Medical Device Compliance: CE vs. UKCA After Brexit

CE vs. UKCA: Understanding the Differences

Medical device manufacturers exporting to both the UK and EU must understand how CE and UKCA markings differ. While both serve as regulatory certifications, they have distinct requirements, approval processes, and governing bodies.

What Is the CE Mark?

The CE (Conformité Européenne) mark indicates that a medical device complies with EU regulations and can be sold across European Economic Area (EEA) countries.

Regulatory Framework: Medical devices must meet requirements under EU MDR (Medical Device Regulation) or IVDR (In Vitro Diagnostic Regulation).
Approval Process: Devices are assessed by Notified Bodies, which verify compliance before granting certification.
Market Access: Required for selling medical devices in all EU member states, Iceland, Norway, and Liechtenstein.

What Is the UKCA Mark?

The UKCA (UK Conformity Assessed) mark is the post-Brexit replacement for CE marking in Great Britain (England, Scotland, and Wales).

Regulatory Framework: Medical devices must meet standards set by the UK Medical Devices Regulations 2002, which currently mirror EU MDR/IVDR but may diverge in the future.
Approval Process: Manufacturers must work with UK Approved Bodies instead of EU Notified Bodies for product assessments.
Market Access: Required for selling medical devices in Great Britain (Northern Ireland still follows CE rules due to the Northern Ireland Protocol).

Key Differences at a Glance

Feature	CE Mark	UKCA Mark
Regulatory Authority	EU MDR / IVDR (European Commission)	UK Medical Devices Regulations (MHRA)
Approval Bodies	EU Notified Bodies	UK Approved Bodies
Market Coverage	EU, EEA, and Northern Ireland	Great Britain (England, Scotland, Wales)
Recognition in the UK?	Currently recognized until transition ends	Required after transition period

Manufacturers selling in both markets need dual compliance, ensuring their devices meet both CE and UKCA requirements to prevent market restrictions. Up next, we’ll cover medical device compliance deadlines and transition periods so you know when key regulatory changes take effect.

Need to get a CE certification for your medical product? Check out Remington Medical’s step-by-step guide to discover everything you need to know.

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Compliance Deadlines and Transition Periods

To give manufacturers time to adapt to post-Brexit regulations, the UK government has introduced a phased transition from CE to UKCA marking. However, these deadlines are quickly approaching, and failure to comply could lead to distribution challenges or even product removal from the market. Below is a breakdown of the key dates and transition rules you need to know.

Key Deadlines for UKCA Compliance

Manufacturers and medical device companies must pay close attention to the following deadlines to avoid compliance disruptions:

June 30, 2023 – The UK extended the transition period, allowing CE-marked medical devices to remain temporarily valid in Great Britain.
July 1, 2024 – UKCA marking becomes mandatory for newly introduced medical devices in Great Britain (subject to final confirmation by regulators).
June 30, 2028 – CE-marked medical devices already placed on the UK market can remain until this date, provided they stay compliant with EU regulations.

Transition Rules for CE and UKCA Marking

Manufacturers selling in the UK need to understand how long CE marking remains valid and when UKCA marking takes full effect.

Devices already CE-marked before July 1, 2024: These can continue to be sold in Great Britain until June 30, 2028, without immediate UKCA approval. However, if any significant modifications are made to the device, it may need to undergo UKCA conformity assessment earlier.
New medical devices entering the UK market after July 1, 2024: These must have UKCA certification and be assessed by a UK Approved Body before being placed on the market. CE marking alone will no longer be sufficient unless further extensions are announced.
Northern Ireland Exception: Northern Ireland still follows EU MDR and IVDR under the Windsor Framework, meaning CE marking remains required there. UKCA marking is not recognized in Northern Ireland, so medical device manufacturers must ensure separate compliance strategies for this region.

What This Means for Medical Device Manufacturers

Remaining compliant means acting ahead of deadlines and ensuring smooth regulatory transitions. As they aim to distribute medical devices deemed safe and effective, here’s what manufacturers should consider:

If you sell in both the UK and EU – You need to maintain compliance with both CE and UKCA regulations to avoid disruptions.
If you only sell in the UK – Start working with a UK Approved Body to ensure your devices are UKCA-certified before the deadline.
If you only sell in the EU – UKCA regulations won’t impact your operations, but staying informed is important in case of future changes.

Understanding these deadlines is crucial for success in the medical device industry, helping you avoid delays, regulatory penalties, and product distribution issues.

Steps to Maintain Medical Device Compliance in Both the UK and EU

To avoid regulatory setbacks and ensure seamless product distribution, medical device manufacturers must take proactive steps to comply with both CE and UKCA requirements. This involves updating documentation, working with the right regulatory bodies, and planning ahead for future changes.

