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The recently signed chapter (Technical Barriers to Trade) of the UK-EU trade agreement is designed to ensure that the respective regulatory schemes will not create unnecessary obstacles to trade for exporters. However, no agreement was reached on the UK’s proposal for a Mutual Recognition Agreement (MRA) on conformity assessment. Without an MRA, UK Conformity Assessment Bodies (CABs) are no longer recognized as competent to perform conformity assessments against EU regulatory requirements for the CE marking of products to be placed on the EU market and vice versa.
Transitional arrangements mean that, in most cases, the CE marking and the reversed epsilon marking will be valid in the UK market until 31 December 2024. However, the majority of goods currently subject to CE marking will be required to meet GB requirements when placed on the market as from 31 December 2024.
It was full steam ahead for UK and EU exporters and importers before Brexit. However, a barrage of regulations and red tape have made imports and exports into and out of the UK an obstacle course. EORI numbers, entry and exit summary declarations, temporary storage declarations… The list seems endless. But never fear! CPSL’s linguistic services, document management know-how, and regulatory affairs experience will reduce your trade tariffs while maximizing compliance.
UK Conformity Assessed (UKCA)
Currently in the EU, approximately 70% of all products sold must have the CE mark. Fortunately, the CE marking obtained in one EU country is valid in all other EU and EFTA countries. But when it comes to the UK, everything changed with the introduction of UK Conformity Assessed marking (UKCA) and other requirements. The UK-only goods marking (UKCA) was originally due to take effect on 1 January 2021. It applies to goods that previously required the CE marking to be placed on the market in Great Britain (England, Wales, and Scotland, and their associated islands). These are also known as ‘new approach’ goods.
Under the EU-UK Trade Agreement and within the British Isles, UK-only goods marking (UKCA) is insufficient for goods placed on the Northern Ireland market, where CE marking is required to demonstrate conformity with the relevant technical requirements. Furthermore, there are different rules for goods regulated under the old approach, for goods covered by national rules, and for medical devices and civil explosives.
If the conformity assessment procedures for a product have not been completed and a supporting CE certificate is not issued before 31 December 2024, then that product is considered to be “new”. This also includes goods that have undergone major changes, such as modifying how they work or changing their purpose or type, therefore requiring new certification. Any “new” good must comply with GB regulatory requirements, including the requirement for conformity assessment by a UK-approved body as from 31 December 2024.
The retesting measure is applicable to all module types for the following regulations:
- Noise Emission in the Environment by Equipment for Outdoor Use Regulations 2001.
- Supply of Machinery (Safety) Regulations 2008.
- Ecodesign for Energy-Related Products Regulations 2010 (with respect to boilers in accordance with Article 4 of Commission Regulation (EU) No. 813/2013).
- Toys (Safety) Regulations 2011.
- Explosives Regulations 2014.
- Pyrotechnic Articles (Safety) Regulations 2015.
- Electromagnetic Compatibility Regulations 2016.
- Simple Pressure Vessels (Safety) Regulations 2016.
- Lifts (Elevator) Regulations 2016.
- Pressure Equipment (Safety) Regulations 2016.
- Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016.
- Non-automatic Weighing Instruments Regulations 2016.
- Measuring Instruments Regulations 2016.
- Recreational Craft Regulations 2017.
- Radio Equipment Regulations 2017.
- Regulation (EU) 2016/425 on personal protective equipment, as it applies in Great Britain.
- Regulation (EU) 2016/426 on gas appliances, as it applies in Great Britain.
Language requirements for importing and exporting goods
The UK government provides up-to-date information for all kinds of businesses wanting to import and export goods into and out of the United Kingdom at https://www.gov.uk/topic/business-tax/import-export. The website has a section entitled notices, forms, and manuals, where it provides forms for import and export; excise notices: storing and moving goods; tariff notices; tariff quota notices; tariff stop press notices; and customs information papers. If you are searching for specific information on importing and exporting medical devices into and out of the United Kingdom, click here.
CPSL has an international team of linguists specialized in sectors and industries that require specific assistance with Brexit-related formalities, including the recently announced rules governing aerosols previously labelled with the reverse epsilon that entered into force on 1 January 2023.
Whether you need to adapt your existing documentation and labels or you are just getting started in the exciting world of importing and exporting within or outside of the EU, the team at CPSL is ready to be your invaluable partner, steering you through the minefield of international trade restrictions with seamless multilingual communication and expertise.
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