Soon the CE mark will no longer be valid in the United Kingdom. Instead, it gets the UKCA and UKNI (for Northern Ireland). What does this mean for import and export?
Hartgers opened with the worthiness of knowing that the effective date has recently been postponed for two years. So 2023 will be 2025. That’s profit anyway. In addition, he soon told that the UKCA and UKNI have been copied from the CE standards for the time being. So technically nothing changes. “But…”, Hartgers said, ” the misery is in the details.”
The first is that the sheet coding is different, that European Notified Bodies (NoBo) are not recognized and that there are own standards. For the time being, this is manageable, because you can look up the sheet coding, you only need the NoBo when the current certificate has to be replaced – so you have to look for a British NoBo – and the standards are online.
However – and this is a tricky one-if the EU changes a directive, the UK doesn’t have to. So, for example, in the transition to the machinery regulation, the old Machinery Directive is likely to remain in force overseas. In addition, this rule means that you can never rely on the rules being the same, you need to keep an eye on it all the time.
In addition, the British could sometimes become more fanatical if they have the basics in order. ” So far there have been few problems, “concludes Hartgers, ” but you don’t know how things will go in the future.”
Anyone importing goods from the UK must check whether the CE rules are met. He may rely on a letter from the manufacturer. And just as well as vice versa, Europe is not content with a British NoBo. “That can still create some obstacles, because the Chinese also use them often.”
“But a really annoying point is that of product liability. In the EU, you can’t rule it out, but in the US, for example, you can. And the UK may be moving more towards the US in terms of regulations.”
At the moment, that is still unclear – and it is probably only maintained after the first major accident. “You have jurisprudence.” What you have to make sure right away is that you buy the standards. Because if you do not have them, it is difficult to harden that you have applied them.