UK: New Post-Brexit Barriers – UKCA Certification and Customs Clearance Splitting for Steel Exports to the UK

Since officially leaving the EU single market in 2021, the UK has established its own independent technical regulations and customs system, posing new compliance challenges for steel exporters. Understanding and adapting to UKCA certification and complex customs clearance splitting processes has become a prerequisite for entering the UK market.

Part 1: UKCA Certification – The New UK Compliance System Replacing the CE Mark

1. Core Requirements of the UKCA Mark

Implementation Time: From January 1, 2023, the UKCA mark will be fully mandatory (with a transition period for certain products).

Scope of Application: Most steel products previously requiring the CE mark and placed on the market in England, Wales, and Scotland.

Construction steel (structural steel, reinforcing bars, etc.)

Pressure equipment components

Machinery and safety components

2. Key Differences Between UKCA and CE Certification

Dimensions: UKCA Certification | CE Certification
Applicable Region: British British Market | EU and EEA
Issuing Body: UK Accreditation Body (UKAS) | EU Notified Body
Technical Standards: Adopts British Standards (BS) | Adopts EU Harmonized Standards
Regulatory Framework: Based on UK regulations (e.g., the Building Products Regulation) | Based on EU directives/regulations
Representation Requirements: Must designate an authorized representative in the UK | Authorized representative in the EU

3. UKCA Certification Process for Steel Products

Step 1: Determine Applicable Regulations

Building Products Regulation

Pressure Equipment Safety Regulation

Machinery Supply Safety Regulation

Step 2: Comply with UK Specified Standards

BS EN standards are generally identical in technical content to EN standards, but the latest UK version must be confirmed.

The UK has begun developing its own standards, which require continuous monitoring.

Step 3: Conduct Conformity Assessment

Self-Declaration (applicable to low-risk products)

Third-Party Certification (for high-risk products, must be performed by a UKAS-accredited body)

Step 4: Prepare Technical Documents

Product Description and Specifications

Design and Manufacturing Drawings

Risk Assessment Report

Test Reports and Calculation Results

Declaration of Conformity (must include references to UK regulations)

Step 5: Affix the UKCA Mark

The mark must be clearly visible and durable.

Minimum height 5mm (can be reduced in special cases)

Include information on the UK authorized representative.

Part Two: UK Customs Clearance Splitting – Addressing the New Reality of the UK-EU Border

1. The Nature and Triggering Conditions of Customs Clearance Splitting
   Root Cause: The UK is no longer a member of the EU Customs Union, and special rules apply to goods entering Northern Ireland.

Core Challenge: When a shipment contains components destined for both the UK and the EU, it must be declared separately upon import.

2. Typical Customs Clearance Segments for Steel Products

Scenario 1: Transit via the UK to the EU

China Port → Felixstowe Port (Main Port)

├── Partial Goods: UK Customs Clearance, UK Duty Payment, Entering England

└── Partial Goods: Transit Declaration, Transit to Rotterdam, Netherlands, Then EU Customs Clearance
Key Operational Points: UK Transit Declaration must be completed in advance; goods must be under customs supervision within the UK.

Scenario 2: Special Rules for Northern Ireland Destination

China Port → Liverpool Port

├── England Destination: UK Tariff Schedule Applicable

└── Northern Ireland Destination: EU Tariff Schedule Applicable (according to the Northern Ireland Protocol)
Key Mechanism: Use the “Northern Ireland” code for special declaration; customs duty refund mechanism may apply.

Scenario 3: UK Warehousing and Distribution to the EU

China → UK Bonded Warehouse

├── Entering the UK Market in Batches: UKCA certification and customs clearance for each batch

└── Transshipment to the EU in Batches: Re-certification (CE marking) and customs clearance required according to EU rules.

3. Key Points for Customs Clearance Splitting

Document Separation: Prepare separate customs document packages for goods destined for different destinations.

Tariff Classification Verification: Differences exist between UK and EU tariff schedules; separate verification is required.

Origin Management: UK and EU rules of origin differ, affecting eligibility for tariff preferences.

VAT Processing: The UK uses an independent VAT system; tariff codes, rates, and declarations are separate from the EU’s.

