Brexit and standardisation: where do we stand?

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This was the title of a web conference organised by French Afnor Normalisation for its members. On the agenda were the changes introduced since 1 January 2021 by the trade and cooperation agreement that took over the organisation of trade between the UK and the EU.

Standardisation is addressed more specifically in the chapter on technical barriers to trade. The three major adaptations introduced by the agreement concern product marking, standards giving presumption of conformity to essential regulatory requirements and bodies accredited for conformity assessment. Thus:

  • The “UKCA marking” (UK Conformity Assessed) marking replaces the “CE” marking for products placed on the English, Welsh and Scottish markets. For Northern Ireland, manufacturers can use either the CE marking or the UK(NI) marking. To facilitate the transition, CE marking alone should continue to be accepted until 1 January 2022 and the UK government has published an explanatory sheet on the transfer between CE and UKCA marking depending on the type of product.
  • The “designated standards” replace the European “harmonised standards” in the new UK legislation. They are standards adopted by a recognised standards body, i.e. CEN, CENELEC or ETSI, but also the British Standards Institution (BSI). They must also be “designated” by a UK Secretary of State. With this system, the United Kingdom is abandoning the logic of harmonisation and is giving itself the means to unilaterally recognise or reject standards chosen at European level to give a presumption of conformity with the regulations.
  • The United Kingdom will deploy its own network of notified bodies to assess the conformity of products placed on the English, Welsh and Scottish markets, the UK Market Conformity Assessment Bodies (UKMCAB).

The BSI, for its part, wishes to continue to participate actively in CEN and CENELEC, retaining all its rights and duties as a Member. It benefits from a derogation. Therefore, it will continue to participate in the work under the same arrangements until 31 December 2021. As a reminder, the BSI is excluded from the second vote count after a formal negative vote in the same way as all non-member countries of the European Economic Area.

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