The Department for Business, Energy & Industrial Strategy of the UK releases the guidance in case the UK leaves the EU after October 31, 2019.

Actually, there are different approaches to placing a product on the UK market depending on the type of product and regulations that should be followed.

First of all, it is necessary to understand whether the product is:

• subject to the requirements of the new approach  
• subject to the requirements of the old approach  
• not subject to common EU rules and may come under the national rules (non-harmonized product).

If a product falls under the requirements of the New Approach

First of all, if the product is placed on the market before the UK has left the EU (currently, the potential date is the end of October 2019), there is no need to re-approve it under the local requirements.

The essential requirements of the EU (such as legal requirements that must be met before a product is placed on the market) that apply to products remain the same for the UK.

If a product meets the relevant requirements and bears the CE marking, it can be placed on the market of the UK but for a limited period of time. This procedure is valid up to the date when the government of the UK publishes the business notice regarding the effectiveness of a new assessment procedure. Up to this date, both the CE or UKCA markings are applicable.

One small notice regarding distributors should also be given. If the product under the new approach is placed on the market of the UK  from the EU or EEA by a distributor in November, his status will be changed from a ‘distributor’ to an ‘importer’.

If a product falls under the requirements of the Old Approach

In this case, the product is subject to detailed regulatory requirements and approvals by public bodies. Before introducing the product, it is necessary to check the relevant guidance.

The following types of products should be additionally checked:

• Chemicals  
• Medicines  
• Vehicles  
• Aerospace

If a product is not subject to common EU rules

After October 31, 2019, the mutual recognition principle will not apply to non-harmonize products placed on the market of the UK. Such products should meet the UK national requirements in any case.

In case when the product is imported from non-EU countries and requires third- party conformity assessment, it is possible to use one of the following ways to confirm the compliance of the requirements and place the product on the market of the UK:

1. Apply for conformity assessment to a UK approved body  
2. Apply for conformity assessment to an EU or EEA notified body. Thus the product can be placed on the EU internal market and the UK market for a limited time  
3. Apply for assessment against EU requirements by using designated conformity assessment bodies for a limited time. However, the bodies need to be based in countries that have previously concluded mutual recognition arrangements in relation to conformity assessment with the EU.

These countries are:  

• Australia  
• New Zealand  
• Canada  
• USA  
• Japan  
• Switzerland  
• Turkey  
• South Korea  
• Israel

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The information has been prepared by the GMA Consult Group team. ‍

GMA Consult Group provides a full cycle of international type approval and global market access services for IT, Telecom, and industrial electrical products in all countries throughout the world. With proven expertise in worldwide regulations, compliance, certification, and conformity assessment, GMA Consult Group can help your company speed up the access to any market with almost zero efforts from your side.

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