On 10 January, the European Commission issued a notice to stakeholders - Withdrawal of the United Kingdom and EU rules in the field of industrial products. Although negotiations between the UK and the EU are still in process, the European Commission’s current position is that UK Notified Bodies will lose their status as EU Notified Bodies from March 2019.
We would like to take this opportunity to assure our clients that LR will seamlessly provide support through any changes to the regimes under which we all operate. We are taking action to mitigate risks and deal with the range of possible outcomes related to Brexit negotiations. There are two areas of our activity that could be impacted by the UK’s exit from the EU:
1. EU Notified Bodies
LR’s status as an EU Notified Body is particularly relevant to our assurance and inspection work performed under various EU Directives and Regulations and to our services to the marine and offshore sector (see table below). Although Brexit negotiations could result in arrangements under which the UK continues to operate its own Notified Bodies, we are actively preparing for the possibility that UK Notified Bodies will lose their status as EU Notified bodies from March 2019.
LR already holds Notified Body status in several major EU27 countries. We are expanding these approvals to replicate the appointments LR holds in the UK. The majority of these new appointments will be in the Netherlands. We have already submitted several applications including the Medical Devices Directive and the In Vitro Diagnostic Devices Directive. The first of these additional Notified Body appointments (for the Lift Directive) was granted by France in November 2017.
In addition to pursuing EU Notified Body 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.
2. EU Recognised Organisation in the maritime sector
In the marine sector, LR is a EU Recognised Organisation and is required to be sponsored by a EU Flag (for the purposes of ensuring compliance with Regulation (EC) No 391/2009, Article 8, paragraph 1). In May, LR agreed with the Danish Maritime Authority to have its sponsorship moved from the UK to Denmark, thereby assuring our ability to continue to act as a EU Recognised Organization post-Brexit. Marine Classification Societies with Recognised Organisation status, based in Non-EU Member States, have also been required to obtain sponsorship by an EU Flag outside of the country where they are principally based (in order to ensure compliance with the Regulation). We, therefore, firmly expect to obtain agreement from the European Commission and are progressing this final step in the process.
LR will keep you up to date with regards to our services as the EU negotiations advance.
In the meantime, if you would like to discuss a particular aspect of our service or our position, please get in touch with your client manager or Tom Boardley, Executive VP and Global Head of Corporate and External Affairs (firstname.lastname@example.org).
LR has submitted applications for Notified Body appointments in major EU27 countries for the following EC/EU Directives:
- Pressure Equipment Directive (PED) - 2014/68/EU
- Transportable Pressure Equipment Directive (TPED) - 2010/35/EU
- Simple Pressure Vessel Directive (SPVD) - 2014/29/EU
- Equipment and protective systems intended for use in potentially explosive atmospheres (ATEX) - 2014/34/EU
- Noise Emission in the environment by equipment for use outdoor (NED) - 2000/14/EC
- Construction Products Regulation (CPR) - Construction Products Directive Reg (EU) - 305/2011
- Marine Equipment Directive (MED) 2014/90/EU Common Safety Method (CSM) EU Reg. - 2004/49/EC
- Rail Interoperability Directive 2008/57/EC Machinery Directive (MD) - 2006/42/EC
- Medical Devices Directive - 93/42/EEC
- In Vitro Diagnostic Medical Devices Directive - 98/79/EC
- Personal Protective Equipment Directive - 89/686/EEC
- Lifts and Safety Components For Lifts Directive - 2014/33/EU