Brexit factsheet: Placing goods on the EU and UK market

Learn about Brexit impacts on new regulations around conformity assessments when selling goods in both the EU and the EU.

Businesses must comply with new regulations on conformity assessments. This applies when you're selling goods in both the EU and the UK.

What will be different when selling to the EU?

1. CE mark, and Health and Safety Standards

Goods which are subject to Health and Safety Standards will still require the CE mark. However, any conformity assessment carried out by a UK conformity assessment (notifying) body will no longer be recognised by the EU. The same principles apply if your business has self-certified in the UK.

CE mark goods tested by a UK based notified body would need to be re-tested by an EU recognised notifying body before being placed in the EU in the event of a no-deal Brexit.

What actions are required?

If your business uses a UK notified body currently, you should check what steps the notifying body are taking to support continued exporting and sale of goods to the EU.

If the notifying body have not taken any steps, your business will need to transfer your conformity assessment certificates to an EU notified body or apply for a new certificate from an EU notified body.

The following are examples of the types of goods which require CE marking:

  • Machinery
  • Electrical products
  • Medical devices
  • Cosmetics
  • Toys

2. Sale of non-harmonised goods to the EU

Some goods can trade in the EU under the mutual recognition principle (goods which are compliant in one-member state may sell that good in another EU member state). This applies even if the national requirements of the latter state are different to those of the former state.

Examples of non-harmonised goods include:

  • Bicycles
  • Beverages
  • Cereals
  • Cooking utensils
  • Edible fruit and nuts
  • Furniture
  • Ladders
  • Precious metals
  • Textiles
  • Vehicles

As part of the EU, and under the principle of free movement of goods, UK businesses can sell these goods in the EU having met the UK national requirements. In the event of a no-deal Brexit, UK national requirements will no longer be acceptable.

What actions are required?

If your UK business exports to the EU, you'll need to meet the national requirements of the first EU country where they are made available (after the 31 October 2019).

Ensure your business is aware of this issue and is ready to meet the national requirements of the first EU country of sale. Select your first country of sale carefully.

Learn more about these requirements on GOV.UK

Will there be any differences when selling goods in the UK?

Yes, there will.

1. CE mark replaced by a new UKCA marking

Businesses will only be able to use the CE marking for products being placed on the UK market for a 'time limited period'.

There will be a new UKCA (UK Conformity Assessed) marking in the event of a no-deal Brexit. Most but not all products which are currently covered by the CE marking will fall within scope of the new UKCA marking.

The UKCA marking will not be recognised in the EU market.

2. Sale of non-harmonised goods in the UK

In the event of a no-deal Brexit, if your business imports non-harmonised goods into the UK you will need to ensure the goods meet the national requirements of the UK.

Learn more about these requirements on GOV.UK

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