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Transition from EU Notified Body to UKCA Approved Body 1st January 2021

5 November 2020

As a result of the Brexit referendum in 2016, the UK officially left the EU at the end of January 2020 and is currently operating within the transition period which comes to an end on 31st December 2020. UK conformity assessment bodies will no longer be able to carry out mandatory conformity assessment for products being placed on the EU market unless agreed in negotiations.  From 1 January 2021, the UK government is putting in place a domestic legal framework that will allow UK conformity assessment bodies to continue operating for most products being placed on the GB market.

This Technical Bulletin has been produced to confirm the transition process for existing UKAS accredited conformity assessment bodies from accreditation in support of Notification (EU CE Marking) to accreditation supporting the new UKCA system, i.e. Approved Bodies. However, it does not cover conformity assessment of products to be placed on the Northern Ireland market which shall be covered in separate communications published by UKAS.

As a replacement for the EU CE Mark, the UK Government is now finalising the UK Conformity Assessed (UKCA) system as part of the legal framework being introduced for mandatory certification of products before being placed on the GB market. Note: This will be introduced for the Great Britain market only, as Northern Ireland, under the Northern Ireland protocol, shall still comply with EU Regulations relating to products and hence recognise the CE Mark.

The existing UK Competent Authorities(1) shall appoint ‘Approved Bodies’ for the purposes of UKCA marking on the same basis as they previously recognised Notified Bodies, i.e. through UKAS accreditation (with one or two noted exceptions such as Medical Devices under MHRA).

It has been determined that the competences and processes required for UKCA Approved Body status will be the same in most aspects to those for Notified Body status. As a consequence, current UK Notified Bodies shall be automatically transferred to Approved Bodies from 1st January 2021 subject to them continuing to meet the requirements of UKAS accreditation. This transition includes other related statuses such as Technical Assessment Bodies (TABs) under the Construction Products Regulation and Recognised Third-Party Organisations (RTPOs) under the Pressure Equipment Regulations.

At the next assessment of each CAB, UKAS will review the changes to reflect the UKCA system.

In support of this transition, UKAS shall automatically update all affected schedules of accreditation to reflect the transfer from EU to UK Regulation effective from 1st January 2021. If any existing Notified Bodies do not want their status to be transferred to a UKCA Approved Body they should notify their UKAS Assessment Manager at the earliest opportunity.

UKCA Approved Bodies shall be listed on a new database set up by Government in support of the UKCA system.

UKAS policy publication P16, Accreditation for the Purposes of Appointment under the UKCA System, is in the process of being updated to reflect UKAS accreditation under the UKCA system, and will be published on the UKAS website for public consultation shortly.

Further Information:



Should you require any clarification on the subject covered by this bulletin, please contact; your Assessment Manager or Kevin Belson, Technical Manager – [email protected]


If you would like to download a pdf version of this Technical Bulletin, please click here.


(1) UK Competent Authorities include the Department for Business, Energy and Industrial Strategy (BEIS), Ministry of Housing, Communities and Local Government (MHCLG), the Department for Transport (DfT), and the Maritime and Coastguard Agency (MCA).