UKCA – the new UK product marking


The UKCA (UK Conformity Assessed) marking is the new UK product marking for goods placed on the market in Great Britain, replacing the EU’s CE marking. This mark will be used to certify that a wide range of products meet safety standards in the UK, covering most products that previously required the CE mark.

While the UKCA marking came into effect on 1st January 2021, businesses are still able to use CE marking until 1st January 2023 allowing Irish companies exporting to the market to prepare for the new marking.

This webinar outlines the practical steps Irish engineering companies can take to ensure products are compliant with the new UK product marking, UKCA.


Presented by Mike Whiting, Compliance Engineer, Newmac Ltd, topics included:

  • What is the UKCA and how does it differ from CE?

  • Aligning your UKCA and CE compliance roadmap

  • How UKCA effects the supply of second hand equipment in the market?

  • UKCA/CE and Northern Ireland


Eurostyle – Navigating Brexit issues to continue strong international growth

Brexit has finally become a reality, but that doesn’t mean Irish companies with a significant presence in the UK have overcome all hurdles.

Many, however, identified the hurdles at an early stage and now have great advice to pass onto other companies in similar situations. Eurostyle is a Cork-based company with roots in the city’s apparel industry since 1820; now predominantly a branded golf/lifestyle company, Eurostyle found itself very vulnerable to the threats of Brexit as 85% of their business was with the UK.

“We have a global licence for Calvin Klein Golf and we own two golf brands, Green Lamb, which is the No.1 ladies golf brand in UK and Ireland, and Dwyers & Co, a golf trouser brand that dates back to 1820,” explains Alan Dwyer, managing director at Eurostyle. “We also own, which sells discounted ladies branded golf apparel online throughout Europe. When Brexit first came up, five years ago about 85% of our business was with the UK, but we identified the issues associated with Brexit and put a plan in place.”

With the support of Enterprise Ireland to find a key stakeholder within the organisation to deal with Brexit, the company identified three major issues with Brexit: duty costs making their products less competitive with fellow UK suppliers, the possibility of economic issues in the UK following Brexit and the subsequent hit on the sterling exchange rate.

“Our first strategy was to look outside of the UK for business, building up relationships with online companies such as Amazon in the US and Zalando in Germany,” says Alan.

“We sell to 18 countries in Europe, but we also now sell to the USA, Canada, Malaysia and Australia. Currently we’ve reduced our exposure to the UK to 70% of our business, and we’ll be at 50% in two years’ time.”

The second hurdle was customs. “The fact that we do business outside of Europe means we have experience in dealing with customs,” says Alan. “We would know a lot about the paperwork required. Our plan to overcome this hurdle is to bring the products directly into the UK to our bigger clients, so we avoid having to pay a duty on goods moving from Ireland to England. We’re VAT registered for the UK, and we have a warehouse and a logistics company set up there already.”

Despite putting in a system whereby the company can supply directly to their UK clients, Alan believes that diversifying their client countries as key. “We’ll continue to build relationships with clients outside the UK, as we think their economy will take a hit from Brexit, and the demand mightn’t be there for us to grow our business. Also, as we sell in sterling to our UK clients, if sterling gets weak and moves towards the euro, our margins could be hit very badly.”

And that’s not the end of the Brexit planning. “There will also naturally be some delay with shipping with Brexit. About 50% of our MissDesignerGolf business is with the UK and we can’t take returns without a duty having to be paid – so we’ve also had to partner with a UK company to deal with our returns. There’s a lot to think about.”


The effects of Covid

Eurostyle sees Brexit as a hurdle they must overcome – this same practical approach came in useful when Covid hit Ireland in early March. “Covid affected us hugely,” says Alan. “We were basically told on a Friday night that we were closing down at midnight, and we had €7/€8 million worth of goods to deliver over the next 12 weeks. It became a bit chaotic as we had a lot of cancellations from our customers and then we had to deal with our factories and suppliers.

“Our business works through pre-orders, so our customers might place an order in August/September for delivery the following March for spring – when Covid hit, we lost 25% of our pre-orders. In the middle of all this, we had a huge cash flow issue as we had goods coming in from Asia that we had to pay for, but we couldn’t send them out during Covid. Enterprise Ireland gave us a support loan from the Sustaining Enterprise Fund, which meant we didn’t let any of our big suppliers down – and we think that will be key for our success in the next year. A lot of American companies basically told their factories tough luck, we can’t pay you, whereas we honoured every order from every supplier and built a strong relationship with them on the back of this.”

