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Brexit impact in relation to Industrial Equipment Directives

We are committed to helping our clients navigate challenges resulting from Brexit, regardless of the outcome of the negotiaton process.

The UK and EU have yet to finalise the agreement for the UK to withdraw from the EU. Through our involvement in Standards Committees, Notified Body Forums and strong relationships with government and industry, we are closely involved with developments.
We will do everything we can to help our clients maintain their NoBo and RO approvals, and to retain their access to EU and UK markets.

As negotiations progress, we will keep you updated both on this page and via our account managers and business support teams.

Our status as an EU NoBo is particularly relevant to our assurance and inspection work performed under various EU Directives and Regulations. Although Brexit negotiations could result in arrangements under which the UK continues to operate its own NoBos, we are actively preparing for the possibility that UK NoBos will lose their current status from March 2019, as both the EU Commission and HM Government have indicated in their respective statements around the impact of a “hard Brexit”.

We are firmly committed to remaining a major EU NoBo for Industrial Equipment Directives and have developed several options for how this will be achieved dependent on the final agreements made between the EU and UK. We already hold NoBo status in several major EU27 countries. We are expanding these approvals to replicate the appointments LR holds in the UK. We have already submitted applications for the following directives in the Netherlands:

  • Construction Products Regulation (CPR)
  • Pressure Equipment Directive (PED) [Excluding the requirements of Article 20 & Annex I para 3.1.3]
  • ATEX (File Retention Only)
  • Noise Emissions Directive (NED)
  • Machinery Directive (MD)
  • Simple Pressure Vessel Directive (SPVD)
  • Rail Interoperability Directive (RID)

In addition to pursuing EU NoBo appointments to maintain support for our clients to access the European markets, we will also work closely with UK regulatory bodies to enable us to continue to support clients in accessing UK markets post-Brexit.

We are working closely with the RvA, the Dutch accreditation council, with which we have a longstanding relationship, to ensure that we remain as an EU recognised NoBo for EU Directives after the UK leaves the EU.

Management systems training and management systems accredited certification are unaffected by Brexit.

We will continue to provide updates as events unfold.

  • Will Lloyd's Register continue to provide Notified Body services in the EU after Brexit?

    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 are pleased to confirm that discussions with the Dutch Accreditation Council, Raad voor Accreditatie (RvA), have indicated that we are on track towards a successful transition of our Notified Body entity from the UK to the Netherlands before 29th March 2019.

    Due to the internal processes between RvA and the Dutch authorities, we expect to receive formal notification by the end of February at the latest. When our status as a Notified Body in the Netherlands is confirmed, we can continue to provide identical services to those currently provided through our UK Notified Body.

  • 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.

  • What steps do I need to take now to transfer certificates that will continue to be recognised by the EU?

    There are not immediate steps required. As we get close to achieving our formal notifications in the Netherlands, we will be in touch with our clients with further details of the transfer process. A key element in our approach is to ensure 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 from our UK Notified Body to our Dutch Notified Body will include the issue of new certificates bearing the new notified body number assigned to us in the Netherlands, which then fully replaces your existing certificate issued from our UK-based Notified Body.

  • How much will it cost to get new certificates?

    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.

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