3 October 2019

Brexit Update

October 3th, 2019 - Three years into the Brexit process, all possibilities are still possible and the outcome hard to predict, but given the statements made by our UK and EU politicians, preparations for a No Deal exit can be the basis for business risk mitigation planning. 

No Deal

As of today, Great Britain is due to leave the European Union (EU) on 31 October 2019. Thereafter, the compliance landscape and related processes and regulations will change. 

As the UK (after a Brexit) will no longer be an EU member state, your current certifications of a UK Notified Body would need to be re-certified by an EU Notified Body. Through the co-operation between the Kiwa companies (both in the UK and in the EU), this is a straightforward process that will involve minimal review but will require a change of the Notified Body number. For Kiwa UK customers we can transfer you to one of the EU based Kiwa Notified Bodies (of your choice).


Please note that if the UK leaves with a deal - your CE Certification, of a UK based Notified Body, would possibly be valid until the end of the implementation period, (31st December 2020 as it is stands today).

UK Market

For the UK market is it is a little less black and white.  If you have your products certified by an UK Notified Body we believe that your current GAR certificate will remain valid as evidence of compliance with the UKCA, and a UKCA Certificate will be provided when required. The UK authorities have stated that it will continue to accept CE marked products by a current UK Notified Body for a period of time, but will introduce a new Conformity Assessment Scheme - the UKCA - which will have a similar structure to the CE compliance framework -

  • It will follow the principle of one test for UKCA and CE - having the same requirements and using the same standards
  • If the legislation for CE is self-declaration based, then it will also be the case under UKCA, meaning that  the content of the Declaration of Conformity will reference the UK law rather than the EU Regulation/Directive
  • If Notified Body involvement is required under CE Marking - then also an UK Approved Body involvement will be required; in principal all UK Notified Bodies will transition to become Approved Bodies

So for example for a gas appliance, all of the testing and certification requirements for CE marking will apply for products which are placed on the EU market (Business as usual). The GAR CE Certificate and Technical Report and associated evidence can then be used to form the basis for approval under the UKCA Scheme.

Our Kiwa UK based company will become a UKCA Approved Body and will be able to transfer all Kiwa clients to the UKCA mark. As stated, Kiwa UK has back to back agreements with our Kiwa GAR Notified Bodies to offer CE marking under their notifications. Furthermore,  Kiwa is able to offer combined surveillance visits for both UKCA and CE, based on one combined audit.


Independently from the outcome of the Brexit, Kiwa can already support manufacturers to prepare for the Brexit. We have a process in place that can provide you with the necessary Draft (UKCA) Certificates and  surveillance agreements. These can already be prepared now and will become activated the moment the Brexit is a fact.

For more information or to discuss the best approach for your company strategy, please contact: Carolien.Geenen@kiwa.com or your local sales representative.