Standards and Conformity Assessment status
Updated 6 January 2020
CE marking arrangements for Northern Ireland clarified.
“The Northern Ireland Protocol came into force on 1 January 2021. For as long as it is in force, Northern Ireland will align with all relevant EU rules relating to the placing on the market of manufactured goods. You must show that your products meet those rules by using ‘conformity markings.’
“The UKNI marking is a new conformity marking for products placed on the market in Northern Ireland which have undergone mandatory third-party conformity assessment by a body based in the UK. This guidance explains how to use the UKNI marking (sometimes referred to as the UK(NI) mark or the UK(NI) indication).”
Mutual recognition of professional qualifications
This topic has not been included in the UK-EU trade agreement although a mechanism has been put into place considered through a UK-EU Partnership Council for profession-specific arrangements.
Standards and Conformity Assessment status
UK National Standards Body status
The British Standards Institute (BSI) has updates on its continued involvement with European organisations and the potential impact. This includes the European Committee for Standardization (CEN), European Committee for Electrotechnical Standardization (CENLEC) and the European Telecommunications Standards Institute (ETSI).
UK National Accreditation Body status
The United Kingdom Accreditation Service (UKAS) also has dedicated Brexit updates on its ongoing relationship with European Accreditation (EA) and what this means for notified bodies and product conformity. UKAS will maintain its role as the UK’s appointed accreditation body.
Goods and third-party assessment in the EU market
The UK government has also produced guidance on: Conformity assessment bodies: change of status from 1 January 2021.
All other forms of accredited conformity assessment operating under UKAS’s membership of IAF and ILAC will continue to be accepted in the EU and globally as usual. However, UK conformity assessment bodies will no longer be able to carry out mandatory* conformity assessment for products being placed on the EU market unless agreed in negotiations.
*This relates to:
- Notified bodies offering CE mark assessment
- Recognised third-party organisations (RTPO)
- User inspectorates (UI)
- Technical assessment bodies (TAB)
Most UK-based conformity assessment bodies carrying out EU mandatory conformity assessment have arrangements in place to continue offering this under non-UKAS accreditation.
Manufactured goods and the UK market – CE vs the UKCA marks
The UK government has issued guidance: Placing manufactured goods on the market in Great Britain from 1 January 2021. The guidance states that: “You need to use a conformity mark if you’re placing certain goods on the UK market. Before 1 January 2021, you can do this using the CE mark or another appropriate mark. From 1 January 2021, the UK Conformity assessed (UKCA) mark will be the conformity assessment marking for Great Britain for most goods currently subject to CE marking.” This means that:
- Relevant products placed in the UK market will require the UKCA mark, although the UK government will accept both CE and UKCA during 2021 to allow for the transition
- The arrangements for Northern Ireland are different and include the new UKNI marking for placing goods into that market
- The UKCA mark will not be recognised in the EU
- The UKCA mark will mirror the CE mark rules
- Products currently requiring a CE marking for sale in the EU will continue to need a CE mark
- Authorised representatives and responsible persons based in the EU will no longer be recognised in Great Britain from 1 January 2021. If you need to use an authorised representative or responsible person, they will need to be based in the UK for products being placed on the GB market
UK services in the EU
The services sector appears to have had much less consideration. This may be because the weight of EU legislation revolves around goods.
The UK Department for International Trade has published guidance on Selling services to the EU, Switzerland, Norway, Iceland and Liechtenstein from 1 January 2021.
Mutual Recognition of professional qualifications.
The UK government guidance below states that, “You’ll need to have your UK professional qualification officially recognised if you want to work in a profession that is regulated in the EU, Switzerland, Norway, Iceland and Liechtenstein. It will need to be recognised by the appropriate regulator for your profession in each country where you intend to work. You’ll need to do this even if you’re providing temporary or occasional professional services.”
- Recognition of EU qualifications in the UK
- Recognition of UK qualifications in the EU, however the EU-UK trade deal only goes as far as to put in place the arrangements for how mutual recognition of qualification will be approached as at 1 January 2021. This will be managed through a “UK-EU Partnership Council for profession-specific arrangements”
The UK Government has a number of country guides in the Selling services to the EU, Switzerland, Norway, Iceland and Liechtenstein from 1 January 2021 section of its website.
Trading with the UK as an overseas exporter
The UK Department for International Trade has published Information for international businesses bringing goods into the UK.
Importing goods from the EU to the UK
Businesses in Great Britain need to follow a new process to continue importing from EU countries from 1 January 2021.