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CE vs UL vs ETL vs GS vs UKCA: Kitchen Appliance Marks

Updated 2026-11-09

Quick answer

CE, UKCA, UL, ETL and GS are not interchangeable. CE and UKCA are self-declared market-access marks backed by tests to EN/BS EN 60335 standards; UL and ETL are North American safety listings by OSHA-recognised laboratories to UL 1026, UL 982 or UL 499; GS is a voluntary German mark issued by a notified body. A CE mark does not open the US, and a UL listing does not replace CE or UKCA.

The short answer: five marks, three different jobs

CE, UKCA, UL, ETL and GS get compared in one sentence all the time, and that sentence is usually wrong. They do three different jobs.

Legal market access is CE for the European Union and UKCA (or CE, which Great Britain continues to recognise under the 2024 amendment regulations) for Great Britain. These are declarations by the company placing the product on the market, backed by testing to harmonised standards. No government body approves a CE file before sale.

North American safety listing is UL or ETL. These are marks of laboratories recognised by OSHA under the NRTL programme, and our guide compares how the UL and ETL listing process runs. Retailers, insurers, electrical inspectors and many customs brokers expect one.

Commercial reassurance is GS. It is a voluntary German mark issued by a notified body, and it includes factory surveillance, which neither CE nor UKCA requires.

One product can carry all of them. None of them replaces another.

Mark Region Legal status Who issues it Underlying standard (this industry)
CE EU/EEA Mandatory for market access Self-declaration, tests by any competent lab EN IEC 60335-1 + EN 60335-2-9 / -2-14 / -2-15 / -2-12
UKCA Great Britain Mandatory; CE still recognised for most goods Self-declaration, tests by any competent lab BS EN 60335 series
UL US, Canada Voluntary in law, expected by retail UL Solutions (NRTL) UL 1026, UL 982, UL 499
ETL US, Canada Voluntary in law, expected by retail Intertek (NRTL) Same UL standards
GS Germany, often DACH Voluntary TÜV, Intertek, SGS and other notified bodies EN 60335 series plus factory inspection

CE: what the file actually has to contain

A CE declaration for a kitchen appliance is a claim that the product meets every directive that applies to it. In practice that is four or five separate legal instruments, not one:

  • Low Voltage Directive 2014/35/EU for electrical safety, tested to the EN 60335 series.
  • EMC Directive 2014/30/EU for emissions and immunity, tested to the harmonised standards listed in the Official Journal.
  • RoHS Directive 2011/65/EU for restricted substances, supported by material declarations from every supplier.
  • Ecodesign Framework Regulation 2009/125/EC and, where the product has standby or networked standby, Regulation 1275/2008.
  • General Product Safety Regulation (EU) 2023/988, which also requires an EU-based responsible person for products sold to consumers.
  • For any part that touches food, Regulation (EC) 1935/2004 and, for plastics, Regulation (EU) 10/2011.

The technical file must sit with the EU responsible person and be available to market surveillance authorities on request. A supplier who can only send a certificate image, and no test report, declaration or bill-of-materials statement, is not giving you a CE file.

UKCA and the CE recognition question

Great Britain applies its own Electrical Equipment (Safety) Regulations 2016 and Electromagnetic Compatibility Regulations 2016, which mirror the EU directives. The standards are the same BS EN 60335 series, so the engineering work is the same. What changes is paperwork, the responsible person in Great Britain, and the plug, which must be BS 1363.

The UK government’s guidance on using the UKCA marking sets out which goods need the mark and how CE marking continues to be recognised. Because that policy has been extended more than once, treat it as a moving target: check the guidance before you print cartons, not after.

UL and ETL: same standards, different laboratories

UL and ETL are usually compared as if they were different levels of approval. They are not. Both are NRTL marks, and both are issued against the same ANSI/UL standards:

  • UL 1026 covers household electric cooking and food serving appliances rated 250 V or less, and its scope explicitly refers to toasters and similar appliances. Air fryers, contact grills, toasters and egg cookers are evaluated under this family.
  • UL 982 covers motor-operated household food preparing machines: blenders, food mixers, food processors, can openers, knife sharpeners. Its scope is limited to short-time appliances with cumulative use under 100 hours a year, and it is written around a nominal 120 V supply.
  • UL 499 covers electric heating appliances rated 600 V or less, which is the family used for warming products such as cup warmers and hand warmers where no more specific standard applies.

The practical difference between UL and ETL is commercial, not technical: which laboratory a given retail buyer already has in its supplier system, and whether the factory already holds a listing that can be extended to your model.

