Brexit and how it will affect certifi cation
Andy Curtis, STA
As the United Kingdom prepares to exit the European Union (EU) (so called ‘Brexit’), the impact on UK certifi cation is a growing concern for many.
Currently, a UK Notifi ed Body (NB) may have the authority to issue certifi cations from within the UK which is valid in the EU. However, with Brexit negotiations continuing, it’s unclear whether or not NBs will have the ability to provide valid EU certifi cation. Although the full impact is not yet known, when the UK leaves the EU, they will no longer be an EU member state and this could potentially mean that EU Directives can no longer be operated by UK organizations that were accredited prior to the UK’s departure.
At time of writing, the UK and EU are discussing a possible transition deal (also called an Implementation Period) to allow UK Notifi ed Bodies (NBs) to continue progressing certifi cation in Europe until December 31st, 2020.
During this period, a trade agreement will be worked on to allow NBs in the UK to continue to operate as EU NBs after the period ends. However, should that transition or trade agreement not result, companies are taking steps to ensure their own agreement is reached.
How EU certifi cation is affected
Since July 2003, manufacturers wishing to place products intended for use in explosive atmospheres within the EU have been required to comply with the ATEX Directive. Issued ATEX certifi cates will remain valid until March 2019 (unless a ratifi ed withdrawal agreement establishes another date) and UK-based ATEX Notifi ed Bodies continue to issue ATEX certifi cates today. After the exit date, the process will be dictated by the type of agreement reached between the UK and EU.
Since 1998, MCERTS certifi cation has been available in the UK. It is based upon EU regulations and is managed by the Environment Agency and implemented by CSA Group (under Sira Certifi cation Service). As the process of Brexit continues, the UK will continue to adopt EU regulations in UK law. The position of MCERTS should continue to be a mark of quality globally.
The future after Brexit
NBs are actively taking action against the rising uncertainty that Brexit provides and are working closely to determine the implications of Brexit and are working to establish ongoing UK operations. It is hoped that a mutual recognition of conformity assessments are included with an agreement, including recognition for UK accreditation.
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