It should be noted that this will be a withdrawal agreement only - a full Trade agreement is likely to take 5-10 years of negotiation (this is just how long the EU takes and unlike the withdrawal agreement, the Trade Deal will be required to be approved by every Member State). So Brexit with no deal become more likely and prudence would suggest to prepare for it.
In September HMG issued 3 statements relating to Trade in the post Brexit world:
- Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal
- Trading under the mutual recognition principle if there’s no Brexit deal
- Appointing nominated persons to your business if there’s no Brexit deal
In brief these statements introduce the concept of a new UK Approval Mark and UK Approval Bodies. The assertion is that all Conformity assessment procedures, Essential Requirements, and standards will remain aligned with those currently in force within the EU. The concept of a single series of tests for products figures prominently.
The UK's "Notified Bodies" will become "Approved Bodies" and will have new 4 digit identifier numbers - so this will mean some alterations to Manufacturers' labels and paperwork. The EU's "harmonised Standards" will become "Designated Standards" in the UK. Manufacturers and importers who wish to place products on the EU and UK market will thus have to apply to both an EU Notified Body and a UK Notified Body. Details of the new Approval Mark are expected later this year.
For Kiwa's gas appliance and component manufacturers and solid fuel appliance manufacturers, Kiwa has arrangements in place - Certification procedures have been aligned and we will continue to work hard to support our customers to transition to the post Brexit world as painless as possible from a Certification perspective. As soon as details of the new mark are available we will contact all our customers to inform you how we can support you in achieving the new Mark.
These new arrangements will apply to all CE marking legislation - a list is given in the links. Kiwa has an extensive network of Notified Bodies across Europe and the UK office will be pleased to assist UK manufacturers access this network.