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What companies should expect post- transition period

Prepare for after the transition period- CE, UKCA, UKNI Markings

The transition period ends on 31 December 2020. From 1 January 2021, the European Union (EU) CE marking will be replaced with UKCA or UKNI markings.

Businesses based in Great Britain (England, Scotland, and Wales) that place toys, electrical, battery-operated products, medical devices, aerosols on the GB market will have to comply with the new Approach goods.

Things we know now

Northern Ireland Protocol- At the end of the transition period, the Northern Ireland Protocol will take effect. The Protocol is a practical solution to avoid a hard border with Ireland whilst ensuring the UK, including Northern Ireland, leaves the EU, enabling the entire UK to benefit from future Free Trade Agreements. NI will still have access to the EU market after the transition period.

What will be the same from January 2021?

CE marked products already on the EU and UK markets that meet EU requirements can remain on the GB market till 1 January 2022.

What will change for GB and EU- businesses from January 2021?

Authorised Representatives - must be based in GB or NI for the GB market. GB-based Authorised Representatives will no longer be recognised in the EU. EU legislation coming into force on 16 July 2021 means you may need to appoint an EU representative if there is no other economic operator in place.

Economic operators-The responsibilities of ‘economic operators’ who deal with CE or UKCA marked goods will change from 1 January 2021. Economic operators include manufacturers, importers, distributors, and authorised representatives.

Importers - A UK-based distributor of EU goods may become an ‘importer’ – and vice-versa.​ Importers have a duty to ensure products are compliant and often must ensure their address is on a product.

Placing CE marked goods on the GB market

EU & GB- based businesses placing CE marked goods that meet EU requirements can continue to be placed on the GB market in most cases until 1 January 2022.

Placing CE marked goods on the EU market

A GB-based business must take steps to ensure compliance with EU requirements by 1 January 2021.

Marking and labelling

If you a GB-based business self-certify or use an EU Notified Body, you can still use the CE marking until 1 January 2022 for goods placed on the GB market (more in some cases). In this case, you can use your EU Declaration of Conformity until 1 January 2022.

  • The CE marking will still be required for products placed on the EU market.

  • You can place the UKCA and CE markings on the same product if it is intended to be placed on both the GB and EU markets, long as the product meets the rules for both markets.

From 1 January 2021 New Approach goods assessed against GB rules by a GB ‘Approved Body’ will need the UKCA marking. In this case, you as a GB-based business will need to use a UK Declaration of Conformity.

  • If you currently self-certify for the CE mark, you can also do so for the UKCA mark.

  • From 1 January 2021 the essential requirements and standards that can be used to demonstrate compliance to the UKCA marking will be the same as they are now for the CE marking.

The Ireland/Northern Ireland Protocol comes into force from 1 January 2021. For as long as it applies, goods placed on the market in NI will need to meet relevant EU rules.

  • The CE marking will continue to be the relevant marking for most goods. If you, a GB-based business self-certify for CE, you can continue to do this when placing goods on the NI market.

  • CE + UKNI markings are used in Northern Ireland if a UK Notified Body is assessing against EU rules. This will be the case from 1st January 2021, and it also applies to existing stock that is not already placed on the market by 31 December 2020 which has been assessed against the CE marking by a UK Notified Body.

  • CE marking is used if an EU Notified body is assessing against EU rules.

  • UKNI marking can’t not be used on its own. It always accompanies the relevant EU conformity marking.

  • UKCA alone will not be valid for the NI market.

From 1st January 2021, the reversed epsilon 3 used to demonstrate compliance with the Aerosol Dispensers or Measuring Container Bottle Regulations, will be replaced by the UKCA mark. Essential requirements remain the same.

  • 3 mark can be used for a period of 12 months – but from 1st January 2022, this must be replaced by the UKCA mark.

  • 3 mark will still be required for products placed on the EU market and the NI market.

  • 3 and UKCA marks can be placed on the same product if it is intended to be placed on both the UK and EU markets, so long as the product meets the rules for both markets.

Interested in learning more? Get in touch

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