Brexit Update – CE Marking and the UK

UK and EU Flags against a blue sky

I recently read a press release by UKAS, the UK’s accreditation body, regarding their ongoing discussions with the UK government regarding the impact that BREXIT could have on UK accreditation.

As mentioned by Douglas Florence in a recent discussion on LinkedIn, it’s possible that if not handled well things could end up in a bit of a mess. Mr Florence particularly noted that:

  • The UK will no longer have any influence in Machinery Working Group and Horizontal committee. At present, the UK is an important actor in EU Machinery Working Group.
  • If UK requirements diverge from EU requirements, manufacturers will need to follow different requirements for different local and EU sales.
  • If UK is not in the EU, UK machinery manufacturers will need to find an EU address to quote on their DoC for the “person authorised to compile the technical file”.
  • The Machinery Directive has less reliance on Notified Bodies than some other Directives, but it will be undesirable if UK manufacturers have to find a Notified Body (NB) outside the UK if UK NBs no longer exist.

It’s worthwhile noting that these points are NOT certain to occur. Depending on what UKAS can do to influence Downing Street, these points could be avoided or could have less impact than is currently foreseen by industry insiders.

It seems that UKAS is trying to ensure that UK accredited bodies are either:

  1. able to maintain their existing accreditation or
  2. at least maintain recognition via mutual recognition agreements with the EU.

As the say in their press release, it is still unclear what direction the UK Government is taking in this matter. Hopefully, we will find out soon!

Read the press release.

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Acknowledgements: Douglas Florence as quoted in the text.
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Author: Doug Nix

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. ( in Kitchener, Ontario, and is Lead Author and Managing Editor of the Machinery Safety 101 blog.

Doug's work includes teaching machinery risk assessment techniques privately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as providing technical services and training programs to clients related to risk assessment, industrial machinery safety, safety-related control system integration and reliability, laser safety and regulatory conformity.

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