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?
We have made applications for Marine Equipment Directive (2014/90/EU) in the Netherlands for NoBo approval for Lloyd's Register Nederlands BV. The application is currently being assessed and we will provide updates here when more information is available.
We intend to provide identical services to those currently provided through our existing entity in the Netherlands: Lloyd's Register Nederlands BV.
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 all necessary measures to enable us to continue to support our clients, by obtaining Notified Body appointments within the EU27.
New UK Approval Regime
The UKCA mark regime came into effect when the Brexit transition period ended on 31 December 2020.
On this date, Lloyd’s Register Verification Ltd (LRV) became a Conformity Assessment Body (CAB) for the UK regulatory system, offering Conformity Assessment services for equipment requiring the UKCA mark.
LRV's UKCA number is 0038 with the scope of services listed on a new UK government domestic database which has replaced the EU’s NANDO database in the UK.
Please note that from 1 January 2021:
- The UK government introduced a ‘standstill’ period which means that from 1 January 2021, the UK accepts compliant equipment marked with either the CE mark with an EU NoBo number, or a UKCA mark with a UK Conformity Assessment Body number. This arrangement will cease on 31 December 2021.
- Manufacturers selling exclusively to the EU need to ensure equipment is CE marked.
- Equipment can be dual certified and marked accordingly with both the UKCA and CE marks, subject to the relevant contractual arrangements being in place with a UK Conformity Assessment Body and with an EU NoBo.
- Manufacturers selling exclusively to the UK market can use the UKCA mark immediately after 31 December 2020.
Please note that from 1 January 2022:
- UK government regulations will only allow equipment to be used if it has a UKCA mark along with a UK approved CAB number.
- Manufacturers selling exclusively to the UK need to ensure their equipment is UKCA marked. We are pleased to be able to support you with this service.
- Manufacturers selling to both the UK and the EU need to both UKCA and CE mark their equipment.
Please note that until 1 January 2023:
MED approved equipment can continue to be placed on UK ships.
Brexit impact in relation to EU Recognised Organisation status
In the marine sector, we are an EU Recognised Organisation (RO) and were required to be sponsored by an EU member State (for the purposes of ensuring compliance with Regulation (EC) No 391/2009, Article 8, previously gained this sponsorship through the United Kingdom.
The amendments to Regulation 391/2009 to remove the need for a sponsoring State entered into force on 28 March 2019.
With this amendment, LR automatically continues to enjoy its recognition following Brexit. Surveys and certificates for EU member States flagged ships, conducted and issued by us on behalf of the flag, remain wholly unaffected. Additional surveys are not necessary, nor is there a need to reissue any statutory Certificate.