United Kingdom (GB) - Smart home product
UKCA and compliance requirements for smart home product
Home automation devices with a wireless link and app or hub connectivity. Treated as radio equipment with connected-product cybersecurity duties on top of the usual substance and take-back rules.
For example: smart plug, smart thermostat, video doorbell, smart bulb.
As radio equipment, the EU RED (and UK Radio Equipment Regulations 2017) covers safety and EMC objectives, so LVD/EMC are not listed separately — this includes mains-voltage products like smart plugs. Products wired into fixed installations (in-wall switches) may additionally engage national wiring rules — verify. Devices with cameras or microphones raise GDPR/UK GDPR privacy obligations, and voice assistants with AI features may have EU AI Act transparency duties — both beyond this dataset, verify for your product. RED cybersecurity delegated regulation applies since 1 August 2025; CRA applies in full from 11 December 2027.
Base requirements5 instruments
The UK's consumer connectable ('smart') product security regime, in force since 29 April 2024. Manufacturers must meet three security requirements (no universal default or easily guessable passwords, publish how to report security issues, publish the minimum security update support period) and products must be accompanied by a statement of compliance.
Key obligations
- 01Passwords must be unique per product or defined by the user of the product (banning universal default and easily guessable passwords) - security requirement in Schedule 1 to SI 2023/1007.source
- 02Manufacturers must publish at least one point of contact to allow a person to report security issues, with information on when the reporter will receive acknowledgement and status updates (vulnerability disclosure policy).source
- 03Manufacturers must publish the defined support period - the minimum length of time security updates will be provided, with an end date - and the information must be accessible, clear and transparent.source
- 04Products must be accompanied by a statement of compliance (which may be digital); manufacturers, importers and distributors each have duties in relation to it, and manufacturers (regulation 8) and importers (regulation 9) must retain it.source
The general safety net for consumer products in Great Britain: no producer may place a product on the market unless it is safe, and producers and distributors must monitor products and notify authorities about unsafe ones. In Northern Ireland these Regulations were superseded on 13 December 2024 by the EU General Product Safety Regulation (EU) 2023/988.
Key obligations
- 01No producer shall place a product on the market unless the product is a safe product (regulation 5) - one which under normal or reasonably foreseeable conditions of use presents no risk, or only the minimum risk compatible with the product's use.source
- 02Producers must provide consumers with the relevant information to enable them to assess the risks and take precautions, and enable traceability by indicating the producer's name and address on the product or its packaging.source
- 03Producers must monitor marketed products: sample-test them, investigate and where necessary keep a register of complaints, and keep distributors informed of the results.source
- 04Distributors must act with due care to help ensure only safe products are supplied and must not supply products that, as a professional, they know or ought to know to be dangerous (regulation 8).source
The GB law for products that intentionally transmit or receive radio waves (Wi-Fi, Bluetooth, cellular and other wireless products). Radio equipment must meet three essential requirements — safety, electromagnetic compatibility and efficient use of the radio spectrum — before being placed on the GB market with UKCA or CE marking.
Key obligations
- 01Design and manufacture radio equipment to ensure a high level of safety (health and safety of persons and domestic animals, and the protection of property).source
- 02Ensure an adequate level of electromagnetic compatibility.source
- 03Ensure the equipment operates in a manner that promotes efficient use of the radio spectrum.source
- 04Carry out a conformity assessment procedure, draw up a declaration of conformity (retained for 10 years from market placement and provided to enforcement authorities on request), and affix the UKCA or CE marking.source
Restricts ten hazardous substances (including lead, mercury, cadmium and four phthalates) in electrical and electronic equipment placed on the Great Britain market. Manufacturers must self-assess, draw up a declaration of conformity and technical documentation, and affix the UK marking.
