Standards·12 min read·

UKCA Marking for Steel Products: What Mill Certs Must Show Post-Brexit

Quick Answer

Quick Answer

UKCA (UK Conformity Assessed) marking replaced CE marking for construction steel products placed on the Great Britain market from 1 July 2025. Compliant steel mill test certificates must reference the applicable UK-adopted standard, name a UKAS-approved body with its UK(AB) number, and include or reference a UK Declaration of Performance (UK DoP). CE marking remains valid in Northern Ireland and the EU.

UKCA is the UK's post-Brexit product conformity marking system, administered by the Office for Product Safety and Standards (OPSS) and implemented through the UK Construction Products Regulation (UK CPR). For steel, it applies to products that are permanently incorporated into construction works and fall within the scope of a harmonised UK standard. This page is a compliance guide — it explains what UKCA means in practice for structural steel MTCs, which steel products are in scope, and exactly what an auditor checks when reviewing a UKCA-compliant certificate.


Scope and Applicability

Which steel products require UKCA marking?

Steel products requiring UKCA marking on the GB market are those covered by harmonised UK standards (hUKS) under the UK CPR. The key product families and their governing standards are:

Steel product familyStandardTypical products
Hot-rolled structural sections and platesBS EN 10025 (Parts 1–6)I-beams, angles, flats, plates for building frames
Hot-finished structural hollow sectionsEN 10210-1CHS, RHS, SHS used as columns and struts
Cold-formed structural hollow sectionsEN 10219-1Thin-wall hollow sections in lighter structures
Reinforcing bar and coilBS 4449:2005+A3Rebar for concrete slabs, columns, foundations
Welded fabric (mesh)BS 4483Reinforcing mesh for slabs
Weathering steel hollow sectionsBS 7668Exposed architectural and bridge hollow sections
Steel wire for concrete reinforcementEN 10138 (where applicable)Prestressing tendons, bonded post-tensioning

Products outside UK CPR scope (do not require UKCA): steel products used exclusively in mechanical engineering, pressure vessels, pipelines, or other non-construction applications. These are governed by separate UK product regulations (UKCA under UKSI 2016/1105, PSSR, etc.).


The Attestation of Constancy of Performance (SACP) System

Under the UK CPR, each harmonised standard specifies an SACP level that determines the role of the UK Approved Body:

SACP LevelManufacturer's roleUK Approved Body roleTypical steel products
System 1+Type testing, FPCType testing, ongoing product testing, FPC certification, surveillanceSafety-critical products
System 2+Type testing, FPCFPC certification and surveillance onlyMost structural steel (EN 10025, EN 10210)
System 3Type testing onlyType testing onlySome non-structural products
System 4Full self-declarationNoneLow-risk products

Structural steel (BS EN 10025, EN 10210, EN 10219, BS 4449) is classified as System 2+. Under System 2+, the manufacturer performs all product testing and issues the UK DoP self-certified. The UK Approved Body (UKAS-accredited) audits and certifies the factory production control system and conducts ongoing surveillance visits — but does not certify individual product batches.


UK Declaration of Performance (UK DoP)

The UK DoP is the formal document in which a manufacturer declares that a construction product meets its stated essential characteristics under an applicable UK standard. It replaces the EU Declaration of Performance (EU DoP) for GB market products.

Mandatory content of a UK DoP for structural steel

A UK DoP for structural steel must contain:

FieldRequired content
1. Unique identification codeA unique reference number for the DoP
2. Intended useThe specific construction purpose (e.g. "structural steel for building and civil engineering structures")
3. Manufacturer's detailsName, registered address, and contact information
4. Authorised representative (if applicable)Name and address of EU/UK agent if manufacturer is outside GB
5. SACP level"System 2+" or the applicable level for the product
6. UK Approved BodyName of the UKAS-accredited body, its UK(AB) number, and scope of certification
7. Harmonised UK standardFull standard reference e.g. "BS EN 10025-2:2019"
8. Declared performanceTable of essential characteristics and their declared performance levels
9. Date and signatureSigned by an authorised representative of the manufacturer

