BREXIT: Compliance Steps to Take Now

Starting January 1, 2021, new regulatory compliance rules went into effect for products sold into the United Kingdom. These changes are a result of the United Kingdom exiting the European Union in the process known as “Brexit.” Manufacturers need to take action now to ensure their electrical and electronic products are compliant when sold into the UK and in particular England, Wales, and Scotland.

The key step for manufacturers and one that requires immediate attention is to affix the new UKCA marking for products sold in the UK. The deadline for including the UKCA mark is now less than one year away and all products sold in the UK will require it starting January 1, 2022.   Until then, manufacturers can continue to label their UK products with the CE Mark.

Note that Northern Ireland (NI) is part of the UK but the regulatory processes for NI will continue to follow the EU regulations and products sold in Northern Ireland require a CE Mark label.

There are no technical changes for manufacturers to address specifically due to Brexit.  Products will not require re-testing or new testing in order to apply the UKCA mark. For example, the UK radio equipment regulation (SI 2017/1206) and EMC regulations (SI 2016/1091) are transposed into UK law based on the existing European Union Radio Equipment Directive and EMC Directive, respectively. Manufacturers can continue to bring new products to the UK and the EU by testing to the same harmonized standards listed in the European Union Official Journal or the applicable standards that are generally applied for CE Marking processes.

At this point a European Union CE Mark Manufacturers Self-Declaration (DoC) is still required and is the compliance document required for products sold in the UK. We anticipate it may be necessary to also list the British Standard equivalent “BS” standards with “EN” standards for future DoCs.

Through the UK/US Mutual Recognition Agreement, Elite is a UK Approved Body and listed in the UK Market Conformity Assessment Body database. Our scope of accreditation includes EMC and Radio Equipment Regulations.

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