Since Brexit, motorcycle apparel sold in Great Britain — England, Scotland, and Wales — has needed to carry the UKCA (UK Conformity Assessed) mark rather than the EU CE mark. For brands launching in or expanding to the UK market, this creates an additional certification layer that sits alongside, not instead of, CE certification for EU sales.

This guide explains the UKCA requirement as it applies to motorcycle clothing in 2025: what has changed, what has stayed the same, how the two marks relate to each other, and what brands need to do in practice to sell certified garments in Great Britain.

What Changed After Brexit

Before 31 December 2020, the CE mark was valid across both the EU and the UK. UK market access was governed by EU product safety legislation, and a garment certified to EN 17092 with a CE mark could be sold in any EU country and in the UK without any additional certification.

From 1 January 2021, the UK separated its product regulation framework from the EU. Great Britain (England, Scotland, Wales) introduced the UKCA mark as the UK equivalent of the CE mark. Northern Ireland operates under a different arrangement — the Windsor Framework means CE-marked products continue to be accepted in Northern Ireland, aligning it with the EU single market for goods.

For motorcycle apparel specifically, the technical standard remains the same — EN 17092 applies in both the EU and UK. What changes is the conformity assessment procedure, the identity of the Responsible Person, and the mark affixed to the garment.

The Current Position in 2025

The UK government has extended recognition of CE marks for many product categories multiple times since Brexit. As of 2025, CE-marked motorcycle apparel can still be sold in Great Britain under a transitional arrangement, but brands selling into the UK market should treat this as a temporary situation and plan for full UKCA compliance.

The UK Office for Product Safety and Standards (OPSS) has signalled that permanent recognition of CE marks in Great Britain will not continue indefinitely. Brands building a UK retail strategy should obtain UKCA marking now rather than waiting for the transition period to end under time pressure.

UKCA vs CE: The Practical Differences

The technical standard is the same — EN 17092 for jackets, suits, and trousers; EN 13594 for gloves. You do not need to retest to different performance requirements. The differences are procedural:

The Responsible Person

For CE marking, the Responsible Person — the entity that places the Declaration of Conformity on the market — must be established in the EU. This can be the brand itself (if EU-registered) or an authorised representative in the EU.

For UKCA marking, the Responsible Person must be a UK Responsible Person — an entity registered in the UK. If your brand is UK-registered, you can act as your own UK Responsible Person. If you are an EU brand selling into the UK, you need either a UK entity or to appoint a UK-based Authorised Representative.

The Declaration of Conformity

A CE Declaration of Conformity (DoC) references EU legislation and the CE mark. A UKCA Declaration of Conformity references UK legislation and the UKCA mark. They must be separate documents, although the underlying technical evidence (test reports, Technical Construction File) can be the same for both.

Brands selling in both markets need two Declarations of Conformity — one for CE, one for UKCA — referencing the same test evidence.

The Mark

CE and UKCA marks are different symbols. CE-marked garments sold in Great Britain must eventually display the UKCA mark instead. During the current transitional period, CE marks are still accepted, but plan for dual marking (CE on the EU-facing label, UKCA on the UK-facing label) or a universal label that complies with both markets.

Notified Bodies vs Approved Bodies

For CE certification, third-party conformity assessment is conducted by EU Notified Bodies. For UKCA certification, the equivalent bodies in Great Britain are called UK Approved Bodies. Many laboratories that were previously EU Notified Bodies have obtained UK Approved Body status and can issue both CE and UKCA certificates from the same test programme.

When commissioning testing, confirm that the laboratory holds both EU Notified Body status (for CE) and UK Approved Body status (for UKCA). Most major international test labs — SGS, Intertek, Bureau Veritas, Element — hold both.

Practical Steps for UK Market Entry

Step 1: Confirm Your UK Responsible Person Status

If your brand is UK-registered, you can act as your own UK Responsible Person. Confirm this with your legal adviser or directly with the OPSS guidance. If you are not UK-registered and are entering the UK market through a distributor, determine whether your distributor can act as UK Responsible Person or whether you need to appoint a separate UK Authorised Representative.

Step 2: Commission Testing with a UK Approved Body

When you commission EN 17092 testing, request that the lab issue a UKCA-applicable report in addition to the CE test report. Most labs handle this as a single submission with dual output. Confirm the lab's UK Approved Body number before commissioning.

Step 3: Prepare UK-Specific Documentation

Issue a UKCA Declaration of Conformity referencing the UK legislation (Supply of Machinery (Safety) Regulations 2008 or the relevant UK PPE regulation as applicable). The DoC format is defined in UK legislation — it differs slightly from the EU format.

Step 4: Label Compliance

Garments sold in Great Britain under UKCA must display the UKCA mark. If you are selling to both the EU and UK, your labelling options are:

  • Separate label variants: CE label for EU stock, UKCA label for UK stock
  • Dual-marked label: displays both CE and UKCA marks with the relevant declarations available for each market
  • UK-only label: UKCA mark only for garments sold exclusively in Great Britain

The UKCA mark must be displayed at the same prominence as the CE mark. It cannot be smaller or less legible than any other mark on the label.

Northern Ireland: A Special Case

Northern Ireland sits in a unique regulatory position under the Windsor Framework. CE-marked goods produced to EU standards can circulate freely in Northern Ireland. UKCA-only marks are not sufficient for goods sold in Northern Ireland — CE marking is required.

For most motorcycle apparel brands, the practical approach is to use CE marking across all Irish island distribution (Republic of Ireland and Northern Ireland), and UKCA marking for Great Britain. Dual marking (both CE and UKCA) on a single label is the simplest solution for brands selling to all four nations of the UK plus the Republic of Ireland.

How AJSAMCO Supports UKCA Compliance

AJSAMCO has manufactured garments for UK-registered brands since before Brexit and understands the UKCA transition. We support brands with:

  • Material data sheets and construction specifications for UK Technical Construction Files
  • Recommendations for UK Approved Body laboratories for testing
  • Label design review to confirm UKCA mark placement and content
  • Flexible label production — we can produce garments with CE-only, UKCA-only, or dual-marked labels depending on your distribution markets

If you are entering the UK motorcycle apparel market or expanding an existing EU brand into Great Britain, request our product catalogue to see our current range and discuss compliance requirements with our team.