But Covid, in a way, simply sped up an inevitable shift in Eurostyle’s business model, as Alan explains. “All the bricks and mortar shops closed and didn’t want any goods, but our online clients got busier and busier – so our business went from being a 70% bricks and mortar/30% online split three years ago to being the opposite now. Most of our online clients have doubled their business during Covid and therefore now want double the product from us. As a result, our business will grow strongly over this year and next. To be honest, we had been working towards this change for a few years and in a way, Covid played into our hands a little.”

As a result, despite the hurdles of Brexit and Covid, the future is bright at Eurostyle. “We’re about to take on a licence for DKNY Sport in Europe, a fairly major American brand, so we think over the next few years our business can double. This will help us venture beyond golf and into the general sports market. Calvin Klein Golf has grown considerably and has nearly doubled in sales this year. Obviously we lost out on the bricks and mortar shops, but those losses haven’t been as significant as the gains, so we’re very positive going forward. We thought that Covid could close our business but it’s actually grown it, and we see Brexit as another hurdle that we need to carefully navigate in order to move forward – not something to panic over.”


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Brexit: The key takeaways for Irish firms

The conclusion of the EU-UK Trade and Cooperation Agreement (TCA) was a significant achievement for all concerned. The historic deal provides for tariff- and quota-free trade between the EU and the UK and protects Ireland’s place in the Single Market. It also establishes a foundation for a strong future partnership and positive engagement and co-operation between the EU and the UK in the period ahead.


Of critical importance is the fact that Ireland’s €92 billion trade in goods, services and agrifood with the UK will not be subject to unwelcome tariffs.

Another very important dimension of the TCA is the arrangements it puts in place for international connectivity, including aviation and road haulage, co-operation on cross-border law enforcement, energy links, trade in services as well as goods and a range of other important areas such as UK involvement in EU programmes, including the Horizon research programme and PEACE PLUS.

In addition, a legally secure bridging mechanism has been put in place to allow for the continued smooth flow of data between the EU and the UK. This avoids potential disruption to current arrangements where companies in Ireland have payroll and other processes carried out in the UK. It also enables Irish service providers to continue serving UK customers, with no requirement to adjust existing arrangements.

The arrangements for air travel mean point-to-point flights between the UK and EU destinations, including Ireland, can continue to operate smoothly. This will help maintain vital trade and business corridors between Ireland and the UK.

There are also new arrangements on ownership and control, and marketing cooperation between airlines. The impact of these arrangements has already been seen, with Ryanair moving to restrict the voting rights of UK-based shareholders.

The UK’s departure from the Single Market does mean new restrictions on British airlines, with point-to-point routes between EU destinations no longer open to them, for example.

The arrangements on road connectivity are particularly welcome as they make explicit provision for the unique situation of the island of Ireland, and the rights for our haulage sector are protected as much as possible. The agreement provides for point-to-point access between the EU and the UK, which covers the majority of traffic between Ireland and the UK.

Irish hauliers will also enjoy some cabotage rights within the UK. These will allow hauliers to deliver a load to one destination in the UK and then carry goods to another destination there. North-South cooperation on road haulage is protected, while Irish hauliers will retain the right to transit through the UK to third countries outside the UK, such as Switzerland.

But tariff- and quota-free trade does not mean barrier-free access. While the TCA is fundamentally in Ireland’s interest, it cannot and does not replicate the status quo which existed prior to Brexit. The UK’s decision to leave the EU means that the EU-UK relationship cannot be as close as it was before 1 January 2021.

From a practical point of view, this means that Irish goods are now subject to customs checks and controls on entry to the island of Britain. This applies to all goods destined for the UK market or transiting Britain en route to the EU or other markets.

To illustrate the scale of the challenge this presents for Irish business, it is estimated that the number of declarations made by Irish firms each year will increase from 1.7 million a year to more than 20 million as a result of Brexit

A great many Irish businesses have already prepared for this new situation and have put in place arrangements to cater for it. Those who are not yet ready need to act now if they are not to suffer severe disruptions to their business.

The first step in the preparation process is to obtain an EORI (Economic Operators Registration and Identification) number. This is a European Union registration and identification number for businesses which undertake the import or export of goods in or out of the EU. Companies can register for a number through Revenue’s EORI online registration service; the process is very straightforward and can be completed in minutes.

