UKCA or CE for control panels: which mark for which market

As of 6 November 2026, a low-voltage control panel placed on the Great Britain market can carry either UKCA or CE. CE recognition for electrical equipment, EMC, RoHS and machinery has no end date in law, although it sits in regulations the government can change by statutory instrument, as SI 2026/867 does for machinery.¹²³ Northern Ireland and the EU need CE, with UKNI added in Northern Ireland only where a UK body carried out a mandatory third-party assessment.⁴ The date to plan for is 20 January 2027, when the EU Machinery Regulation applies and the Great Britain route for CE-marked machinery is rewritten to follow it.⁵³ SI 2026/867 does not amend the electrical, EMC or RoHS regulations.³⁶ This is an inference from SI 2026/867: a panel outside the machinery rules keeps its present route.

Not legal advice. Rules last checked 6 November 2026.

The position, rule by rule

HSE's machinery page, last updated 29 October 2024, still says CE recognition ends on 31 December 2024.¹⁵ That is out of date. The legislation.gov.uk changes table for 2026 shows no change to the electrical or RoHS regulations, two to Schedule 5 of the EMC regulations from SI 2026/40 (conformity bodies under the India trade agreement), and 28 to the 2008 machinery regulations from SI 2026/867.⁶ That table can lag, so recheck it.

What each regime asks for

In all four regimes below, Great Britain takes UKCA or CE, Northern Ireland CE or CE and UKNI, and the EU CE.¹

Under the electrical regulations the technical documentation must contain, where applicable, the results of design calculations and examinations, and test reports.¹⁹ For a panel builder, records such as the short-circuit rating, its basis and the protection it relies on and the temperature-rise verification of a 61439 assembly fall under that list. An estimate from makers' constants, as in temperature rise in a sealed panel, is a design check and does not replace that verification. This is an inference from the wording of the schedule.

Which regime is your panel under?

This table is an inference from the sources in its last column. The standard you build to is a separate question: see whether BS EN IEC 61439 or BS EN 60204-1 applies.

What to keep, and for how long

One file per panel serial number, kept until 10 years after the last unit of that design was placed on the market, meets each of the clocks below. For a fixed installation, whoever installed it keeps the engineering practice documents for the whole period of operation.²⁵

The clocks differ: the electrical and EMC guides run from placing on the GB market,¹⁶¹⁷ RoHS from the last product, with a 10-year record of who supplied you and whom you supplied,¹⁰ and the 2008 machinery rules from manufacture.²⁷²⁸ GOV.UK counts from each individual product.⁹

Who is the importer, and whose address goes on the plate?

For a panel builder this comes up in two directions: buying in finished equipment from abroad to supply on, and shipping panels from Great Britain to Northern Ireland or the EU. An importer is a person or business established in the UK who supplies a product from outside the UK.⁹

GOV.UK's Northern Ireland guide defines an importer as supplying from outside the UK,⁴ which sits awkwardly with OPSS on GB goods going to Northern Ireland, so take advice on that route. A GB authorised representative is not recognised for Northern Ireland or EEA placing.⁸

An importer selling under its own name, or modifying the product in a way that affects compliance, takes on the manufacturer's duties.⁹ Read with the GOV.UK definition above, a maker outside the UK that sells to a UK reseller or integrator makes that UK customer the importer. Selling direct to an end user is less clear. A contract can allocate the work and the cost, but it cannot change who the law treats as importer, so take advice.

Machinery is different. Regulation 2 of the 2008 Regulations puts the duties on a "responsible person", meaning the manufacturer or its authorised representative, but its definition of manufacturer falls back to the person who places the machinery on the market if no one else qualifies,²⁹ and the OPSS glossary is wider still: "or the person placing the product on the GB market".⁸ A GB business bringing in machinery from a maker with no UK representative should assume it may carry the manufacturer's duties. SI 2026/867 does not appear to create a separate importer regime in Great Britain; that is an inference from its text, and it does not leave the importer free of duty. In Northern Ireland and the EU the Regulation adds importer duties from 20 January 2027.¹⁴³

Does the Machinery Regulation change anything for a panel?

