While the UK exited the EU on 31 January 2020, we continue to provide European Union Notified Body (EU NoBo) services to customers all over the world through the EU NoBo status of several of our LR legal entities.
Our status as an EU NoBo is particularly relevant to our assurance and inspection work performed under various EU Directives and Regulations, which helps our clients retain their access to EU markets.
We hold NoBo status in several major EU countries:
- Pressure Equipment Directive (PED) in Germany (Lloyd’s Register Deutschland GmbH), Spain (Lloyd’s Register España SA) and the Netherlands (Lloyd's Register Nederland B.V.)
- Transportable Pressure Equipment Directive (TPED) in the Netherlands (Lloyd's Register Nederland B.V.)
- Construction Products Regulation (CPR) in the Netherlands (Lloyd’s Register Verification B.V.)
- Machinery Directive (MD) in the Netherlands (Lloyd’s Register Verification B.V.) and Spain (Lloyd’s Register España SA)
- ATEX (File Retention Only) in the Netherlands (Lloyd’s Register Verification B.V.)
Simple Pressure Vessel Directive (SPVD) in the Netherlands (Lloyd’s Register Verification B.V.)
- Marine Equipment Directive (MED) in Germany (Lloyd’s Register Deutschland GmbH) and the Netherlands (Lloyd’s Register Verification B.V.)
Will Lloyd's Register continue to provide Notified Body services in the EU after Brexit?
Yes, we are committed to providing all our customers with the same range of services post Brexit in the EU27 and the UK and we currently provide in the EU.
We are already approved as a NoBo for the Lifts Directive in France by COFRAC: our NoBo number 2748.
We have made applications for other approvals in the Netherlands, where LR has a large and long-established operation. We intend to provide similar services to those currently provided, through two existing notified bodies in the Netherlands, Lloyd's Register Verification BV (for Industrial Equipment Directives and Transportable Container authorisations) and Lloyd's Register Nederland BV (for Medical Devices and In-Vitro Diagnostics Devices).
We have made applications for Medical Devices directives under 93/42/EEC and 98/79/EC to VWS/Directie GMT in the Netherlands for notified body approval for Lloyd's Register Nederland BV.
We have made applications for ATEX, CPR, MD, MED, ND, PED, RID and the SPVD directives to RvA in the Netherlands for NoBo approval for Lloyd's Register Verification BV. We already hold a variety of accreditations in the Netherlands through which we have a longstanding relationship with RvA.
The applications are in various stages of assessment, with an expectation of obtaining approvals starting from around the end of 2018.
We have already prepared the required applications to the relevant Dutch authorities for the EU Transportable Pressure Equipment Directive, the International Carriage of Dangerous Goods by Road (ADR) regulation, and the Transport of Dangerous Goods by Rail (RID).
How long will my existing Lloyd's Register certificates remain valid for?
Unless a mutual recognition arrangement is agreed between the EU and the UK either on a transitional or permanent basis as part of the Withdrawal Agreement, currently issued LR certificates will cease to be valid with effect from the withdrawal date (30 March 2019 00:00 hrs CET). There are indications that mutual recognition of Notified Bodies will be included within the scope of the proposed transition agreement, covering the period until December 2020. We understand that discussions also include the possibility of a permanent mutual recognition scheme forming part of the final agreement. However, to address the possibility that there could ultimately be no recognition agreement between the EU and the UK, we are taking necessary measures to enable us to continue to support our clients, by obtaining Notified Body appointments within the EU27.
Will notified body transfers be free of charge or at a nominal cost?
It is our intention to transfer clients’ approvals from our UK Notified Body to that in the Netherlands with minimum cost once we obtain appointment in the Netherlands. We are discussing the transfer process with the Dutch authorities and will let you know any developments as they arise.
UPDATE : What steps do I need to take now to transfer certificates that will continue to be recognised by the EU?
We have made applications for ATEX, CPR, MD, MED, ND, PED, RID and the SPVD directives for NoBo approval for Lloyd's Register Verification BV in the Netherlands and are pleased to confirm that this has received accreditation from the Dutch Accreditation Council, Raad voor Accreditatie (RvA).
This means we can now progress with our application to the various Dutch ministries and we expect to receive formal notification and a posting on the Nando website in the next few weeks.
Once we receive approval, we will have Notified Body status both in the UK and the Netherlands. As such, in the case of a soft Brexit i.e. a structured withdrawal from the EU with an agreed deal, this will allow you to decide which will best meet the needs of your business.
Notified Body status in the Netherlands means we can continue to provide similar services to those now provided through our UK Notified Body for the following EC Directives and Regulations:
Noise emission in the environment by equipment for use outdoors
Transportable Pressure Equipment
Simple Pressure Vessels
Interoperability of the rail system within the Community
Directive (EU) 2016/797
Interoperability of the rail system within the European Union (recast)
Regulation (EU) No 305/2011
Please note, our application for Directive 2014/90/EU Marine equipment is being treated as an Extension to Scope (ETS) and will be added to the schedule of accreditation in the coming weeks.
If you decide to transfer, the next stage in the process will be to move your current certificates from LRV Ltd/LRC-Energy AS to LRV B.V. We have ensured that our Notified Bodies in the UK and the Netherlands work to identical processes and procedures which will make the transitioning of your certificates from one body to another as straightforward as possible, with minimal impact on your business.
The transfer includes the issue of certificates bearing the new Notified Body number assigned to us in the Netherlands, which then fully replaces your existing certificate issued from the UK.
Will ISO/UKAS standards certification be affected by Brexit?
ISO is an international organisation and not tied to the European Union in anyway. ISO Standards are therefore unaffected by Brexit. As an International Accreditation Forum (IAF) MLA signatory, UKAS’s accredited management system approvals will continue to be recognised post Brexit.