After that, companies need to determine the commodity code for the product or products they are exporting. Companies can find detailed lists of these codes on the Revenue website (

The next step is to decide who will be handling the customs declarations. In many cases, firms will use logistics partners or customs brokers to do this, but SMEs may well decide to do it themselves either to reduce costs or due to difficulties in finding a suitable partner.

Making declarations online is known as Direct Trader Input (DTI) and requires importers, exporters or their agents to have dedicated software making electronic declarations to the Automated Entry Processing (AEP) system. To do this, companies need to register with Revenue and obtain a digital certificate to make declarations to the system.

Several software products which can handle electronic declarations are available on the market and many of them can interface with ERP and accounting software to extract the data required for the declarations.

Accuracy is absolutely critical. There are more than 50 data points in a customs declaration and a slight error in any one of them will slow down or stop the shipment.

Where companies do decide to use a partner to handle customs on their behalf, they should not rely on business carrying on as usual in the early months of the new arrangements. The massive increase in the volume of declarations will put even the largest and best-prepared operators under strain. Companies need to talk to their partners and ask them if they are ready, if they have taken on more staff, and how high up their priority list they are.

For larger exporting companies, there is the option to apply for Authorised Economic Operator (AEO) status with Revenue. This allows them to self-certify exports and receive priority treatment when their goods are crossing borders. Traders that have registered under Authorised Economic Operator schemes will be mutually recognised in the EU and UK under the TCA.

At another very practical level, businesses must prepare for delays in supply chains, both for imports and exports. The massive traffic jams witnessed at Dover and Calais and other English Channel ports before Christmas gave some indication of what could happen in worst-case scenarios. Many importers and exporters will have to increase stockholdings to cater for such delays and this will require them to invest in warehousing and other storage facilities as well as potentially change the terms of trade with their customers and suppliers.

Those exporters who are not yet ready for the new customs regime should use the traditionally quiet period at the beginning of the year to prepare for it. Enterprise Ireland has a suite of supports available to help firms get ready and an excellent starting point in the process is the online Brexit Readiness Checker which delivers a personalised report that highlights any gaps in preparations, identifies priority areas for attention, and gives details of where to find help and support, all in 15 minutes.

The EU-UK Trade and Cooperation Agreement (TCA) may not have replicated the frictionless status quo which has existed up until now, but it certainly represents a vast improvement on what a no-deal Brexit would have meant for Ireland and Irish businesses. As such, the challenge now is to make the most of that and take advantage of the tariff- and quota-free access to the UK market which the deal has delivered.


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CE marks authorised by UK will no longer be valid within the EU

From 1st January new rules will apply to those exporting to GB, as well as those buying from it


That’s the date on which the Brexit transition period ends, and the UK finally leaves the EU.

New Year’s Day is a Red Letter one for Irish businesses trading with the UK. It marks the end of the Brexit Withdrawal Agreement transition period and the beginning of the UK’s new status as a Third Country, outside the EU.

Regardless of the outcome of trade talks, this means:

  • Significant changes to the certification rules governing Irish exports to the UK
  • New certification requirements for Irish manufacturers bringing parts in from the UK
  • Greater legal responsibility as former Irish ‘distributors’ of UK goods become ‘importers’ to the EU



Get properly certified

“If you receive products from the UK, you should assess your responsibilities under EU law now.” – Mary White

Irish companies exporting to the UK must take steps now to ensure their products are correctly certified. Failure to do so could see goods impounded.

Currently, goods that are compliant with EU legislation carry the CE mark. However, if your product’s CE mark is authorised by a UK standards assessment body, known as Notified Bodies, that certification will no longer be valid within the EU.

“If your organisation relies on certificates, licenses or authorisations for goods or services which have been issued by UK Authorities, or by UK-based Notified Bodies – or are held by someone established in the UK – these will no longer be valid within the EU, post-Brexit,” warns Mary White, Head of the Brexit Unit at the National Standards Authority of Ireland (NSAI).

Companies in such a position need to transfer certification – or seek new certification – from a Notified Body or Authority within the EU-27 member states. “The sooner you do it the better,” she says.


New responsibilities

From 1st January the legal rules surrounding some business activities will change.

Anyone who previously acted as a distributor of goods originating in the UK will now become an importer of those goods and take on significantly more responsibility for ensuring they conform to EU standards. That applies for component parts, as well as finished goods.

“If you receive products from the UK, you should assess your responsibilities under EU law now.  It is likely that post-Brexit, if you buy goods from the UK you will be considered as an importer for the purposes of EU product legislation.  This means you will have another set of obligations under EU law depending on the sector,” says White.