Read against the Regulation's text, four things follow. The exclusion stays: low-voltage switchgear and control gear is still excluded in so far as it falls within the Low Voltage Directive, so a panel with no safety function should stay where it is.¹⁴ Safety logic gets more attention: a safety component is now "a physical or digital component, including software".¹⁴

Retrofits have a defined trigger in Northern Ireland and the EU from 20 January 2027. A "substantial modification" is one not foreseen by the manufacturer that creates a new hazard or increases a risk and requires, among other things, guards or protective devices whose processing necessitates modifying the existing safety control system; whoever carries it out becomes the manufacturer.¹⁴ HSE's line for Great Britain is broader in wording.¹⁵

Documents can be digital from 20 January 2027. Until then the EC declaration must accompany the machinery.²³ From that date, on the GB CE route, the EU declaration may be reachable through an internet address or code for at least 10 years, and everything must be in English or translated.³

What happens to orders that straddle 20 January 2027?

The contract only helps for a finished product. OPSS says only fully manufactured products can be placed on the market,⁸ and GOV.UK counts each individual product,⁹ so a machine, or a panel that is itself a safety component or partly completed machinery, still being built on 20 January 2027 is not protected by an earlier order. A panel under the electrical, EMC and RoHS regulations alone is not affected by this date. This is an inference from SI 2026/867: machinery placed in Great Britain on or after that date cannot rely on Directive-based CE, and needs the Regulation's requirements (CE or UKCA) or the 2008 Regulations' own UKCA route.³ Because the test applies to each finished unit, keep the contract, the invoice and a dated completion record for each unit.

What is still unsettled

Great Britain's own machinery rules. The memorandum says similar measures to those taking effect in Northern Ireland will come to Great Britain as soon as parliamentary time allows,³⁰ and the February 2026 response says full replication is not possible.³¹ So from 20 January 2027 a UKCA route under the 2008 Regulations' own requirements appears to run beside one under the EU's, and no source gives a date for when that ends.

Harmonised standards for the Regulation. The Commission's page says the first list can be expected before the end of this year.³² Its summary list generated on 28 October 2026 shows EN 60204-1:2018 ending under the Directive on 20 January 2027, and the page warns that this date may appear for many standards. Until the new list is out, nobody can say which standards give a presumption under the Regulation. GB's designated lists are separate, and machinery list version 16 shows no end date for EN 60204-1:2018,³³ so check how the designated lists and the current editions of 60204-1 and 61439 differ before you cite one.

Guidance and reform. The Commission's machinery page still lists only the guide to the Directive,⁵ and the OPSS guide predates the 2026 instrument.⁸ Do not plan around the product safety proposals until the government responds.¹² Keep UKCA and CE declaration templates separate, since GOV.UK's Fast-Track guidance raises divergence as a hypothetical.⁷

Notes

1. GOV.UK, Product regulations by sector and current approaches to product marking: UKCA and CE regimes, published 31 March 2026. ↩ ↩² ↩³ ↩⁴

2. legislation.gov.uk, Product Safety and Metrology etc. (Amendment) Regulations 2024, SI 2024/696, made 23 May 2024, in force 1 October 2024, regulations 4, 8, 11 and 14 and the explanatory note. ↩ ↩²

3. legislation.gov.uk, Supply of Machinery (Safety) (Amendment etc.) and the EU Machinery Regulation (Enforcement etc. in Northern Ireland) Regulations 2026, SI 2026/867, made 22 July 2026, in force 20 January 2027, regulations 2, 3, 9, 12, 13 and 15. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

4. GOV.UK, Placing CE, or CE and UKNI, marked products on the market in Northern Ireland, updated 8 April 2026. ↩ ↩² ↩³

5. European Commission, Machinery, read 6 November 2026. ↩ ↩² ↩³ ↩⁴

6. legislation.gov.uk, changes tables for 2026: electrical regulations, RoHS, EMC, machinery, read 6 November 2026. ↩ ↩²

