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

As of 6 November 2026: the mark and paperwork a control panel needs in Great Britain, Northern Ireland and the EU, and what changes on 20 January 2027.

By Wataru Sasaki, Editor. Written with AI assistance under human editorial supervision.

Published 5 November 2026. Updated 5 November 2026. 13 min read.

Desk research. The figures here are calculated from published formulas or taken from public records, with sources in the notes. None of it was measured on a production line.

Safety: not yet checked by a qualified engineer. This work can injure or kill. Use it to prepare questions, and follow the equipment maker's instructions, your risk assessment and the licensed standard.

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. SI 2026/867 does not amend the electrical, EMC or RoHS regulations, so on our reading a panel outside the machinery rules keeps its present route.

Not legal advice. Rules last checked 6 November 2026.

The position, rule by rule

RuleWhat the source saysDate
Marking in Great BritainUKCA or CE for electrical equipment, EMC, machinery and RoHS.1 Fast-Track UKCA may rest on recognised EU requirements5GOV.UK, 31 March 2026
Basis of CE recognitionSI 2024/696 removed the expiry of the provisions that let GB obligations be met through EU requirements2; OPSS calls this indefinite6In force 1 October 2024
UKCA on a label or accompanying documentAllowed until 11pm on 31 December 20277; Defra says on the product from 1 January 2028, unless that is not possible or warranted86Guidance updated 21 August 2026
Northern Ireland markingCE, or CE and UKNI; UKNI is never used alone.4 Qualifying goods can enter the GB market on those marks7Guidance updated 8 April 2026
Product Regulation and Metrology Act 2025 and what is made under itIn force 21 July 2025 except section 11(1) and (3); an enabling Act.9 SI 2026/867 is made partly under it, the only instrument we could find that bears on panels.3 Consultations on a new safety framework and on enforcement closed 23 June 2026; both pages said "We are analysing your feedback" on 6 November 20261011SI made 22 July 2026; in force 20 January 2027
EU Machinery Regulation 2023/1230Applies from 20 January 2027, when Directive 2006/42/EC is repealed.1213 Machinery placed before then must meet the Directive12Commission page read 6 November 2026
Great Britain machinery from 20 January 2027New regulations 12A and 12B: CE or UKCA may rest on the Regulation's requirements. Machinery already placed in line with the rules then in force may continue to be made available3In force 20 January 2027
Northern Ireland machinery from 20 January 20272008 Regulations revoked for Northern Ireland; the Regulation applies directly, with HSENI enforcing for products used at work3In force 20 January 2027

HSE's machinery page, last updated 29 October 2024, still says CE recognition ends on 31 December 2024.14 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 (conformity bodies under the India trade agreement), and 28 to the 2008 machinery regulations, all from SI 2026/867.15 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

RegimeConformity route and core documents
Electrical Equipment (Safety) Regulations 2016; Directive 2014/35/EU. 50 to 1,000 V AC, 75 to 1,500 V DC16Self-declaration.7 Technical documentation, declaration of conformity, marking, identification, instructions in English16
Electromagnetic Compatibility Regulations 2016; Directive 2014/30/EU17Self-declaration.7 Same documents17
RoHS Regulations 2012; Directive 2011/65/EU8Self-declaration.7 Technical file, declaration, substance control. GB runs its own exemptions; Northern Ireland follows the EU's8
Supply of Machinery (Safety) Regulations 2008; Directive 2006/42/EC, then Regulation 2023/1230 from 20 January 202763Self-declaration, except that machinery in Schedule 2 Part 4 self-declares only where designated standards covering all applicable requirements are applied in full; otherwise an approved or notified body.718 Partly completed machinery: declaration of incorporation and assembly instructions, with no marking614

Which regime is your panel under?

This table is our inference from the sources in its last column. The standard you build to is a separate question: see 61439 or 60204-1.

