Ensuring continuity of market access for your products and services

September 2020: Intertek understands the complexity of the impending regulatory market changes which Britain’s exit from the EU will bring, and the impact on exporters & importers to the UK and European markets, where a Notified Body is required to assess the conformity of their products or services.

The Brexit transition period exit date is set for 31 December 2020, at which point the United Kingdom (UK) will leave the European Union (EU) Single Market and Customs Union. The UK Government and the European Commission are engaged in free trade negotiations which will determine if a Comprehensive Free Trade Agreement (CFTA) is signed, or the United Kingdom exits with no agreement in place.


The outcome of these negotiations will have an impact on product conformity assessment, product marking and market access. There will either be an agreement in place which allows the CE Mark to be used in both the EU and UK, or an alternative set of arrangements will apply from 1 January 2021.

The UK Government has said that it will continue to recognise the CE Mark for a limited time for goods that are placed on the GB market, in the event that the UK Government and the EU fail to reach a CFTA (see below). However the EU has said it will cease to recognise CE Marks issued by UK-based Notified Bodies from 31st December 2020. This means the EU will continue to require products to be CE marked to gain entry for sale in mainland Europe, on the basis that the mark is issued by an EU-based Notified Body.

On 1st September 2020, the UK Government issued public notices related to the new UK market regulatory framework following the end of the transition period. This is available here: www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021.

We have provided a summary of the changes below:

If the UK Government and EU fail to reach a CFTA, to allow businesses time to adjust to a new set of requirements, CE marking will continue to be recognised in the Great Britain (GB) market (England, Scotland and Wales) until 1st January 2022. After this date, CE marking will not be accepted and the new UKCA (UK Conformity Assessed) marking will apply to goods being placed on the market in Great Britain. The UKCA marking covers most goods which were previously subject to the CE marking. For the Northern Ireland (NI) market, special marking rules (CE or CE /UK(NI)) will apply with a different transition timeline.

How Intertek can support you now and beyond the UK’s exit from the EU

Intertek has taken the necessary steps to ensure that customers have continuity of Notified Body services regardless of the outcome following the end of the transition period. Intertek has accredited Notified Bodies based in the EU as well as in the UK and can provide you with market access solutions to export goods to:

  • The EU market – if the CE marking on your product was issued by an EU-recognised Notified Body or you have self-declared the conformity of your product against the regulations, no further action is needed
  • The GB market – if your existing product is already CE marked, it will continue to be accepted until 1st January 2022. However for new products yet to be sold in Great Britain, UKCA marking will need to be used immediately after 1st January 2021
  • NI market – existing and future new products placed on to the NI market that are CE or CE/UK(NI) marked will be accepted until 1st January 2023

In addition to the above, Medical, Automotive, Aerospace and Construction Products have additional special rules that will apply from 1st January 2021 until June 2023.

If an agreement is reached between the UK Government and EU on a new trading relationship, both CE and UKCA marks will be recognised and accepted by EU and UK authorities.

Intertek EU-27 Notified Body Services Capability

  • ATEX Directive
  • Gas Appliances Regulation
  • Boiler Efficiency Directive
  • EMC Directive
  • Radio Equipment Directive
  • Outdoor Noise Directive
  • Machinery Directive
  • Life Safety & Security (CPR)
  • Building Construction Products (CPR)
  • Personal Protective Equipment (PPE) Regulation
  • Toys Directive
  • Medical Devices Regulation
  • Pressure Equipment Directive

Intertek UK Approved Body Services Capability

  • ATEX Regulation
  • Gas Appliances Regulation
  • Boiler Efficiency Regulation
  • EMC Regulation
  • Radio Equipment Regulation
  • Outdoor Noise Regulation
  • Machinery Regulation
  • Life Safety & Security (CPR)
  • Building Construction Products (CPR)
  • Personal Protective Equipment (PPE) Regulation
  • Toys Regulation

Contact our experts today to discuss how we can support you

For customers seeking to minimise their certification risks and who are not already working with an EU Notified Body, Intertek can support transitioning customers to EU Notified Bodies to ensure continuity of market access, whatever the outcome of the negotiations. Customers would still have a period post-transition to identify any additional UKCA Mark needs for access to Great Britain markets.


Contact Intertek’s experts today to discuss your needs with us.

For Marking guidance from the UK Government visit www.gov.uk/transition

CE Marking www.intertek.com/marks/ce/


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