Part Three: Specific Considerations for the Steel Industry

1. UK Steel Safeguard Measures

Steel Product Quota Management: The UK implements tariff quotas for specific steel products.

National Allocation and First-Come, First-Served: Quota allocation methods differ from the EU; advance planning is necessary.

Certificate of Origin Requirements: Certificates of origin complying with UK rules are mandatory.

2. Impact of UK Low-Carbon Policies

Carbon Border Adjustment Mechanism Research: The UK is considering establishing a system similar to CBAM.

Low-Carbon Requirements for Public Procurement: Government projects impose requirements on the carbon footprint of steel.

Industry Decarbonization Roadmap: Focus on the UK steel industry’s 2030-2050 emission reduction targets.

3. Supply Chain Restructuring Strategies

Strategy A: UK Warehouse as Regional Hub

Establish a bonded warehouse in the UK to serve the UK and Irish markets.

Advantages: Rapid response to UK orders.

Challenge: Maintaining dual-certified inventory.

Strategy B: EU Warehouse + Separate UK Delivery

Establish an EU central warehouse in the Netherlands or Belgium.

Ship UK orders separately and complete UKCA certification.

Advantages: Reduced UK warehousing costs.

Challenge: Extended delivery times to the UK market.

Strategy C: Dual-Line Supply Chain

Establish independent UK and EU supply chains.

Advantages: Professional operation, clear compliance.

Challenge: Higher initial investment.

Part Four: Comprehensive Compliance and Logistics Solutions

1. Four-Step Implementation Framework

Step 1: Regulatory Benchmarking Analysis (1-2 months)

Identify applicable UK regulations for the product

Compare differences between UKCA and existing CE certification

Assess clearance splitting needs and frequency

Step 2: Certification System Conversion (2-4 months)

Select a UKAS accredited certification body

Update technical documents and test reports

Appoint an authorized representative in the UK

Step 3: Logistics Process Reengineering (1-3 months)

Select a logistics partner familiar with UK and EU customs clearance

Design clearance splitting operation procedures

Establish a dual document management system

Step 4: Continuous Compliance Management (Ongoing)

Monitor updates to UK standards

Regularly audit the performance of authorized representatives

Attend UK trade compliance training

2. Cost Optimization Strategies

Certification Cost Sharing: Negotiate with UK importers to share UKCA certification fees

Tariff Optimization: Fully utilize the UK Global Tariff Schedule (categories with tariffs lower than the original EU Common Tariff)

Logistics Integration: Consolidate UK and Northern Ireland orders to optimize clearance splitting efficiency

Digital Tools: Adopt customs declaration software to reduce human error and delays

3. Risk Response Measures
   Transition Management: Monitor changes in transitional arrangements for UKCA certification and border checks.

Political Risk Monitoring: Further adjustments may be needed to the implementation of the Northern Ireland Protocol.

Maintaining Dual Certification: Maintaining both UKCA and CE certification capabilities for the foreseeable future is necessary.

Contingency Plans: Establishing alternative routes in case of port congestion or border disruptions in the UK.

Conclusion: Building Resilient Supply Chains in a Fragmented Market

Post-Brexit UK Steel Trade Exhibits Three Key Characteristics:

Dual Compliance: Parallel UKCA and CE Certifications, with Gradually Diverging Technical Standards

Border Complexity: Physical… While administrative boundaries truly exist, customs clearance splitting has become the norm.

Market Uniqueness: While maintaining connections with Europe, the UK is building an independent trade policy system.

Successful companies will adopt a strategy of “dual capabilities, flexible allocation, and deep local cultivation”:

Investing in building independent UK compliance and logistics capabilities

Choosing the optimal supply chain model based on product characteristics and customer distribution

Establishing deep relationships with local UK partners (certification bodies, logistics providers, distributors)

Ultimately, exporting to the UK is no longer a simple extension of exporting to Europe, but a new market segment requiring specialized strategies, resources, and knowledge. Companies that can systematically address the challenges of UKCA certification and customs clearance splitting will not only gain a competitive advantage in the UK market but also accumulate valuable experience in navigating the fragmentation of the global trade system.