Tue, 09 March, 2021
At 11pm on 31 December 2020, the BREXIT transition period ended and the UK left the European Union. Since then, TWI has received a number of enquiries on the effect that this has on the application of European standards and regulations by UK organisations. These are summarised below.
It is important to note that TWI is not authorised to give official interpretations/guidance on behalf of the UK Government or BSI and this summary represents the understanding of our experts, and cannot be taken as a definitive answer. These may be obtained by the relevant bodies/organisations.
ISO standards: No changes. BREXIT does not affect BSI’s membership of ISO, so there are no changes to the UK’s role in the drafting of ISO standards or to their applicability on the UK.
EN standards (includes ‘BS EN’ and ‘BS EN ISO’ standards): No changes. BSI's membership of CEN and CENELEC continues until the end of 2021, so the UK participation on the drafting of EN standards and their application in the UK will not change in that period. EN and ISO standards will continue to be adopted by BSI as BS EN ISO. BSI expects that its membership will continue beyond that time. See here for more details.
- EN 1090-1 Factory Production Control (FPC) certification is still required in the UK. The new UK domestic regime covers most goods that were subject to the EU’s CE marking. The technical requirements for these goods are the same as they were before the UK left the EU. However, there has been some changes introduced, which include the UKCA marking and a system of third-party conformity assessment by UK-recognised Approved Bodies, and UK Conformity Assessment Bodies (CABs) under the Pressure Equipment (Safety) Regulation (PER), that have replaced the EU system of Notified Bodies (see ‘Pressure Equipment’ above)
- Manufacturers with a UK Notified Body Factory Production Control certificate will no longer be able to CE mark their products under this FPC system. The UK market will no longer accept a CE marked product from January 2022. This means all European countries that do not have a UK Certification Body will need to gain certification with a UK Certification Body to export into the UK. For manufacturers that need to export into Europe a CE mark is still required
- UK CABs and UK Approved Bodies can provide equivalent UK Factory Production Control certificates, enabling manufacturer’s to UKCA mark and UK(NI) mark their products. TWI Certification Ltd has been granted a new UK ‘Approved Body’ status operating under the UK Statutory Instrument (SI) No. 1359
- TWI Certification Ltd has partnered up with a Swedish company called AAA Certification AB (A3CERT) to ensure its customers can place any of the three marks (CE, UKCA, UK(NI)) on their products. See further details here