United Kingdom maintains alignment with the EU

The European regulatory change resulting from Regulation (EU) 2023/1230, applicable from January 20, 2027, will have a direct impact on access to the UK market.

The British Government has confirmed that it will maintain the recognition of the CE marking in Great Britain indefinitely, which means that products that comply with the new European Regulation can continue to be marketed in this market without the need for duplicate certification.

In parallel, Northern Ireland will directly apply this Regulation as of October 2026, within the framework of its specific regulatory obligations.

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What will change for exporting to the UK?

From January 2027, any machine placed on the market in the EU or Northern Ireland will have to comply exclusively with Regulation (EU) 2023/1230. Since the UK recognizes this framework, this requirement becomes the technical reference for exporting to Great Britain as well.

This means that companies will have to adapt their products to new requirements, especially in areas related to digitalization, software and security.

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Direct impact on exporting companies

The new Regulation introduces relevant changes in the obligations of manufacturers and economic operators, which directly affect companies selling machinery in the United Kingdom.

The main impacts include:

• The consideration of software as a safety component.
• Mandatory inclusion of source code and control logic in technical documentation.
• Strengthening the obligations of importers and distributors in the verification of compliance.
• The definition of “substantial modification”, which shifts responsibilities from the manufacturer.

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These changes involve a thorough review of design, documentation and certification processes.

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What products and processes are affected

The scope of the Regulation is extended and incorporates new categories and requirements. Certain machines will require mandatory intervention by notified bodies, especially those with advanced safety components or self-evolving behavior.

Likewise, the requirements for partially completed machines are increased and the use of digital documentation is consolidated, provided that its availability is guaranteed for at least ten years.

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Preparing to maintain access to the British market

For exporting companies, this new scenario means that adaptation to the European Regulation will be key to ensuring continuity in the United Kingdom.

Regulatory alignment between the two markets avoids duplication, but requires anticipation. Starting a gap analysis as soon as possible and adapting internal processes will be crucial to meet deadlines and avoid commercial risks.

In order to facilitate this transition, we have prepared an extended briefing note with full details of the changes, their specific impact in the UK and recommended actions for companies.