101 UK Brexit Notes

Connemara Programme October 16 2018 pg. 88 After March 2019 if there’s no deal Goods already placed on the market will be able to continue to circulate in the UK. Additionally, goods that meet EU requirements (and were tested by an EU recognised conformity assessment body) can still be placed on the UK market. This is intended to be a time-limited measure. The results of conformity assessment carried out by UK notified bodies will no longer be recognised in the EU. This means that products tested by a UK notified body will no longer be able to be placed on the EU market without retesting and re-marking by an EU recognised conformity assessment body. For the areas within scope of this notice (see Annex A), notified bodies based in the UK will be granted new UK ‘approved body’ status and listed on a new UK database. Approved bodies will be able to assess products for the UK market against UK essential requirements (which, immediately after exit day in a ‘no deal’ scenario, will be identical to EU essential requirements). Manufacturers selling goods on the UK market will then be able to affix a new UK conformity marking before placing a product on the UK market. A separate UK marking to replace the wheel mark will be in place for marine equipment. Manufacturers will not need to use these markings from the point of exit in a ‘no deal’ scenario if they have used the relevant EU marking after having their product assessed by an EU recognised body. This will be a time-limited arrangement. Details of these markings will be published later in 2018 and with sufficient time to allow businesses to prepare. The United Kingdom Accreditation Service’s role as the UK’s national accreditation body, including for most UK conformity assessment bodies, will remain as it is now. Existing harmonised standards (used to demonstrate conformity with EU essential requirements) will become UK ‘designated standards’, used to demonstrate conformity with UK essential requirements. As noted above, immediately following exit these will be identical to EU essential requirements. Implications All manufacturers intending to place products on the UK market on or after 29 March 2019 will want to consider the actions outlined below. All manufacturers placing products on the EU market will need to take the actions outlined below if they intend to place products on the EU market on or after 29 March 2019 Actions for businesses and other stakeholders Manufacturers placing products on the UK market should note:  Products that meet EU requirements can continue to be placed on the UK market without any need for retesting or re-marking, including where they have demonstrated compliance with EU requirements after exit day. This will apply for a time-limited period and sufficient notice will be given to businesses before that period ends.  Products that meet UK requirements and bear a UK conformity marking can be placed on the UK market, as long as any third-party testing required has been carried out by a UK-recognised conformity assessment body.  For product areas covered by this notice, UK-based notified bodies will become UK approved bodies after March 2019 and will be listed on a new UK database. Manufacturers placing products on the EU internal market should note:  Products which were tested by a UK-based notified body will need to be retested by an EU-recognised conformity assessment body before placing on the EU internal market (A list of EU-recognised conformity assessment bodies can be found on th e NANDO database . After March 2019, in a no deal scenario UK-based bodies will no longer be listed on this database).  Alternatively, manufacturers can seek to arrange for their files to be transferred to an EU-recognised notified body to allow for certificates of conformity issued by a UK- based notified body to continue to be valid.  In either of the scenarios above, products where third-party testing is required would need to be re-marked with the new EU-recognised notified body’s four-digit number.