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Post Brexit and Standards

3rd February 2020

The UK left the European Union, single market and customs union on 31 January 2020.

There is a transition period where not much will change, expiring in December 2020, however British business should be prepared as some regulatory requirements will cease to be mirrored between UK and Europe.

I am often asked about the ISO Standards and how the UK will be affected; put simply there will be no change in application or compliance.

The main Standards are marked to ensure International acceptance: e.g BS EN ISO 9001:2015Where BS means that the Standard is adopted as a British Standard

  • EN means that it is adopted as a European Standard
  • ISO means that it is adopted as an International Standard

We will continue to have Certification Bodies in the UK accredited by UKAS (United Kingdom Accreditation Service).

The one area that will change is the CE marking of products. There will be a transition period but in the long-term products sold in the UK will need to be certified to the UKCA (UK Conformity Assessed) Marking standard.

However, products destined for European markets will still need to be CE marked as Europe will not accept the UKCA mark. It is likely that as the CE and UKCA requirements will be the same, most products destined for UK and EU markets will need to be dual marked UKCA & CE.

The following rules will apply:

  • UKCA markings must only be placed on a product by the manufacturer or authorised representative;
  • When attaching the UKCA marking the manufacturer takes full responsibility for the products conformity with the requirements of the relevant legislation;
  • The UKCA marking must only be used to show product conformity with the relevant UK legislation;
  • Any UKCA marking must not misconstrue the meaning or form of the mark to third parties;
  • No other markings may be attached which affect the visibility, legibility or meaning of the UKCA marking;
  • The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation.

The Government will clarify the situation in due course.

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