Conduct a Regulatory Gap Analysis

Before making changes, manufacturers should evaluate how current CE-marked devices align with UKCA requirements. This helps identify potential compliance gaps early.

Review existing certifications – Determine whether your current CE marking will remain valid under the transition period.
Assess differences in regulations – While UKCA currently mirrors EU MDR/IVDR, future changes could create divergences that need attention.

Identify the Correct Regulatory Bodies

CE and UKCA certifications require approvals from different organizations, so manufacturers must engage with the appropriate regulatory bodies.

For CE marking – Work with an EU Notified Body to ensure compliance under EU MDR or IVDR.
For UKCA marking – Partner with a UK Approved Body to certify products for sale in Great Britain.

Pro Tip: If you plan to sell in both the UK and EU, consider working with regulatory consultants who have expertise in both regions.

Update Technical Documentation and Labeling

Medical device compliance requires detailed technical documentation, and labeling requirements differ between CE and UKCA.

Revise documentation – Ensure device specifications, clinical data, and post-market surveillance plans meet UKCA requirements.
Update product labels – Devices sold in Great Britain must display the UKCA mark instead of or in addition to the CE mark, depending on the transition timeline.

Ensure Compliance for Legacy Products

If your medical device is already on the market under CE marking, you may need to take additional steps to maintain compliance under UKCA.

For devices with CE marking before July 1, 2024 – You can continue selling them in Great Britain until June 30, 2028.
For new devices post-2024 – They must undergo UKCA assessment before entering the UK market.

By taking these steps now, manufacturers can prevent regulatory disruptions and keep their devices legally available in both regions.

How Contract Manufacturers Can Support Your Compliance Efforts

Navigating the transition from CE to UKCA compliance can be challenging, especially for manufacturers managing multiple regulatory requirements. Contract manufacturers can play a key role in ensuring your medical device compliance, reducing the burden on internal teams, and helping you avoid costly delays.

Assisting With Conformity Assessments and Regulatory Submissions

Contract manufacturers often have established relationships with regulatory bodies and a deep understanding of both compliance requirements and international standards. They can:

Guide manufacturers through the UKCA conformity assessment process with UK Approved Bodies.
Ensure technical documentation meets both EU MDR/IVDR and UK medical device regulations.
Assist with regulatory submissions, reducing the risk of approval delays.

Supporting Technical Documentation and Labeling Compliance

Meeting UKCA requirements involves updating documentation and product labeling. Contract manufacturers can help by:

Reviewing and updating risk management files, clinical evaluations, and post-market surveillance reports.
Ensuring packaging and labeling include both CE and UKCA marks where necessary.
Maintaining compliance records to meet audit and inspection requirements.

Managing Supply Chain and Manufacturing Adjustments

Regulatory shifts may require manufacturing modifications, especially for companies producing dual-compliant products. Contract manufacturers help by:

Adjusting production lines to accommodate both CE and UKCA marking requirements.
Ensuring materials and components comply with UK-specific medical device regulations.
Implementing quality control measures that align with UK and EU standards.

Keeping Manufacturers Ahead of Regulatory Changes

Regulations are expected to evolve further, and staying compliant requires ongoing monitoring. Contract manufacturers can:

Provide early insights into regulatory updates to prevent last-minute disruptions.
Offer continuous compliance support, ensuring effective medical devices that remain market-ready.
Help companies strategize for long-term compliance rather than reacting to last-minute rule changes.

By partnering with a reliable contract manufacturer, businesses can streamline the compliance process, focus on innovation, and ensure their medical devices remain legally available in both the UK and EU markets.

Partner With Remington to Ensure Medical Device Compliance

Remington Medical specializes in medical device contract manufacturing, providing end-to-end regulatory support to ensure your products meet all necessary requirements. From prototyping to packaging, our expert team helps you make sure your devices are safe, effective, and compliant. Contact us today to discuss how we can support your regulatory and manufacturing needs.

Medical Device Compliance After Brexit: CE vs. UKCA

CE vs. UKCA: Understanding the Differences

What Is the CE Mark?

What Is the UKCA Mark?

Key Differences at a Glance

Compliance Deadlines and Transition Periods

Key Deadlines for UKCA Compliance

Transition Rules for CE and UKCA Marking

What This Means for Medical Device Manufacturers

Steps to Maintain Medical Device Compliance in Both the UK and EU

Conduct a Regulatory Gap Analysis

Identify the Correct Regulatory Bodies

Update Technical Documentation and Labeling

Ensure Compliance for Legacy Products

How Contract Manufacturers Can Support Your Compliance Efforts

Assisting With Conformity Assessments and Regulatory Submissions

Supporting Technical Documentation and Labeling Compliance

Managing Supply Chain and Manufacturing Adjustments

Keeping Manufacturers Ahead of Regulatory Changes

Partner With Remington to Ensure Medical Device Compliance

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