What you are sellingProbable regimesWhy, and who might disagree
Stand-alone low-voltage panel, switchboard or MCC, or a panel in your name for someone else's machine, no safety functions or only bought-in safety components fitted to their makers' instructionsElectrical, EMC, RoHS; your declarationBEAMA says every assembly on the GB market must carry the mark.19 The machinery regulations exclude low-voltage switchgear and control gear in so far as the electrical regulations cover it,6 and the Regulation keeps that.13 ZVEI's cases 3.1 and 3.2b are a German trade view;20 no UK authority confirms it for panels.
Panel where you implement a safety function yourselfMachinery as a safety component, plus EMC and RoHSCheck first whether it counts as a logic unit to ensure safety functions (Schedule 2 Part 4 item 21 today; Annex I Part B point 17 of the Regulation).1813 The Commission's guide limits that to complex components and says the control system as a whole is not one, so take advice.21 If it is one, you can self-declare only where standards covering all the relevant requirements are applied in full; otherwise an approved or notified body is needed.7 On the GB CE route a missing matching designated standard can itself force third-party assessment: regulation 12A(6) and (7) today, new regulation 12A(2)(c) from 20 January 2027.223
Panel built to a machine builder's order, not marketed in your nameNone of its own, according to ZVEI, if the machine builder takes responsibilityContested. BEAMA's wording points the other way and OPSS is mixed.20196 A contract records who takes responsibility; it does not decide whether a placing on the market happened. If the panel could go on anything else, or the customer will not accept the role in writing, issue your own declaration.
A complete machine, with its panelMachinery, plus EMC and RoHSThe Commission's LVD guide says such a declaration refers to machinery and not the LVD.23
One-off panel for a named fixed installation, not otherwise soldElectrical and RoHS as above. EMC differsEMC regulation 37 lifts the apparatus duties in Parts 2 and 3 if you supply the installation's EMC characteristics and precautions.24 The Commission calls the EU equivalent extraordinary and case by case.25 We read this as lifting the EMC duties only.
Panel with a radio module, or for a hazardous areaAdd the Radio Equipment Regulations 2017 or the explosive atmospheres regulationsBoth have their own lines in the sector table, and third-party assessment can apply.17

What to keep, and for how long

Keep one file per panel serial number until 10 years after the last unit of that design was placed on the market. For a fixed installation, whoever installed it keeps the engineering practice documents for the whole period of operation.24

The clocks underneath 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,8 and the 2008 machinery rules from manufacture.2627 GOV.UK counts from each individual product.7

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

An importer is a person or business established in the UK who supplies a product from outside the UK.7

CaseWho is the importerWhose address, and whereThe labelling concession
EEA or Swiss maker to Great BritainThe UK business placing it on the market, including a former distributor17The importer's, on the productUntil 31 December 2027 it may go on the packaging or an accompanying document716
Japanese maker to Great BritainThe UK business placing it on the marketThe importer's, on the product, or on packaging or a document only if that is not possible16On our reading, not available: it covers goods from an EEA state or Switzerland
GB maker to Northern Ireland or the EUIn the EU, an EU businessOPSS says the NI or EU importer's address must be on the goods16None16

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.6

An importer selling under its own name, or modifying the product in a way that affects compliance, takes on the manufacturer's duties.7 A Japanese or EU maker selling to a UK reseller or integrator makes that customer the importer, on our reading. 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,28 and the OPSS glossary is wider still: "or the person placing the product on the GB market".6 A GB business bringing in machinery from a maker with no UK representative should assume it may carry the manufacturer's duties. We read SI 2026/867 as creating no separate importer regime in Great Britain, which does not leave the importer free of duty. In Northern Ireland and the EU the Regulation adds importer duties from 20 January 2027.133

Does the Machinery Regulation change anything for a panel?

On our reading, 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.13 Safety logic gets more attention: a safety component is now "a physical or digital component, including software".13

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.13 HSE's line for Great Britain is broader in wording.14

Documents can be digital from 20 January 2027. Until then the EC declaration must accompany the machinery.22 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,6 and GOV.UK counts each individual product,7 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. On our reading of SI 2026/867, machinery placed in Great Britain on or after that date cannot rely on Directive-based CE: it needs the Regulation's requirements (CE or UKCA) or the 2008 Regulations' own UKCA route.3 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,29 and the February 2026 response says full replication is not possible.30 So from 20 January 2027 a UKCA route under the 2008 Regulations' own requirements appears to run beside one under the EU's, and we do not know 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.31 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 60204-1:2018,32 so check why the list and the current edition can differ before you cite one.

Guidance and reform. The Commission's machinery page still lists only the guide to the Directive,12 and the OPSS guide predates the 2026 instrument.6 Do not plan around the product safety proposals until the government responds.10 Keep UKCA and CE declaration templates separate, since GOV.UK's Fast-Track guidance raises divergence as a hypothetical.5

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

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

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

  6. 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

  7. 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

  8. 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

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

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

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

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

  13. 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

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

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

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

  20. 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

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

  22. 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

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

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

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

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

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

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

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

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

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

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