR registration in Germany and France shows how differently two EU states price the same product; Britain is a third ledger. The material side sits in reading material declarations for LED lighting.
The plug is a separate regulation, and it fails more often than the label
Where a luminaire is supplied with a plug – plug-in linear fixtures, shelf and under-cabinet units, display stands – the Plugs and Sockets etc. (Safety) Regulations 1994 apply alongside the electrical safety regulations. Regulation 12 requires the appliance to be fitted with a standard plug to BS 1363 carrying a fuse link to BS 1362, rated per the manufacturer’s instructions or, absent those, to Table 2 of BS 1363.
The common failure is a 13 A fuse in a 40 W fixture. That fuse protects the flexible cord, not the load, and a 13 A cartridge will not protect a 0.75 mm cord from an insulation fault. A 3 A fuse is normal for small luminaire loads, and the plug must carry a notified body’s approval marking. The only alternative to a BS 1363 plug is a non-UK plug inside an approved conversion plug that needs a tool to remove – a loose adaptor in the carton does not count.
Connected fixtures: PSTI and the Radio Equipment Regulations
Wireless luminaires and networked controls sold to consumers in Britain fall under the Product Security and Telecommunications Infrastructure regime, in force since 29 April 2024. Three requirements apply: no universal default passwords, a published vulnerability disclosure policy, and a stated minimum security update period. Compliance is evidenced by a statement of compliance that distributors must see before stocking, and penalties reach GBP 10 million or 4% of qualifying worldwide revenue.
There is no CE-style mark for PSTI and no register to file into. A fixture sold exclusively through specification channels is generally treated as out of scope, but the same hardware in a retail carton pulls the model back in – which is why retail and project versions should carry two files. Radio equipment has its own GB regime under the Radio Equipment Regulations 2017, and needs the radio test reports, not just the EMC ones.
A ship-ready checklist for a British launch
Every line below has an owner and an artefact. A file that cannot produce the artefact on request is not a file.
| Item | Owner | Evidence to hold |
|---|---|---|
| Conformity mark | Manufacturer | CE or UKCA on the rating label; dated EU or UK DoC |
| DoC standards | Manufacturer | Designated BS EN list versions, cross-checked against the EU DoC |
| Importer identity | GB importer | Name and postal address on product, or packaging before 2028 |
| Energy label | Supplier | UK artwork with Union Flag and the SI number, correct class |
| Product information sheet | Supplier | Public URL that the QR code resolves to, still live |
| UK REACH | GB importer or manufacturer | DUIN reference or registration number per substance |
| UK WEEE | GB producer | Regulator registration plus scheme membership number |
| Mains plug | Manufacturer | BS 1363 plug, correct BS 1362 fuse rating, approval mark |
| PSTI, if connected | Manufacturer | Statement of compliance and support period |
None of these items is expensive on its own. The cost appears when one is missing at the port, at a distributor’s goods-in check, or in a trading standards enquiry six months after the invoice was paid.
Frequently asked questions
Can I ship a CE-marked luminaire to Britain with no UKCA work at all?
Yes, for electrical safety, EMC, ecodesign and RoHS, provided the CE file is complete and the DoC current. Recognition has been indefinite since 1 October 2024. What CE does not cover: the UK energy label, a UK importer identity and the UK registers.
Does the energy label apply to a luminaire or only to lamps?
The obligation attaches to the light source, including one placed in a containing product, where the label and information sheet must be available for the contained source. A non-replaceable module is classified on the module it contains. Confirm with your test house rather than assuming a fixture is out of scope because it is not a lamp.
Do I need both marks on the same label?
Only if you want both. Dual marking is allowed where the product meets the essential requirements of both regimes, and it is common on fixtures sold into Britain and the EU from one line. A UKCA-only label blocks EU sales entirely.
What is the most common reason a British shipment gets held?
A label that does not match the file: EU artwork with a Union Flag pasted on, a class that no longer matches the tested data, or a QR code pointing at a page that was taken down. Importer details missing from the product runs a close second.
This article is a procurement guide, not legal advice. Confirm requirements for your specific product and market with a qualified compliance provider.
