The UK now has its own UKCA (UK Conformity Assessed) marking regime. In practice, CE marking is still accepted for most products through at least mid-2025 as the transition period keeps being extended — but the long-term direction is UKCA. For an LED downlight, you need: electrical safety (UKCA/CE per the UK's version of LVD), electromagnetic compatibility (EMC), and RoHS compliance (the UK's version mirrors the EU directive). The UK also has its own energy label and product database, separate from the EU's EPREL system.
The practical difference: if you previously relied on a CE Technical File held by an EU-based entity, that entity may not be recognized for UKCA purposes — you need a UK-based "authorized representative" or your own UK entity. If you're selling into both the EU and UK, expect to maintain two sets of compliance documentation, two sets of energy label registrations, and two sets of WEEE-equivalent recycling registrations. It's duplicate paperwork, not different safety standards. We provide the documentation for both regimes when you tell us both destinations.
Northern Ireland has separate rules under the Windsor Framework — if your goods might end up there, talk to a UK compliance specialist.