If you import from the UK, you will now be required to keep additional information on file too, so engage with your UK suppliers to obtain this information as soon as possible.



CE becomes UKCA

“Remind your UK customers that they will become ‘importers’ under UK law.” – Mary White

Come 1st January Irish products placed on the UK market will be subject to UK legislation.

New UK regulations stipulate that any product that requires a Declaration of Conformity will have to have this carried out by a UK Approved Body, as opposed to an EU-27 Notified Body.

To be traded in Great Britain the goods must be marked not with the CE mark but with a new mark the UK has introduced, UKCA (Conformity Assessed).

Until 31st December 2021, CE marked products will still be allowed to be placed on the UK market.

“Remind your UK customers that they will become ‘importers’ under UK law, and they will be required to be able to access a copy of your product’s technical file. You should prepare this information now, so that it will be available to your UK customers after 1st January 2021,” says White.


Regulatory divergence 

In January the UK will have UK legislation coming into force similar to current EU legislation. However, “What they don’t say is whether they will update this legislation when the EU amends its legislation,” says White.

At present there are 32 pieces of EU legislation covering manufactured products here, in the form of both directives and regulations.

Several EU directives currently under review, including the Machinery Directive. “The UK will not be obliged to update their legislation as they will not be bound to EU rules, hence, there will be divergence,” she warns.


Act now 

“My message for Irish manufacturers that require their product to be certified under a particular piece of EU legislation is to first, ensure that your certification is carried out by an EU-27 based Notified Body from the 1st January 2021.” – Mary White

If you use a UK Notified Body, check to see if it has established itself in an EU-27 Member State, as some have relocated, she points out. In Ireland there are now 16 Notified Bodies who undertake conformity assessments, up from three just two years ago.

If yours hasn’t relocated to the EU-27, check the EU NANDO (New Approach Notified and Designated Organisations) website to look through its database of 1500 Notified Bodies  []  to find an alternative.


Transfer your files

“From 1st January, UK Notified Bodies can no longer certify your product and issue the CE mark,” says White.

“You can transfer your existing technical file from the UK NB to an EU based NB up until the 31st December. Otherwise, you will have to get your product recertified, and this can take several weeks to transfer.”


  • if you currently CE mark your product under EU rules, you will still have to, post Brexit.
  • if you rely on a UK Notified Body for the certification of conformity that underpins your CE mark either you will need to transfer your technical specification files from your UK Notified Body to an EU-27 one, or
  • you will need to obtain a new certificate that has been issued by an EU-27 Notified Body
  • if you do this post-Brexit, you will automatically be required to start with a new application.



EU Declaration of Conformity 

Make sure to have your Declaration of Conformity documentation in order, a requirement for CE marked goods.

“If you are an Irish manufacturer and are currently importing a CE certified component from the UK after the 1st January, you are now importing from a Third Country,” reminds White.

A copy of the Declaration of Conformity for the certified component needs to be available at the point of entry, demonstrating that the product has been certified by an EU-27 Notified Body.

All products certified by a UK Notified Body must be placed on the market before Brexit occurs or else will need to be recertified.

As long as the certified product is in transit, and an invoice has been generated by the Irish manufacturer or importer of the goods before 11pm on 31st December 2020, “this product can still be placed on the EU market, even if it does not arrive until March,” she points out.


EU Declaration of Performance

Goods being placed on the market in England, Scotland and Wales will have to have UKCA marking, with conformity assessment carried out by a UK approved body.

As well as a UKCA mark, such goods will need UK Declaration of Performance documentation to support them.

There is a transition period in which CE marking will still be permissible, giving Irish companies time to get their UK certifications in order.

The UKCA mark will be required for industrial products from January 2022, and for medical devices from July 2023.

Although a new mark CE UK (NI) is also being introduced, EU rules will continue to apply to goods moving to and from Northern Ireland, with no significant changes there, she says.


Finally, don’t trip over a pallet

ISPM 15 is an international phytosanitary measure developed by the International Plant Protection Convention (IPCC) that sets down standards for the treatment and marketing of wood packaging material (WPM) such as the pallets and crates used in international trade.

Under EU Regulations, certain minimum standards apply and those that have attained the requisite standard are heat treated and stamped.

Currently ISPM15 is a requirement for WPM entering the EU from Third Countries. It does not currently apply to EU UK trade.

