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Brexit: update on requirements

Brexit: update on requirements
CECE Europe
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Brexit: update on requirements

On 17th September the CECE Technical Commission met to discuss the regulatory files where special focus on Brexit requirements was made by CECE member CEA. Below you can find the summary of the main concerns.

The UK government recently published revised guidance covering the placing of manufactured goods on the Great Britain (GB) market. These requirements will come into force once the current transition period ends on 31st December 2020. In the meantime, EU and UK negotiators continue to develop a free trade agreement (FTA). If the FTA is ratified it might supersede some of the new guidance. One point of major note is that regardless of whether or not an FTA is agreed, the Northern Ireland Protocol will come into force on 1st January 2021, resulting in the Northern Ireland market generally being treated as if it was still in the EU Single Market. Therefore, from a goods regulatory perspective, once the current transition period ends, the UK market will effectively be split into the GB market (comprising England, Scotland and Wales) and the Northern Ireland market.

One of the most noteworthy announcements in the recent guidance is that the UK has offered a grace period during which products that are currently CE marked and have either been self-assessed or, where mandatory third-party conformity assessment is required, assessed by an EU recognised notified body, they can continue to be placed on the GB market through until 31st December 2021. This new guidance supersedes previous advice that indicated products would require to be UKCA marked, with any mandatory conformity assessments being performed by a UK-based notified body, by the much earlier date of 1st January 2021. However, it should be noted that this grace period will end on 1st January 2022, meaning that products must be UKCA marked and fully compliant with all aspects of UK law thereafter.

A similar situation exists for the acceptance in GB for the approvals of engines installed in non-road mobile machinery (NRMM). The new guidance advises that UK will continue to accept NRMM engines being placed on the GB market through 2021 on the basis of existing valid EU approvals. It should be noted that this grace period will also end on 1st January 2022. No further information is yet available about the full UK approval scheme covering NRMM engines, which will be implemented at some point in the future.

Source: CECE