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UKCA vs CE Marking for PPE After Brexit: What Still Applies in 2026?

8 July 2026 by
UKCA vs CE Marking for PPE After Brexit: What Still Applies in 2026?
Ralph Stirrat

More than five years since the UK left the EU single market, the rules around PPE conformity marking are still catching people out. If you buy or supply safety equipment in Great Britain, you have probably seen products carrying CE marks, UKCA marks, or both. The question we get at Colbrook all the time is: which one is actually valid now?

The short answer is both. But there are some important details that matter, especially if you are sourcing PPE from abroad, specifying equipment for a contract, or selling to Northern Ireland.

So let's cut through the confusion.

The Two Marks Explained


CE marking stands for Conformite Europeenne. It has been the standard for PPE across Europe for decades. Any safety product sold in the European Economic Area needs a CE mark to show it meets the relevant health and safety requirements under the PPE Regulation (EU) 2016/425.


UKCA marking stands for UK Conformity Assessed. It was created after Brexit as the British equivalent. Same principle, different system. For products placed on the Great Britain market (England, Scotland, Wales), UKCA is the UK's own conformity mark.

A split visual showing two PPE safety helmets side by side

Do You Need UKCA or Is CE Still OK?


The UK government has extended recognition of CE marking for PPE indefinitely. As of July 2026, you can still place CE-marked PPE on the GB market as long as the CE marking is valid under EU law. That means you do not need to dual-mark everything overnight.


But there is a catch.


If your PPE relies on a certificate from an EU-based notified body (like BSI Nederland, INSPEC International, or SATRA Technology Europe), and you have not had that certificate reviewed by a UK Approved Body, the UKCA route is not automatically open to you. You can still sell the product on its CE mark, but you cannot legally put a UKCA mark on it without UK-based certification.


For practical purposes, most imported PPE sold in the UK today still carries CE marking. Many manufacturers have not switched to UKCA because the deadline has been pushed back so many times, and the EU market is bigger than the UK market.


What About Northern Ireland?


This is where it gets a bit more specific. Under the Windsor Framework, Northern Ireland continues to follow EU rules on PPE. So products placed on the NI market need CE marking. UKCA marking alone is not accepted in Northern Ireland unless the product also meets EU requirements.


If you supply PPE across the whole of the UK, you need to be aware of this. A UKCA-only product is fine for Glasgow or Cardiff, but not for Belfast or Derry.


How to Tell Which Mark a Product Has


It is usually straightforward. Look at the product label or packaging. A CE mark will have the four-digit number of the notified body underneath it (for example, 0086 for BSI or 2797 for SATRA). A UKCA mark will have the four-digit number of the UK Approved Body.

 site manager in hi-vis workwear checking PPE

Some products carry both marks. This is becoming more common as manufacturers dual-certify their products to sell in both markets. If you see both, you are covered everywhere in the UK.


What This Means for Buyers


If you are a site manager or business owner in Scotland buying PPE for your team, here is what you need to know.


You can still buy CE-marked PPE. It is legal, it is widely available, and it meets the same safety standards it always did. The safety requirements behind the CE mark have not changed just because of Brexit.


If you are tendering for a public sector contract, check the specification. Some contracts now specifically require UKCA marking. We have seen a few tender documents in Scotland that ask for UKCA-certified PPE, especially for high-risk items like safety harnesses and respiratory protection.


If your supplier only offers UKCA-marked products and you also need to supply Northern Ireland, make sure they have CE certification too.


For most everyday PPE (hi-vis vests, safety gloves, hard hats, safety glasses), the transition has been smooth and both marks are widely accepted.


Where Colbrook Can Help


We stock a huge range of PPE from leading brands like Portwest, Helly Hansen, Yoko, and JSP. Every product we sell conforms to the relevant UK and EU standards. If you are unsure whether a specific item carries CE, UKCA, or both, just ask.


Our team in North Lanarkshire deals with this question daily. We can help you check your existing PPE stock, advise on specifications for new orders, and make sure you are meeting your legal obligations under the PPE at Work Regulations 2022.


Give us a call on 01236 755544 or browse our PPE range online at colbrook.co.uk. We ship across Scotland and the rest of the UK.

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