Great Britain | General Product Conformity

Product conformity and vehicle regulations after Brexit

What are the main provisions of the EU-UK Trade and Cooperation Agreement with regard to product conformity and vehicle regulations?

Fortunately, the EU and UK managed to reach a last-minute agreement before Christmas and an orderly Brexit was ensured.  Unfortunately, contrary to what some hoped, CE will not be accepted in UK in the future anymore and products will have to bear a special UKCA conformity mark.  On the other hand, at least, Great Britain made a commitment to further accept the UNECE regulations for vehicles and their parts.

The UKCA product conformity system that we described in one of our previous insights (see link) has come true.  It will become mandatory for the CE-products after the end of the transition period after 31 December 2021.  Until then, CE-labelled products can be still be imported and sold, if several specific conditions are met (e.g. if they have been placed on the market before 1 January 2021).

As far as vehicles and their parts are concerned, this issue was raised in the Annex TBT-1: Motor Vehicles and Equipment and Parts Thereof of the EU-UK Trade and Cooperation Agreement.  Basically, the Parties recognised that the WP.29 is the relevant international standardising body and that UN Regulations and GTRs under the 1958 Agreement and 1998 Agreement are relevant international standards for the products covered.

Each Party shall accept on its market products which are covered by a valid UN type approval certificate as compliant with its domestic technical regulations, markings and conformity assessment procedures, without requiring any further testing or marking to verify or attest compliance with any requirement covered by the UN type approval certificate concerned.

For further information and guidance about the product conformity and vehicle regulations after Brexit please do not hesitate to contact us.


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