Impact of Brexit on Testing, Inspection and Certification services

December 2020

If no trade agreement is reached between the UK and the EU during the transition period (and a “hard Brexit” occurs), European legislation will cease to apply to the UK. Both companies based in the UK and companies based in the EU will likely to be faced with changed rules regarding activities in the area of Testing, Inspection and Certification (TIC). The exact consequences are not yet known.

Impact on UK based companies

When EU regulation no longer applies to the UK, it will become a third country in relation to the remaining EU Member States. UK based manufacturers and exporters to the EU will then export products from a third country into the EU market. Consequently, they will probably need to meet the requirements applicable to exporters in the area of TIC.

Impact on EU based companies

The UK is an important trading partner for many European countries. Brexit will probably also have consequences for companies who export products and services form the EU to the UK that are tested, inspected and certified according to EU regulation. According to expected post-Brexit standards, this regulation will then probably no longer apply to these products and services.

Impact on UK based Notified Bodies

In the European Union, a Notified Body (NoBo) is a third-party entity that has been accredited by a Member State to assess whether a product or service to be placed on the market meets certain standards. Companies that want to have a product or service tested, inspected or certified in accordance with the correct regulations, use a NoBo for this. Kiwa is one of these NoBos.

From the moment Brexit takes effect, UK Notified Bodies will lose their status as European Notified Bodies. Products inspected, tested or certified by a UK Notified Body cannot be placed on EU market unless re-tested/re-certified by an EU Notified Body.

Validity of certificates

In the event of a "hard’ Brexit" or the absence of a transition or full UK-EU treaty, it is possible that UK and EU Notified Bodies’ certificates may not be mutually recognized or deemed valid.