Brexit Update — CE Marking and the UK

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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Translation Bafflement

iStock_000009386795Small - Photo of Instruction manualI’ve been notic­ing a trend with some of my clients that I am hav­ing a real­ly hard time under­stand­ing — maybe a read­er can help me get this…

A basic require­ment in the EU is that man­u­als and oth­er infor­ma­tion a man­u­fac­tur­er pro­vides to their cus­tomer be pro­vid­ed in the offi­cial lan­guage of the coun­try where the prod­uct is being sold. One pos­si­ble way around this is to pro­vide a graph­i­cal set of instruc­tions. Prob­a­bly the best exam­ple of this is IKEA, where every­thing is done graph­i­cal­ly.

To me, this is only log­i­cal, after all, if I buy a prod­uct I’d like to be able to read the instruc­tions in Eng­lish, and I can’t imag­ine that oth­er peo­ple wouldn’t want to read the instruc­tions in their native lan­guage too.

But here’s the thing—I reg­u­lar­ly have clients who don’t want to trans­late their instruc­tion man­u­als. They look for every pos­si­ble excuse, from ‘those guys didn’t do it’, refer­ring to a com­peti­tor, to ‘the cus­tomer speaks and reads Eng­lish, so we don’t need to trans­late’. The first excuse is laugh­able in my opin­ion, and the last one is at least some­what plau­si­ble, but the law requires trans­la­tion. Sim­ple. Sell the prod­uct in Ger­many, pro­vide instruc­tions in Ger­man. Sell it in Italy, pro­vide instruc­tions in Ital­ian.

IKEA Desk Chair Instructions
Graph­i­cal Instruc­tions, IKEA Style

This even holds true here in Cana­da where I live. In most of Cana­da, Eng­lish is pre­dom­i­nant, but every pack­age is marked in Eng­lish and French, and instruc­tions are pro­vid­ed in Eng­lish and French. Why? Because we have two offi­cial lan­guages, Eng­lish and French.

So what’s the big deal? I under­stand that there is a cost attached to trans­la­tion, but it’s a cost of doing busi­ness in anoth­er mar­ket and should have been eas­i­ly fore­see­able in devel­op­ing the prod­uct bud­get.

If you can explain this to me, I’d love to hear from you!