UKCA Marking for LED Lighting: What You Need to Know

What is UKCA Marking?

The UKCA mark is the UK's product conformity marking. It indicates that a product meets the essential requirements of the relevant UK regulations and has undergone the appropriate conformity assessment procedures.

For LED luminaires, the key regulations are:

• Electrical Equipment (Safety) Regulations 2016 (the UK equivalent of the Low Voltage Directive) — covers electrical safety for equipment operating between 50V and 1000V AC

• Electromagnetic Compatibility Regulations 2016 (the UK equivalent of the EMC Directive) — ensures equipment does not generate excessive electromagnetic interference and is immune to interference from other equipment

• Ecodesign for Energy-Related Products Regulations 2010 (as amended) — sets minimum energy efficiency requirements for lighting products

• Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (UK RoHS) — restricts hazardous materials

The UKCA mark must be applied to products placed on the GB market (England, Scotland, Wales). Northern Ireland follows separate rules under the Windsor Framework and continues to accept CE marking.

CE vs UKCA: What Changed?

The technical requirements are currently identical — the UK regulations mirror the EU Directives in substance. The key differences are administrative:

• Marking — products must carry the UKCA mark (not CE) for the GB market. The CE mark alone is no longer sufficient.

• UK Declarations of Conformity — manufacturers must issue a UK Declaration of Conformity referencing the relevant UK regulations (not EU Directives)

• UK Authorised Representative — non-UK manufacturers placing products on the GB market may need a UK-based authorised representative

• UK Approved Bodies — where third-party conformity assessment is required (e.g., for ATEX-certified luminaires), this must be carried out by a UK Approved Body rather than an EU Notified Body

For most standard LED luminaires (which are self-certified by the manufacturer), the practical impact is limited to updating documentation, markings and declarations. For ATEX and other third-party certified products, the change is more significant.

Transition Deadlines

The UK government has extended transition arrangements several times. The current position:

• CE marking continues to be accepted on the GB market indefinitely for most product categories, following the government's December 2024 announcement. This means products bearing a CE mark can continue to be placed on the GB market without needing a separate UKCA mark.

• However, manufacturers are encouraged to transition to UKCA marking, particularly for products where UK-specific requirements diverge from EU requirements in the future.

• For ATEX-certified equipment, UK Approved Body certification (UKCA) is required for products first placed on the GB market after 1 January 2025, unless they already hold valid EU-type examination certificates from before that date.

Specifiers should note that the regulatory landscape is evolving. Products from reputable manufacturers will carry both CE and UKCA markings to ensure compliance in all markets.

What Specifiers Should Check

When specifying LED luminaires for UK projects:

1. Verify the product carries a UKCA mark (or CE mark under the current transitional acceptance) — check the product label and documentation

2. Request the UK Declaration of Conformity — this should reference the relevant UK regulations and be signed by the manufacturer or their UK authorised representative

3. For ATEX products — verify the certificate has been issued by a UK Approved Body (e.g., Baseefa, CSA Group UK) if the product was first certified after the transition deadline

4. Check RoHS compliance — the UK RoHS regulations mirror EU RoHS but require a separate declaration

5. Verify Ecodesign compliance — minimum efficacy requirements and flicker limits (PstLM < 1.0, SVM < 0.4) apply under UK Ecodesign regulations

All EOS luminaires carry both CE and UKCA markings with full UK Declarations of Conformity, and our ATEX products hold UK Approved Body certificates.