P34-35 EU CE UKCA Regulations:Layout 1 28/01/2021 14:56 Page 34 Operator Guide
Compliance regulations after Brexit
Brexit is a hot topic at the moment: every manufacturer, whether EU or UK-based, wants to know how it’s going to impact them. The UK officially leſt the EU on 31 January 2020, when a transition period withdrawal agreement was set in place that specified that EU law will continue to apply in the UK until 31 December 2020. Aſter this period, EU treaties, EU free movement rights and the general guidelines under EU law no longer apply to the UK. Here, Chris Rush, digital content writer at
distrelec.com, takes a look at how Brexit might affect the laws and regulations governing product compliance and liability for the UK market and in the EU.
Chris Rush T
he results of the 2016 referendum defied predictions and shook-up global stock markets, causing the
British pound to fall to its lowest level for 30 years. The process of leaving the EU was started by invoking Article 50 of the Lisbon treaty, which was triggered on 29 March 2017. The UK had, from this point, two years to agree and negotiate a deal on a new relationship with the EU. This was extended several times due to failed negotiations and changes in the UK parliament. On 31 December 2020, the UK left with a
deal agreed between the British Prime Minister Boris Johnson and the President of the European Commission Ursula von der Leyen. Current EU legislation sets a high standard for
product safety, environmental and other regulatory requirements which apply to a wide range of products such as electrical equipment, medical devices, machinery and toys. Changes on any of this legislation ultimately
34 | electrical wholesalerFebruary 2021
change the free movement of goods between the UK and EU, where restrictions could be in place.
Under the withdrawal Act for the UK,
government ministers will have to legislate to amend the UK laws implementing EU directives to ensure those laws are coherent and effective after Brexit, and as a result the UK will have to form its own conformity assessed marking system.
How does Brexit impact health and safety compliance? Before Brexit, the UK as part of the EU had mandatory conformity marking for regulating goods sold within the European Economic Area (EAA) called Conformité Européenne, also known as the CE mark and very similar to FCC in the US. This directive applies not only to goods produced within the EAA, but also to those sold in the EAA. This is what makes the CE mark very recognisable throughout the world.
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