To enter the EU, products need CE, and packaging must be registered under EPR. To enter the UK, the mark changes to UKCA. Mix up one letter, and your cargo may get stuck at the border.
Three Concepts, Three Levels
| Requirement | Applicable Market | What It Governs |
|---|---|---|
| CE Mark | EU / European Economic Area | Product complies with EU safety, health and environmental regulations |
| UKCA Mark | UK (England, Scotland, Wales) | Product complies with UK domestic regulations |
| EPR | EU member states and the UK | Extended producer responsibility for packaging |
CE: Not a Certification, but a Self-Declaration Plus Responsibility
The CE mark is a mandatory requirement for products entering the EU market, indicating compliance with relevant EU directives or regulations.
Many people mistakenly think CE is a "certificate issued by an authority." In fact, for most products, the manufacturer self-declares and bears compliance responsibility.
What the manufacturer must do includes: conduct a conformity assessment, compile technical documentation, issue a Declaration of Conformity (DoC), and affix the CE mark.
For certain high-risk categories, an EU Notified Body must be involved, and self-declaration is not allowed.
UKCA: The Replacement Mark After Brexit
After Brexit, most products entering the UK market switched to the UKCA mark.
Two points to note: first, UKCA applies only to the UK and cannot replace CE; second, EU member states do not recognise UKCA.
Those selling in both the EU and the UK often need to prepare two sets of marks and two Declarations of Conformity.
EPR: Packaging Must Also Be "On the Register"
EPR stands for Extended Producer Responsibility, and the core principle is "whoever places packaging on the market bears the recycling responsibility."
Germany, France, Spain, Italy and other countries each have their own packaging EPR systems, typically requiring registration first, then declaration, then payment.
Without an EPR registration number, goods may be delisted, and platforms will also require you to provide it.
Rules vary from country to country, and the registration entity, declaration cycle and packaging classification all differ.
What Else to Do Beyond Getting the Certificate
Technical documentation must be retained: drawings, test reports, risk assessments, manuals — none can be missing.
The Declaration of Conformity must be standardised: clearly state the product, applicable regulations, manufacturer information and signatory.
Document retention periods must be sufficient: even if the product is discontinued, documents must be kept for the required number of years for inspection.
How to Apply the Mark Correctly
The CE mark must be scaled according to the prescribed proportions; it must not be distorted or have its letter spacing arbitrarily changed.
The mark must be clear, durable and not easily worn, and can be affixed to the product or packaging.
Do not affix CE to categories that do not require CE, and do not use UKCA to replace CE.
Three Common Misconceptions
Misconception 1: Having CE means you can sell across the entire EU. EPR, chemicals, packaging and others still have their own requirements.
Misconception 2: CE and UKCA are mutually recognised. They apply to different markets and cannot substitute for each other.
Misconception 3: EPR is the logistics provider's job. The registration entity is usually the seller or importer placing goods on the market, and logistics providers cannot register on your behalf.