Two US points are separate from safety listing. Digital controls with a switching power supply normally need FCC equipment authorisation as an unintentional radiator. Any part in contact with food must use materials acceptable under FDA regulations in 21 CFR Parts 170–199.

GS: the German retail key

GS is issued under the German Product Safety Act by notified bodies. It is voluntary, and it is not a substitute for CE: a GS certificate is normally issued on top of CE compliance. It adds two things that CE does not: an annual factory inspection, and a public certificate number that a retail buyer can check.

In this industry GS is asked for most often by German and Austrian retail and by some marketplaces. If your channel does not ask for it, CE plus a good EN 60335 report is the normal baseline.

What each market asks for, in one table

Market Legal mark Standard family Who tests What the importer must hold
EU CE EN 60335-1 + part 2 Any competent lab; notified body only for specific cases Declaration of conformity, test reports, technical file, EU responsible person
Great Britain UKCA or CE BS EN 60335 series Any competent lab UK declaration, technical file, UK responsible person, BS 1363 plug
United States None by law; UL/ETL listing expected UL 1026 / UL 982 / UL 499 UL Solutions or Intertek (NRTL) Listing report, FCC authorisation for digital controls, FDA-compliant food contact materials
Canada cUL or ETL-C CSA C22.2 series, UL standards UL, Intertek, CSA Canadian listing, bilingual labelling
Australia/NZ RCM AS/NZS 60335 series Accredited body; EESS registration EESS registration, certificate of conformity for declared articles
Saudi Arabia SABER / SASO IEC 60335 with national differences IECEE-recognised labs Product certificate of conformity on SABER
Japan PSE (DENAN) IEC 60335 with JIS differences Registered conformity assessment body PSE mark and notification to METI
Korea KC KC 60335 series KTC, KTL, KTR KC certificate and registration

How a factory prepares several markets from one design

The efficient route is one core design tested once, then extended. Four habits make that work:

  1. Design to IEC 60335-1 plus the correct part 2 from day one. Air fryers, contact grills and toasters sit in part 2-9; stand mixers and blenders in part 2-14; egg cookers and milk heaters in part 2-15; cup warmers in part 2-12. Choosing the wrong part 2 is the most common cause of a wasted test programme.
  2. Run a CB Scheme project first. An IECEE CB report is accepted as input by certification bodies in most markets, which reduces repeat testing for the US, Australia, Saudi Arabia and Japan.
  3. Freeze the bill of materials before testing. A different heating element, thermostat, motor, PCB or enclosure plastic is a technical change, and most labs will treat it as a new evaluation.
  4. Fix the plug and voltage variants at the drawing stage. One 120 V version and one 220–240 V version, each with the right plug and cord set, is cheaper than retrofitting.

Documents importers should ask for, every shipment

Document What it proves Needed for
Declaration of conformity Which directives and standards were applied EU, UK
Safety test report Measured results, clause by clause All markets
Certificate with verifiable number Third-party listing or certification US, Canada, GS markets
EMC test report Emissions and immunity EU, UK, US (FCC), Australia
RoHS / REACH statements Material compliance EU, UK
Food contact declaration and migration test Materials in contact with food EU, US, and retail private label programmes
Battery test summary (UN 38.3) Cell and pack transport safety Any product with a lithium battery
Artwork and label proof Correct mark, language, importer details All markets

Why shipments get held, and how to avoid it

Most rejections in this industry are avoidable paperwork failures, not product failures:

  • The mark on the product does not match the file. A carton printed with a GS logo and no GS certificate is a recall risk for the buyer.
  • The certificate covers a different model. Buyers check model numbers. A certificate for a 1,500 W version does not cover the 1,700 W version.
  • The declaration names the wrong legal entity. The importer, not the Chinese factory, is usually the responsible economic operator in the EU and UK.
  • Labels are in the wrong language. EU appliance labelling and instructions must be in the language of the member state of sale; Canada requires English and French.
  • No EU responsible person. Since the General Product Safety Regulation applied, consumer products need one, and marketplaces ask for the name and address.
  • Food contact evidence is missing. A basket coating or blender jar without a declaration of conformity under Regulation (EC) 1935/2004 stops a private-label launch.
  • Battery products ship without UN 38.3. Lithium cells and packs need a test summary before air or sea freight.

Plug, voltage and marking details that differ

Item EU UK US Australia
Plug CEE 7/7 Schuko, CEE 7/16 Europlug BS 1363 (Type G) NEMA 5-15 AS/NZS 3112
Voltage / frequency 230 V / 50 Hz 230 V / 50 Hz 120 V / 60 Hz 230 V / 50 Hz
Rated voltage on label 220–240 V 230 V 120 V 230–240 V
Instructions language Language of the member state English English (French for Canada) English
Responsible person EU address required UK address required Importer of record Australian supplier declaration

Frequently asked questions

Is CE enough for a German retail buyer? Legally yes. Commercially, German retail often asks for GS as well, and some buyers will not list a small appliance without it. Ask the buyer before you pay for a GS project.