EU DoP vs UK DoP

FeatureEU DoP (for CE marking)UK DoP (for UKCA marking)
Regulatory basisEU CPR 305/2011UK CPR (as retained/amended)
Notified bodyEU notified body with NB numberUKAS-approved body with UK(AB) number
MarketEU + Northern IrelandGreat Britain only
LanguageAny EU official languageEnglish (for GB market)
CE vs UKCA markCE mark on product/packagingUKCA mark on product/packaging

UKAS-Approved Body vs EU Notified Body

After Brexit, UK Approved Bodies (UK(AB)) replaced EU Notified Bodies (NB) for the GB UKCA system. They are separate registers:

Body typeAccreditationRegisterApplicable market
EU Notified Body (NB)EU member state national accreditation body (e.g. DAkkS, COFRAC)NANDO database (EC website)EU + Northern Ireland
UK Approved Body (UK(AB))UKAS (UK Accreditation Service)UKAS website / OPSS registerGreat Britain only
UK(NI) Approved BodyUKAS (NI-specific scope)OPSS registerNorthern Ireland (accepts CE or UKCA)

A mill certificate referencing a body that is only on the EU NANDO register (not on the UKAS UK(AB) register) does not demonstrate UKCA compliance for GB market placement — even if the body was formerly recognised as an EU notified body before Brexit.

How to verify UK(AB) status: Search the OPSS register at gov.uk/guidance/uk-approved-bodies or the UKAS directory. The UK(AB) number has the format UK(AB) followed by a four-digit number (e.g. UK(AB) 0123). This number must appear on the UK DoP.


CE and UKCA Dual Marking

The dual marking period — during which both CE and UKCA were accepted in GB — ended on 30 June 2025. The position from 1 July 2025:

ScenarioGB (England, Scotland, Wales)Northern IrelandEU / Republic of Ireland
Product with only UKCAAcceptedNot accepted for CE-mandated usesNot accepted
Product with only CENot acceptedAcceptedAccepted
Product with both CE + UKCAUKCA element acceptedCE element acceptedCE element accepted
Stock imported before 1 July 2025 with CEOPSS guidance permits use; check current guidanceAcceptedAccepted

Manufacturers wishing to sell into both GB and the EU now need both marks, which requires both a UK(AB) and an EU NB to certify their FPC systems under their respective regimes. Many European mills serving the UK market have obtained both to maintain access.


What a Compliant UK MTC Looks Like vs a Non-Compliant One

Compliant UK MTC — structural steel to BS EN 10025-2

A compliant certificate will contain language similar to:

"This material has been manufactured in accordance with BS EN 10025-2:2019, Grade S355J2+N. Factory Production Control has been certified by [Name] UK(AB) 0123 (UKAS-accredited). The UK Declaration of Performance reference number is [DoP-2025-XXXX], issued in accordance with the UK Construction Products Regulation."

Non-compliant UK MTC — common failures post 1 July 2025

Failure modeWhat you see on the MTCWhy it fails
CE-only reference"Conforms to EN 10025-2:2004 CE marked, NB 1234"EU NB, not UK(AB); CE not valid for GB post-July 2025
No DoP referenceStandard and grade stated but no DoP numberUK DoP must be issued and referenced
Missing UK(AB) numberUKAS body named but no UK(AB) numberCannot verify the body's scope on OPSS register
Wrong standard editionReferences superseded EN 10025-2:2004 without UK adoption confirmationBSI UK edition reference required
Self-declared only, no body"Manufactured to BS 4449, self-certified"System 2+ requires UK(AB) FPC certification

Northern Ireland Protocol / Windsor Framework

Northern Ireland remains subject to EU single market rules for goods, including the EU CPR. This means:

  • CE marking (supported by an EU NB) continues to be valid in Northern Ireland
  • UKCA marking is also accepted in Northern Ireland as an alternative
  • Goods moving from GB to NI under the Windsor Framework may require additional checks; advice from HMRC and OPSS should be followed for specific supply chains

For a fabricator in Northern Ireland supplying into both NI (EU rules) and GB (UKCA), materials with both CE and UKCA marks provide the most flexibility.