7. GOV.UK, Fast-Track UKCA, published 31 March 2026. ↩ ↩²

8. Office for Product Safety and Standards, Supply of Machinery (Safety) Regulations 2008: Great Britain, updated 24 March 2025. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

9. GOV.UK, Placing UKCA or CE marked products on the market in Great Britain, published 31 March 2026, updated 21 August 2026. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³

10. GOV.UK, RoHS compliance and guidance, updated 22 July 2025. Parts of this page still describe UKCA for GB and CE for Northern Ireland; the sector table and SI 2024/696 cover recognition. ↩ ↩² ↩³ ↩⁴

11. GOV.UK, Product safety and metrology regulatory changes: UKCA and CE regimes, updated 31 March 2026. Commencement: section 15 of the Act. ↩

12. GOV.UK, Product regulation: the UK's new product safety framework, read 6 November 2026. ↩ ↩²

13. GOV.UK, Product regulation: market surveillance and enforcement framework, read 6 November 2026. ↩

14. Regulation (EU) 2023/1230, Official Journal L 165, 29 June 2023. EUR-Lex refuses automated reading, so the text was read in the EU's consolidated version 02023R1230 of 27 July 2026, which includes Regulation (EU) 2026/1744 and states that it has no legal effect, hosted by a consultancy: Article 2 list (p)(v), Article 3(3) and (16), Articles 13, 18, 51, 52 and 54, Annex I Part B point 17, Annex II point 4. Check the authentic text before relying on it. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

15. HSE, Placing work equipment and machinery on the market after Brexit, updated 29 October 2024. ↩ ↩² ↩³

16. Office for Product Safety and Standards, Electrical Equipment (Safety) Regulations 2016: Great Britain, publication updated 27 October 2026, sections 3, 4 and 6. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

17. Office for Product Safety and Standards, Electromagnetic Compatibility Regulations 2016: Great Britain, sections 4 and 6. ↩ ↩² ↩³ ↩⁴

18. legislation.gov.uk, Supply of Machinery (Safety) Regulations 2008, Schedule 2, Part 4. ↩ ↩²

19. legislation.gov.uk, Electrical Equipment (Safety) Regulations 2016, Schedule 2, paragraph 2, sub-paragraph (4)(e) and (f), version for England, Wales and Scotland, read 6 November 2026. ↩

20. BEAMA, Specifying a Low-Voltage and Controlgear Assembly, edition 1, July 2026, section 4. Trade guidance, cited for its reading only. ↩ ↩² ↩³

21. ZVEI, Placing on the market and CE marking of switchgear cabinets for machines, 5 November 2018. German trade position under the Directive, cited for its reading only. ↩ ↩² ↩³

22. European Commission, Guide to application of the Machinery Directive 2006/42/EC, edition 2.3, April 2024, §42, §68 and §388. ↩

23. legislation.gov.uk, Supply of Machinery (Safety) Regulations 2008, regulation 12A. Fast-track UKCA has the same trap at regulation 12B(4) and (5). ↩ ↩²

24. European Commission, Low Voltage Directive guide, August 2018, §70. ↩

25. legislation.gov.uk, Electromagnetic Compatibility Regulations 2016, regulation 37. ↩ ↩²

26. European Commission, EMC Directive page, Guide for the EMCD, revision 8, April 2025, section 5.4. ↩

27. legislation.gov.uk, Supply of Machinery (Safety) Regulations 2008, Schedule 2, Part 7. ↩

28. legislation.gov.uk, Supply of Machinery (Safety) Regulations 2008, Schedule 2, Part 2. ↩

29. legislation.gov.uk, Supply of Machinery (Safety) Regulations 2008, regulation 2. ↩

30. legislation.gov.uk, Explanatory Memorandum to SI 2026/867, paragraphs 5.4 to 5.11. ↩

31. GOV.UK, Government response to the call for evidence on machinery safety legislation, 25 February 2026. ↩

32. European Commission, Harmonised standards: machinery, read 6 November 2026, with its summary list. ↩

33. GOV.UK, Designated standards: machinery, consolidated list version 16, 8 August 2026. ↩