Can a Chinese factory issue a CE certificate? A factory can issue a declaration of conformity as the manufacturer, and it can hold test reports. A “CE certificate” issued by an unaccredited body has no standing with market surveillance. What matters is the test report, the standards cited and the technical file, and our test report checklist shows how importers verify each one.

Does UL listing expire? A listing stays valid while the product and factory remain under the laboratory’s follow-up inspection programme. If production moves to another factory, the listing normally has to be transferred or re-issued.

Do I need a new certificate for a new colour? Usually not, if only the colour of the housing changes and the material and electrical construction stay the same. Changing material, adding a window, or changing the control board normally does.

Is a test report from a Chinese lab accepted in the EU? Yes, if the lab is competent and the report cites the correct EN standards and clauses. Market surveillance looks at the technical content, not the flag on the lab.

What about a product with a lithium battery, like a portable blender or a hand warmer? Three layers apply: safety of the appliance, safety of the cell and pack (IEC 62133-2 is the usual reference), and transport (UN 38.3 plus the applicable packing instruction). Under the EU Batteries Regulation (EU) 2023/1542, additional marking and due-diligence duties also apply.

Which mark should a new brand buy first? Match the first market you will actually ship to. A brand launching on Amazon.com should budget for a US listing and FCC first; a brand launching in Germany should budget for CE, an EU responsible person and, if retail asks, GS.

Where to go next

Ask us for model-specific data, including which standards a given model has already been tested to, through /contact/.

Frequently asked questions

Is a CE certificate accepted in the United States?

No. The US has no CE-style system. Retailers, insurers and customs brokers expect a listing mark from an OSHA Nationally Recognized Testing Laboratory, such as UL or ETL (Intertek), to a US standard such as UL 1026 for cooking appliances or UL 982 for motor-driven kitchen machines. A CE declaration and an EN 60335 test report are useful technical evidence, but they do not satisfy a US retailer's compliance team.

Is ETL as good as UL?

For US market access, yes. ETL is the listing mark of Intertek, which is recognised by OSHA under the NRTL programme, the same programme that recognises UL. Both marks show the product was tested to the same ANSI/UL standard, for example UL 1026, and both are accepted by inspectors and by most retailers. The practical difference is commercial: some retail buyers have a preferred laboratory, and some factories hold one listing rather than both.

Do I need GS if I already have CE?

Not legally. GS is a voluntary German mark, so CE alone is enough to place a product on the EU market. GS matters commercially: German and Austrian retail buyers, and some marketplaces, ask for it, and a GS certificate from a notified body such as TÜV or Intertek also covers the factory inspection that CE does not require. Budget for GS only when a specific retail channel asks for it.

Can one test report cover CE and UKCA?

Often yes in substance, but not automatically in paperwork. Great Britain applies the same BS EN 60335 standards as the EU, and the UK government continues to recognise CE marking for most goods. That means a CE file with EN 60335 test reports usually supports a UKCA declaration too. The declaration of conformity, the responsible person in Great Britain and the label wording still have to be UK-specific, and the plug must be BS 1363.

What is the difference between a certificate and a test report?

A test report records what a laboratory measured. A certificate is issued by a certification body that also operates a factory surveillance or follow-up service, and it carries a number that buyers can verify in the body's online database. Retail buyers usually want the certificate and the right to check it, not only a PDF report. Always verify a certificate number on the issuing body's website before you accept it.

Does a CB report replace national certification?

No, but it shortens the work. An IECEE CB Scheme report and certificate, based on IEC 60335-1 plus the relevant part 2, is accepted as input by certification bodies in most countries. They still review national differences and issue their own mark. A CB report is the cheapest way to prepare several markets from one test programme.

Which mark do I need for Amazon or a European marketplace?

Marketplaces ask for the legal mark first: CE for the EU, UKCA or CE for Great Britain, and a US listing for Amazon.com. They also ask for the test report behind it and, for EU sales, an EU responsible person under the General Product Safety Regulation. A GS certificate is a commercial advantage in Germany, not a platform requirement.

How long does certification take?

Timelines come from the laboratory, not from a public table. A single-market safety file for one model is usually quoted in weeks, and multi-market projects take longer because each market reviews national differences. Battery products add UN 38.3 transport testing, and any change to the heating element, motor, PCB or enclosure material after testing normally requires a re-test or an extension.

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