Product Certification and CE Marking landscape in the event of a no-deal Brexit on 31st October
This note details what happens to the Product Certification and CE Marking landscape in the event of a no-deal Brexit on 31st October, and what impact this has on the ability for Pyroguard to place UK-manufactured products on the market.
UK market
The UKCA (UK Conformity Assessed) marking is the new UK product marking that will be used, subject to parliamentary approval, for certain goods being placed on the UK market if we leave the EU without a deal. However, goods legitimately affixed with CE marking already on the UK market before the UK leaves the EU will be able to continue to circulate in the UK. Additionally, goods which are made and assessed against EU harmonised standards and legitimately carry the CE marking can continue to be placed on the UK market. It is intended that these arrangements will be for a time-limited period, but the UK Government’s draft legislation itself does not limit the duration of this provision. Products being placed on the UK market in this way must be compliant with the obligations of the EU’s Construction Products Regulation.
Conclusion: A no-deal Brexit will not affect Pyroguard’s ability to sell any of its manufactured products in the UK market. Pyroguard will adopt the UKCA mark should this become necessary in due course in order to ensure continuing supply of conforming product.
EU Market
After exit day, the European Commission will no longer recognise CE certificates from UK notified bodies. Therefore, for placing products on the EU market after exit day manufacturers will either need to:
- undertake the necessary conformity assessment activity with an EU-recognised notified body or
- arrange for the transfer of the certificate (and associated files) from a UK notified body to an EU-recognised notified body
Pyroguard have taken steps such that all conformity assessment activities are already with EU-based notified bodies.
Conclusion: A no-deal Brexit will neither affect Pyroguard’s ability to legitimately CE Mark its products manufactured in the UK, nor its ability to sell its products in the EU market.
More guidance can be found on the UK Government’s website here.
Dr Richard Ainsworth
Group Technical Director