EU / Great Britain | General Product Conformity

Brexit – what’s next?

A new European Commission’s Communication summarizes the main changes after the Brexit transition period on 1 January 2021 – unfortunately, there are still many unknowns.

Recently, the European Commission published its Communication entitled “Getting ready for changes – Communication on readiness at the end of the transition period between the European Union and the United Kingdom”, in which it described the main changes in the EU-UK relations which will take place starting from 2021. The document covers the impact of the Brexit on different sectors and helps businesses to prepare for it. However, the negotiation process is still ongoing and before it is closed, the business uncertainty will remain significant.

The Communication concerns topics such as trade in goods, trade in services, energy, travelling and tourism, mobility and social security coordination, company law and civil law or data, digital and intellectual property rights.

Regarding product certifications and labelling, as of 1 January 2021, the Union and the United Kingdom will be two separate regulatory and legal spaces. This means that all products exported from the Union to the United Kingdom will have to comply with UK rules and standards and will be subject to any applicable regulatory compliance checks and controls on imports. This means that, for example, the new British UKCA conformity label will most probably be required along with the CE label for imported products.

Moreover, if no agreement is reached, where Union legislation requires certification by an EU Notified Body (e.g. for some medical devices, machinery, personal protective equipment or construction products), products certified by EU-based bodies will no longer be allowed to be placed on the UK market without an additional UK certification.

Unfortunately, there is still a lack of detail from the UK government regarding the UK’s post-transition replacement of the ‘CE Mark‘. Manufacturers are worried they will not have enough time to complete the administration required to get the new UKCA mark if they have to wait for this decision to be made till the end of the EU-UK negotiations.

The full text of the European Commission’s Communication on Brexit is available under the following link.

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