Exit day is 12th April (this Friday) – Exit time is 12.00 CET midnight
On 13th April, the UK will be a third country and UK Notified Bodies will lose their status as EU Notified Bodies. These “Notified Bodies” assess the conformity of products before they can be placed on the EU market. Once approved by the Notified Body, the CE Mark can be affixed to them.
At present, there are 1,500 Notified Bodies (NBs) in the EU, 174 operating in the UK including 50 NBs for Construction.
9 NBs are in Ireland, 3 of which are the NSAI (National Standards Authority of Ireland). The NSAI is a Notified Body for Construction Products, Medical Devices and Non-Automatic Weighing Scales.
Irish products which currently rely on a UK Notified Body for CE marking will no longer be able to be placed on the EU market.
Irish companies with products certified by UK Notified Bodies will also not be able to continue to export these to the UK, despite the fact that the UK government issued guidance earlier in the year stating that the CE Mark would continue to be recognised for an unspecified period of time until the mark is replaced by a proposed new UKCA mark.
This is because the UK bodies which issued those CE Marks will no longer be authorised to do so by the EU. The certification would need to be transferred to an EU Notified Body.
Companies must also be mindful of the Declaration of Conformity, which is a legal document that must accompany all CE Marked products sold in the European Union and other countries which recognise the mark.
After Exit day, “distributers” of UK products in Ireland will become “importers” or, they may become authorised representatives, or they may even be treated as a manufacturer if they are marketing the products under their own brand. These roles all entail further legal obligations.
Where a product is being sourced from the UK or another country and no longer carries a CE Mark, other steps will need to be taken. The certification will need to be transferred from the UK Notified Body to an EU27 Notified Body or a new CE Mark applied for.
Further information is here.
[the Exit day may change, please keep following this Blog]