MTC Compliance Checklist — 8 Fields an Auditor Checks for UKCA

When auditing a steel mill test certificate for UKCA compliance on the GB market, verify these eight fields in order:

#FieldWhat a compliant MTC showsRed flag
1Applicable standardUK-adopted standard e.g. "BS EN 10025-2:2019"References EU-only EN edition without UK confirmation
2Grade designationFull grade per standard e.g. "S355J2+N" or "B500B"Grade absent or uses non-standard abbreviation
3UK DoP referenceDoP number traceable to the manufacturer's published UK DoPNo DoP reference; or EU DoP only
4UK(AB) name and numberNamed UKAS-approved body with format "UK(AB) XXXX"NB number only (format: 4-digit EU number without UK(AB) prefix)
5SACP level"System 2+" stated or implied by UK DoPSystem 4 self-declaration only (insufficient for structural steel)
6UKCA marking confirmationStatement that product is UKCA marked or DoP confirms UKCACE marking stated as sole conformity route
7Chemical and mechanical resultsValues within the limits of the declared UK standard and gradeValues present but no standard reference to verify against
8EN 10204 certificate typeType 3.1 (or 3.2 for pressure/critical applications) signed by authorised inspectorType 2.2 (works certificate) — insufficient for structural compliance

Frequently Asked Questions

Is UKCA mandatory for all steel used in UK construction from July 2025?

UKCA is mandatory for construction products within the scope of a harmonised UK standard that are placed on the GB market from 1 July 2025. Products used in mechanical engineering, pipework, pressure equipment, or other non-construction applications fall under different UK product regulations. "Placed on the market" means making the product available for the first time in GB — products already in a stockholder's inventory before 1 July 2025 are not automatically affected, though OPSS guidance on this should be checked for each specific product type.

Can a European mill's CE DoP be used in the UK?

No. An EU DoP (used for CE marking) cannot substitute for a UK DoP (required for UKCA marking) on the GB market from 1 July 2025. However, a European mill that has also obtained UK(AB) FPC certification from a UKAS-accredited body can issue both a UK DoP (referencing the UK(AB)) and an EU DoP (referencing the EU NB), allowing the product to carry both marks and be sold in both markets.

What type of EN 10204 certificate is required for UKCA-compliant structural steel?

EN 10204 Type 3.1 is the standard requirement. Type 3.1 is a test report produced by the mill's authorised inspector (independent of production), validated against the order. Type 2.2 (a works certificate declaring conformity without third-party inspection) is not sufficient to demonstrate compliance with the mechanical and chemical requirements of structural steel standards. Type 3.2 — validated by a purchaser's representative or independent inspector — provides the highest level and may be required for critical applications.

How do I verify that a UK Approved Body is genuinely UKAS-accredited?

Search the UKAS directory at ukas.com or the OPSS UK Approved Bodies register at gov.uk. Enter the body's name or UK(AB) number. The entry will show: the accredited scope (which standards and SACP levels), the accreditation status (active/suspended), and the body's registered address. If the body does not appear or its scope does not cover the relevant standard, the certificate is non-compliant.

What happens if I receive non-UKCA steel for a UK project after July 2025?

For a project specified under UKCA requirements, non-compliant material cannot be incorporated into the works without a concession or substitution approved by the structural engineer and (where applicable) the building control authority. Options are: return the material to the supplier, obtain supplementary independent testing and a UK DoP through an alternative route, or formally approve a concession documenting the evidence of compliance. The procurement contract should include warranties that all construction products comply with applicable UK conformity requirements at the time of delivery.

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