However, from 1st January 2021 the UK becomes a Third Country and ISPM15 becomes a requirement.

“As of now, there are in excess of 100 million pallets in the UK, 90% of which do not have this mark,” says White. As all WPM may be subject to official checks either upon or after entry to the EU, now is the time to discuss this issue with your UK trade partners.


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Dr Suraya Diaz: Taking a healthy approach to customs

LEO Prepare Your Business for Customs programme is helping small businesses put their best foot forward for Brexit

Use the Brexit Readiness Checker to review your firm’s preparedness 

Dr Suraya Diaz knows it’s better to be proactive than reactive. When it comes to wellness, prevention is better than cure. When it comes to business, it’s all about preparation. For Brexit, it means signing up for a Local Enterprise Office Prepare Your Business for Customs workshop.

That’s exactly what the Galway based health store owner and maker of organic food, cosmetics and wellness products did. Indeed, Brexit is the reason the Portuguese woman moved to Ireland to start a business in the first place.

She had studied biochemistry and biology in Portugal and completed a master’s degree in clinical microbiology before moving to the UK to do a PhD in biochemistry and molecular biology where she studied infectious diseases.

“I wanted to understand the mechanics of infection,” she explains. “But I also always wanted to start a business.”

At around the time she finished her PhD, talk in the UK was turning to a Brexit referendum. That prompted a move to Galway, where she worked as a researcher, studied nutrition, herbal medicine, naturopathy and homeopathy and set up a practice helping to promote wellness in others.

When she couldn’t find products with the exact blend of ingredients she needed for her clients, she decided to make them herself. She developed a range of certified organic products, opening a small manufacturing facility in 2019, which she expanded in 2020 with assistance from Local Enterprise Office Galway.

Today her products sell online and via health food stores and pharmacies.

“The Local Enterprise Office has been very helpful and I have availed of various different courses and vouchers.

As well as providing me with grants for machinery and marketing, it enabled me to employ my first member of staff. I am also doing a Lean for Micro course which is very important in helping to improve efficiencies,” says Suraya.

She has also benefited from a number of LEO business mentors. “Sometimes, when you are starting a business, you can be so focused on the thing that you are doing now that it can be hard to see the whole business in its totality. Mentors really helped me with that. They gave me a new perspective and made me question things.”

Participating in Enterprise Ireland’s New Frontiers programme, Phase I and II, helped too. “It’s a very comprehensive programme and I’d definitely recommend it. I had a background in biochemistry, nutrition, naturopathy and herbal medicine but I didn’t have a business background.”

In order to be fully Brexit ready, she signed up for the Prepare Your Business for Customs workshop.

Being Brexit Ready

“Because I was already aware of Brexit, I had tried to limit my UK suppliers as much as possible from the start. As a result, the majority of my suppliers are not in the UK,” she points out.

But with the UK accounting for 70% of her sales, ensuring UK exports are as seamless as possible is vital.

“I am trying to go to other markets as well including Spain, the Netherlands and Germany but the reason my exports grew in the UK so much was because of Amazon. With Covid-19, many more UK people were at home and, when a shortage of stock emerged from their usual suppliers they started looking for an alternative, and it was an opportunity for me,” she explains.

But the more she sold into the UK, the more important it was to make sure she was Brexit-ready.

“I did the Local Enterprise Office Prepare Your Business for Customs workshop because I wanted to be informed and I wanted a good overview of what was ahead of me.

I also wanted to understand things like INCOTERMS. The lecturers were very informative and, at the end of the session it was very interesting to hear what the other businesses were saying and doing too.”

In terms of tariffs, regulations and possible trade restrictions, there is still a lot of uncertainty, she points out.

“The biggest challenge is that we don’t know exactly what is coming or how expensive it will be. However, because

I did the LEO Prepare Your Business for Customs programme, I know I have done all the right things, like registering for my EORI (Economic Operators Registration and Identification) number. I know the things I need to look out for and it gave me the tools I need to talk to a customs broker.”

As a result, whatever happens after midnight on December 31st, when the UK finally leaves the EU, Dr Suraya Diaz is ready for it. “I am a positive person anyway, but I think I will be okay. Although we will all feel the impact of Brexit, at the same time I think it will open many doors to us.

There are so many customers out there in Europe who are currently buying from the UK. Those UK businesses might struggle to deliver in Europe,” she says. “Ireland can find some very important opportunities there. I’m hopeful I can take advantage of that.”

Use the Brexit Readiness Checker to review your firm’s preparedness