FROM 1st JANUARY 2021 THE UNITED KINGDOM IS NO LONGER PART OF THE EUROPEAN UNION MEMBER STATES.
Brexit has introduced several changes regarding normative standards and has introduced modifications to the regulatory procedures relatively to product conformity.
LET’S TAKE A CLOSER LOOK AT WHAT HAS CHANGED WITH BREXIT FROM A LEGISLATIVE POINT OF RELATIVELY TO PRODUCT MARKING:
From 1st January 2021 a new product marking has been introduced for products to be placed on the market of the United Kingdom (England, Wales and Scotland) which is identified with the acronym 
(UK Conformity Assessed).
This marking will progressively substitute the CE marking in the former member states.
Nonetheless, this newly introduced marking is not recognised by the 27 EU member states, therefore to place a product in the EU market, CE marking will be necessary.
If products are intended for Northern Ireland, despite it is part of the former member states, CE marking and all other EU markings will still be valid.
However, in case a UK body carries out a third party conformity assessment, both CE and UKNI markings must be applied.
It is important to note that such products with double CE –
, marking, cannot be placed on the EU market because they have been evaluated by a UK-based certification body.
TIMELINES AND DEADLINES
A transition period has been granted For UKCA marking application in order to allow companies to adjust to the new regulations. Therefore for most part of the products CE marking and pertinent technical documentation can be used until the 1st January 2022 deadline.
New marking must be applied immediately if the product meets all the following conditions:
- it is intended for the UK market;
- it falls under the legislation which requires marking;
- it requires conformity assessment from a notified body;
- product conformity assessment has been carried out by a UK assessment body.
From 1st January 2023 it is mandatory to apply , with no exception. , with no exception.
At this date, the technical requirements, processes and assessment standards used to prove conformity and obtain
,marking, do not seem to be any different from the same required for CE marking.
Below you will find a brief overview of what has been said so far and which tells you what markings are accepted in each market:
MACHINERY DIRECTIVE
Post Brexit, the Machinery Directive 2006/42/CE will be replaced by the Supply of Machinery (Safety) Regulations 2008,which is UK’s national implementation of the Directive.
With the act named The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 NO. 696, enforced on 1st January 2021, some modifications have been introduced which have a general impact in matter of regulations regarding product safety, including machinery regulations.
Moreover, the Low Tension Directive has been replaced with The Electrical Equipment (safety) Regulation 2016 No. 1101, in which all references to the European Union have been deleted and some definitions have been modified.
STANDARDS
Post Brexit, the EU harmonised standards will become DESIGNATED STANDARD and can be used to guarantee presumption of conformity with UK regulations.
Most of these standards will not undergo any modification to the European Directives harmonised standards.
In the matter of machinery safety EN ISO 14120 and EN ISO 13857, reference standards for the design and installation of machinery fencing guards, these will remain the same.
The harmonised standards will still be used in Northern Ireland, where the European regulations will still be applied.
DECLARATION OF CONFORMITY
As far as the Declaration of Conformity is concerned, a new declaration has been introduced named ’UK Declaration of Conformity’’.
This document has the same layout of the EU declaration of conformity, without references to the European standards and regulations which have been replaced by the same standards and regulations in force in UK.
