Post Brexit & Product Conformity

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Brexit & the New UKCA Mark  – Extract from .gov website

Published 1st September 2020

“The UK has left the EU, and the transition period after Brexit comes to an end this year.

Businesses are encouraged to be ready for full implementation of the new UK regime as soon as possible after 1 January 2021. However, to allow businesses time to adjust, CE marked goods in scope of this guidance that meet EU requirements (where these match UK requirements) can continue to be placed on the GB market until 1 January 2022 where EU and UK requirements remain the same. This includes goods which have been assessed by an EU recognised notified body.

The UKCA (UK Conformity Assessed) marking is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking and will apply to most goods currently subject to the CE marking.  Where mandatory third-party conformity assessment was required for CE marked goods, it will also be required for UKCA marked goods.

Both the CE and UKCA mark can be placed on a product so long as neither impedes the visibility of the other and requirements of both the GB and EU legislation are met.

From 1 January 2021 the technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – will be largely the same as they are now. That means that if your goods are currently made to the technical requirements necessary for CE marking then it will be made to the same technical requirements that will exist for UKCA marking from 1 January 2021. However, the conformity assessment bodies that test them may need to be different. The conformity assessment will need to be carried out by a UK-recognised approved body in order to be marked with the UKCA marking. The type of conformity assessment procedures will be the same that were required for the CE marking.

The UKCA marking will not be recognised on the EU market. Products currently requiring a CE marking will still need a CE marking for sale in the EU from 1 January 2021. From 1 January 2022, the CE marking will not be recognised in Great Britain for areas covered by this guidance and the UKCA marking. However, a product bearing the CE marking would still be valid for sale in the UK so long as it was also UKCA marked and complied with the relevant UK rules. So, for existing stock, if your good was fully manufactured and ready to place on the market before 1 January 2021, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body”.

For more information, please refer to the following links:

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