Dear mods, the following is not political, it is a description of the realities of the UK-EU Trade and Co-operation Agreement for manufacturers of certain goods. But I accept you may feel it does not belong here, so in that case please feel free to delete.
(PS. Do not use the following as a guide if you are a manufacturer affected by these changes. Get some proper bloody advice!)
OK Robert, you asked for it!
Say you make something covered by an EU regulation or directive, that needs 3rd party assessment, like PPE, a construction product, or a pressure device. Up until 31st December, you got your certificate and applied the CE mark. Job done.
From 1st January it all changes. And it doesn’t change but also changes most in Northern Ireland.
So, you want to sell your FFP2 mask in the European Union (EU), which now obviously does not include the UK. OK, you still need a CE mark. Is your certificate from an EU27 (not UK) body? Yes? Good, carry on CE marking.
Oh, you had a UK certificate? Oh sorry, no CE mark for you. Did you transfer it to an EU27 body? No? tough, get a new one.
Ah, but you want to sell in the UK as well. Congratulations, your UK certificate can be used in the UK. Except you have to change all your labels and remove the CE mark, and put on the UKCA mark. User Information and Declarations? Yes please, all changed. Oh, we’ll let you off doing it all straight away, as long as everything has a piece of paper with the UKCA mark we’ll let you have 2 years to change the markings. Except for some things.
Ah, but you DO have an EU27 certificate? That’s all right then! You can still CE mark and sell it in the UK! For one year! That’s right, you can sell your Concrete flue liners until December 31st 2021, and then you will have to get a second certificate from a UK body, and use the UKCA mark. Two certificates, two marks, two sets of paper. Easy peasy.
Oh wait, we forgot Northern Ireland. You see, when I said UK, I didn’t really mean the United Kingdom of Great Britain and Northern Ireland. I mean Great Britain. The big bit, England and Scotland and Wales. Yes, to sell in Great Britain you need a UK conformity assessment approval and to use the UKCA mark. Not a Great Britain approval, with a GB mark, oh no, it’s a UK mark.
Northern Ireland has its protocol, because of the Good Friday Agreement. Which means no land border. Which means, that it still follows some EU rules. And that means that the CE mark is accepted. That’s right, with your EU27 certificate you can CE mark your steam boiler and sell it in Northern Ireland.
Ah, but what about all those UK (sorry) GB businesses supporting UK test houses? That’s alright, Northern Ireland is also following the UK rules as well as the EU rules. You can sell your product in Northern Ireland. With a CE mark. But not just a CE mark, a CE mark AND a UK mark. And not just any old UK mark, but a CE mark with a UK(NI) mark. That’s right, with a UK certificate you can CE mark your steel joist as long as you put those magic letters after it. But don’t try and sell it in the Republic with that mark on. Or in the UK (sorry) GB. Oh no.
Ah, but what if you are actually IN Northern Ireland? And you make what is known as a Northern Ireland qualifying good? Well, congratulations, the best of both worlds! If you have an EU27 certificate, you can sell your Fire suit in NI, and of course in the rest of the EU. Ah but wait, didn’t Boris promise ‘unfettered access’ to the UK (sorry) GB market? Yes he did! So, you have a CE marked commercial grade carpet, which you can sell in the rest of the UK (sorry) Great Britain! That’s right, a NI business CE marking NI qualifying goods with a French (or German, Spanish, Polish, Slovenian…) certificate can continue to sell CE marked bursting discs long after your competitors have had to get a UK certificate! Huzzah!
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