Key obligations
- 01EEE placed on the market must not contain the substances listed in Schedule A1 above the maximum concentration value by weight in homogeneous materials: 0.1% for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP, and 0.01% for cadmium.source
- 02Manufacturers must carry out the internal production control procedure and draw up technical documentation demonstrating compliance.source
- 03Manufacturers must draw up a declaration of conformity stating that the requirements have been met in relation to the EEE.source
- 04The UK marking must be affixed visibly, legibly and indelibly to the EEE (or to its packaging or accompanying documents where that is not possible).source
UKCA is Great Britain's product conformity marking, introduced after EU exit for goods that previously used CE marking. Since 1 October 2024, CE marking is also recognised in Great Britain with no end date for most goods covered by the framework, so businesses can generally use either marking.
Key obligations
- 01Before placing a product in scope of the regime on the GB market, carry out the conformity assessment required by the relevant product regulation and affix the UKCA marking — or the CE marking, which businesses have the flexibility to use in place of UKCA under the continued recognition policy.source
- 02Draw up a UK declaration of conformity and maintain technical documentation (technical files and test reports) demonstrating compliance.source
- 03Apply the UKCA marking in its standard, recognisable form, at least 5mm in height (unless a different minimum dimension is specified in the relevant legislation), and ensure it is easily visible, legible and indelible.source
- 04Until 11pm on 31 December 2027, the UKCA marking may alternatively be placed on a label affixed to the product or on a document accompanying the product (certain sectors such as marine, medical devices, rail and construction products have their own specific rules).source
If your product also...
Extra regulations triggered by specific features
Intended for or marketed to children (under 14)
Documents you will need
Deduplicated across the regulations above
- Statement of complianceMinimum information set by Schedule 4 to SI 2023/1007 (product details, manufacturer information, defined support period, signatory details). Must accompany the product (can be digital); manufacturers and importers must retain it.source
- Compliance recordsManufacturers have a duty to maintain records and to investigate potential compliance failures under Part 1 Chapter 2 of the Act.source
- Traceability and monitoring recordsNo declaration of conformity or technical file is required. Producers should be able to evidence traceability (name and address on product or packaging), sample testing, complaint investigation and, where necessary, a complaints register.source
- Declaration of conformityMust identify the specific product and include manufacturer name/address (and authorised representative where applicable); retained for 10 years from market placement and made available to enforcement authorities on request. Format set out in Schedules 6 and 7 (a simplified form is provided for).source
- Technical documentationEvidence that the equipment meets the three essential requirements, including the conformity assessment records.source
- Instructions and usage informationInstructions and safety information in easily understandable English, including frequency bands, transmit power and any restrictions on putting into service.source
- UK Declaration of ConformityMust be drawn up by the manufacturer stating the requirements have been met; a model template is available for download from the GOV.UK RoHS guidance page.source
Frequently asked
Does PSTI require UKCA marking?+
No. There is no conformity marking under the PSTI product security regime. Instead, every relevant connectable product must be accompanied by a statement of compliance, which can be a digital document.
Does GPSR 2005 require UKCA marking or a declaration of conformity?+
No. It is a general safety-net regulation with no conformity marking, declaration of conformity or technical file. Your obligations are that the product is safe, that consumers get the information they need, that you can trace products (name and address on the product or packaging), and that you monitor and notify.
My product has Wi-Fi or Bluetooth — which UK regulations apply?+
The Radio Equipment Regulations 2017 apply to anything that intentionally transmits or receives radio waves, and they carry their own safety and EMC essential requirements. Radio equipment in scope is generally excluded from the Electrical Equipment (Safety) Regulations 2016, so the RER is usually your primary regime (RoHS and other laws can still apply in parallel).
Which substances does UK RoHS restrict?+
Ten substances, listed in Schedule A1: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates (DEHP, BBP, DBP, DIBP). The limit is 0.1% by weight in homogeneous materials for each, except cadmium at 0.01%.
My product is CE marked — do I also need UKCA to sell in Great Britain?+
For most goods covered by the UKCA/CE regime (electrical, EMC, radio, toys, machinery and similar), no. Since 1 October 2024 the government recognises CE marking for the GB market with no end date, so you can use CE, UKCA, or both. Check your specific product area though — sectors like medical devices, construction products, marine, rail and unmanned aircraft have separate arrangements.
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