After 47 years of membership, the United Kingdom has left the European Union. The United Kingdom left the European Union on 1 February 2020. There was a transitional period until the end of 2020. There were far-reaching changes after 31 December 2020. Here you'll find an overview of the range of information available on machinery safety.
Brexit – Effects on machine safety
Brexit UKCA mark - Transitional arrangement extended!
Brexit - Regulations
In Mid-November 2022 - a few weeks before the original deadline was to expire at the end of 2022 - the British government extended the deadline up to which products with CE marking may be imported into the United Kingdom (apart from a few exceptions). The new deadline is now 31.12.2024. As a manufacturer, the choice is yours, as indeed it was before, and you can import products with CE or UKCA marking into Great Britain.
Previously, the regulation provided for CE marking and the EU conformity assessment to be used under specific circumstances until 1 January 2023, when placing machines or machine components on the British market. However, back in 2021, the deadline for applying CE marking of products for import into the United Kingdom, which originally was to end on 31.12.2021, was extended until 31.12.2022.
Nevertheless, it is a fact that a national British conformity assessment procedure has been established. A separate conformity mark, the "United Kingdom Conformity Assessment - UKCA" has been introduced. The procedure refers to national UK laws and no longer to EU directives.
Implementation obligations - Regardless of the deferral
As a manufacturer, you will surely welcome the extra time. But the bureaucratic burden of Brexit has increased noticeably. If you, as manufacturer, wish to import products into the United Kingdom, independently from the conformity marking you will be obliged as a minimum to appoint and nominate an authorised representative, based in the United Kingdom, as a contact address for the English market surveillance authorities. If inspections are carried out, there is a high risk that deliveries will be rejected if the manufacturer has not taken all the necessary measures.
After 1 January 2025, only the UKCA mark is to be accepted. However, until 31 December 2027, companies will still be permitted to declare UKCA marking and information about the product importer on an accompanying document or label.
Brexit – Current regulations at a glance!
Brexit has been a reality since 2021. The most significant changes in machinery safety concern the conformity assessment procedure. In our compact flyer you can read about the Brexit regulations that currently apply.
Pilz uses standardised processes for international conformity assessment . Pilz experts always work closely with the Pilz subsidiary in the target country. If necessary, Pilz can act as authorised representative and assist in the process of obtaining CE or UKCA marking. If you have any questions, we're here to help and advise.
The following regulations apply for placing goods on the market in Great Britain
In most cases, goods that meet EU requirements can continue to be placed on the British market until 31 December 2024.
Within a defined transition phase from 01.01.2021 to 31.12.2024, it will still be possible to continue using the EU conformity assessment procedure and CE marking under specific circumstances and for specific product groups. Based on each product, you will need to check which product groups fall under which category, and whether they require the UKCA mark from 01.01.2021 or not until 01.01.2025
If your conformity assessment was carried out by a British conformity assessment body, you may no longer use CE marking.
Placing machines on the market in Great Britain - with UKCA marking - requires application of the British conformity assessment procedure, for example with the help of an authorised representative, who is established in Great Britain.
The following regulations apply for placing CE-marked goods on the EU market:
If you place finished goods from Great Britain on the EU market, measures must be taken to ensure compliance with EU requirements by 1 January 2021; there is no transition period.
British notified bodies will lose their accreditation and British EC/EU type examination certificates will no longer be valid. You must go through the process of obtaining them again.
Make sure your machines are placed on the market in Great Britain with Pilz!
Pilz experts will provide support during change processes that must be implemented in line with Brexit as regards certification, CE or UKCA marking of products and machines, the placing of plant and machinery on the market and machine components used in Great Britain or Northern Ireland. We are happy to advise you on how to make the transition safe, smooth and cost-efficient.
Our experts will cooperate with the Pilz subsidiary in the United Kingdom, to help you through the process of obtaining a UKCA. On request, Pilz can also undertake the role of authorised representative.
Official website of the British government, gov.uk, for CE marking:
Website of the European Union:
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Telephone: +61 3 9560 0621