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!