Following the UK's departure from the European Union, manufacturers supplying explosion-protected equipment to both Great Britain and the European Union must ensure they understand the differences between the UKEX and ATEX regulatory frameworks. While the technical standards remain closely aligned, the conformity assessment and product marking requirements differ depending on the destination market.

What is UKEX?

UKEX is the conformity marking required for products placed on the market in Great Britain (England, Scotland and Wales). It applies to equipment and protective systems intended for use in potentially explosive atmospheres under the Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016, as amended following Brexit.

Although UKEX is based on the same essential health and safety requirements as the ATEX Directive, products destined for Great Britain must follow the UK conformity assessment process where applicable.

ATEX Remains in Force in the European Union

Manufacturers supplying equipment to EU member states must continue to comply with the ATEX Directive 2014/34/EU and apply the CE and Ex markings where required.

The technical standards supporting both UKEX and ATEX are largely harmonised with the IEC 60079 series, meaning the engineering requirements remain familiar to manufacturers. However, the administrative route to market differs.

Key Differences

Manufacturers should be aware of several important distinctions:

• UKEX applies in Great Britain, while ATEX applies across the European Union.
• Products requiring third-party conformity assessment must use an approved UK body for UKEX certification and an EU Notified Body for ATEX certification.
• Technical documentation and declarations of conformity must reference the appropriate legislation for the intended market.
• Separate certificates may be required when placing products on both the GB and EU markets.

Planning for Dual Market Access

Many manufacturers continue to serve customers in both Great Britain and the European Union. Planning certification early can help minimise duplication, reduce costs and avoid delays when launching new explosion-protected equipment.

By understanding the differences between UKEX and ATEX, manufacturers can ensure their products remain compliant while maintaining access to key industrial markets.