CE Marking Post Brexit

Feb. 11 2020

Based on the latest guidance, if the UK leaves the EU without a deal, the following will apply. Please note that these comments apply to the requirements for toys, but it is possible that the same will apply to all CE marked products. 

Brexit : CE and UKCA Marking

After Brexit, any product supplied into the EU (by any manufacturer based anywhere in the world, including the UK) will still need to bear the CE mark, if that product currently needs to be CE marked (i.e. if the product comes under a "New Approach" CE marking Directive). 

For products that will be placed on the UK market after Brexit, the CE mark can continue to be used for a time-limited period to show compliance with applicable UK Regulations. (Only necessary for products that currently come within the scope of a "New Approach" CE marking Directive).
The actual time limit (transition period) is still to be decided. 

Alternatively, for the UK only, the UKCA mark can be used to show compliance with applicable UK Regulations. As with CE marking, the UKCA mark is only to be used if a product currently comes under a New Approach CE marking Directive. (Such Directives have already been transposed into UK law).
The UKCA mark will not be recognised in the EU.

For "New Approach" products placed on both the UK and EU market, eventually (after the time-limited period) both the UKCA mark and the CE mark will be needed.

The above applies to both "self-certified" New Approach products (including if a third-party test lab has been used) and products where a Notified Body has been involved.
After Brexit, the UK will recognise EU Notified Bodies (for a time-limited period) but the EU will not recognise UK Notified Bodies.

The applicable testing standards (usually ENs) will continue to be used in the UK after Brexit.
Non-CE marked products will usually come under a specific Directive/Regulation or the General Product Safety Regulations (for the UK.

Voluntary non-legislative EU standards will continue to be used as per the current practice.EU distributors of UK supplied products will become EU importers instead of distributors and will have to take on the tasks and responsibilities of an EU importer, including adding their company name and address on the toy.


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