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!