Does ATEX apply outside the European Union, for example in Turkey or the UK?
Abstract
ATEX is EU law, but the equipment directive also applies in Iceland, Liechtenstein, Norway, Switzerland (by agreement) and Türkiye (Customs Union). Great Britain has its own copy, UKEX, and still accepts CE; Northern Ireland follows EU rules. Elsewhere, national schemes apply.
Only partly. ATEX is European Union law, but the equipment directive 2014/34/EU also applies in the European Economic Area countries (Iceland, Liechtenstein, Norway), in Switzerland through a mutual recognition agreement and in Türkiye through the Customs Union. Great Britain left ATEX and applies its own near-identical regulations (UKEX), while still accepting CE-marked equipment; Northern Ireland follows EU rules. Everywhere else ATEX has no legal force, and national schemes or IECEx-based approvals apply.
Short answer
- EU Member States: both directives apply through national law.
- Iceland, Liechtenstein, Norway (EEA): the European Commission's ATEX Guidelines treat these territories like EU territory for 2014/34/EU.
- Switzerland: 2014/34/EU applies through the EU-Switzerland Mutual Recognition Agreement.
- Türkiye: both directives are transposed into Turkish regulations; CE marking is used for Ex equipment under the Customs Union.
- Great Britain: the 2016 Equipment and Protective Systems Regulations (UKEX) mirror the product directive; CE or UKCA marking is accepted. The workplace side is DSEAR 2002.
- Northern Ireland: EU product rules apply under the Windsor Framework (CE, or CE plus UKNI).
- Rest of the world: ATEX is not law. Buyers may ask for it, but the legal requirement is the national scheme, which may or may not build on IECEx.
Where the ATEX equipment directive applies
The Commission's ATEX 2014/34/EU Guidelines (6th edition, January 2026) state that the directive applies in the EEA territories and in other territories with a suitable international agreement, naming Switzerland (Mutual Recognition Agreement) and Turkey (Customs Union Agreement). The same guidelines list the languages required for instructions there, for example Norwegian in Norway, French, German and Italian in Switzerland, and Turkish in Türkiye.
| Country or region | Equipment (product) rules | Workplace rules |
|---|---|---|
| EU Member States | Directive 2014/34/EU via national law | Directive 1999/92/EC via national law |
| Iceland, Liechtenstein, Norway | 2014/34/EU (EEA Agreement) | National worker safety law |
| Switzerland | 2014/34/EU via the EU-Switzerland MRA | Swiss national law |
| Türkiye | Regulation transposing 2014/34/EU, CE marking | Regulation prepared in parallel with 1999/92/EC |
| Great Britain | Equipment and Protective Systems Regulations 2016 (UKEX), CE or UKCA | DSEAR 2002 |
| Northern Ireland | EU rules under the Windsor Framework, CE or CE + UKNI | Northern Ireland legislation |
| Other countries | National scheme (often IECEx-based) | National law |
For the workplace side outside the EU, the table only names law verified for this article; check the national worker safety legislation for the other countries.
Türkiye: both directives in Turkish law
Türkiye has two separate regulations, one for each directive:
- Equipment: the regulation on equipment and protective systems intended for use in potentially explosive atmospheres (Muhtemel Patlayıcı Ortamda Kullanılan Teçhizat ve Koruyucu Sistemler ile İlgili Yönetmelik (2014/34/AB)), Official Gazette 30 June 2016, No. 29758, last amended 27 June 2020. It was prepared to align with Directive 2014/34/EU and requires the EU declaration of conformity and CE marking. The Ministry of Industry and Technology is responsible.
- Workplace: the regulation on the protection of workers from the hazards of explosive atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik), Official Gazette 30 April 2013, No. 28633, issued by the Ministry of Labour and Social Security under Occupational Health and Safety Law No. 6331, in parallel with Directive 1999/92/EC. The employer must prepare an explosion protection document before work starts.
So an exporter to Türkiye uses the same ATEX conformity assessment and CE marking as for the EU, with instructions in Turkish. The question What is the Turkish equivalent of the ATEX directives? gives the details.
United Kingdom after Brexit
The UK implemented ATEX before leaving the EU and kept those rules. In Great Britain (England, Scotland, Wales):
- Equipment: the Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016, commonly called UKEX. Requirements, categories and conformity procedures follow 2014/34/EU. UK government guidance (updated October 2026) states that the Product Safety and Metrology etc. (Amendment) Regulations 2024 extend recognition of the CE marking indefinitely. A manufacturer can therefore place equipment on the GB market with either the CE or the UKCA marking; since 1 October 2024 a UKCA marking may also rest on conformity assessment completed by an EU notified body.
- Workplace: the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), which implement 1999/92/EC. HSE enforces the 2016 Regulations.
In Northern Ireland, UK guidance states that relevant EU rules on manufactured products apply under the Windsor Framework. Equipment needs the CE marking; where a UK-based body did the mandatory third-party assessment, the product carries CE plus UKNI, and UKNI is never used alone. See Ex certification in other markets for the GB marking options.
Everywhere else: national rules, often built on IECEx
Outside these territories, an ATEX certificate or CE marking has no legal status by itself. The IECEx scheme notes that ATEX is what is legally required to sell Ex products in the EU, and that most IECEx member countries still require some processing to issue their own national mark. Typical examples are EAC under TR CU 012/2011 in the Eurasian Economic Union, INMETRO in Brazil, CCC in China, PESO in India, and NEC/CEC listings in the USA and Canada. Many buyers outside Europe write "ATEX or IECEx" into specifications; that is a contract requirement, not law. Compare the two systems in ATEX vs IECEx.
Common mistakes
- Assuming an ATEX certificate is valid worldwide. It is a legal document only where 2014/34/EU applies.
- Thinking Brexit forces UKCA on all Ex equipment. Great Britain recognises CE indefinitely; UKCA is an alternative, not a replacement.
- Forgetting the workplace side. A country can accept ATEX equipment and still have its own rules for zoning, installation and inspection.
Related on excodex
- ATEX explained: the two EU directives 2014/34/EU and 1999/92/EC in plain language
- ATEX vs IECEx: differences, similarities and which one you need
- Ex certification in other markets: UKEX, EAC, INMETRO, CCC, PESO and others
- What is the difference between ATEX and DSEAR in the UK?
- Standards spaces: UKEX, IECEx, Türkiye explosive atmosphere regulations
Standards and further reading
- European Commission, ATEX 2014/34/EU Guidelines, 6th edition (January 2026), sections on territorial application and languages: single-market-economy.ec.europa.eu
- UK Office for Product Safety and Standards, guidance on the 2016 Regulations in Great Britain: gov.uk
- UK government, using the UKNI marking: gov.uk
- HSE, ATEX and DSEAR: hse.gov.uk
- Turkish equipment regulation (2014/34/AB), Official Gazette No. 29758 of 30 June 2016: resmigazete.gov.tr; amending regulation, No. 31168 of 27 June 2020: resmigazete.gov.tr
- Turkish workplace regulation, Official Gazette No. 28633 of 30 April 2013: resmigazete.gov.tr
- IECEx, FAQ on the certified equipment scheme: iecex.com
This article is general technical information prepared by the excodex editorial team. It does not replace the applicable standards, the equipment certificates and instructions, national regulations or the assessment of a competent person.