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Brexit impact in relation to Marine and Industrial Equipment Directive

We are committed to helping our clients navigate challenges resulting from Brexit, regardless of the outcome of the negotiation 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 (NoBo) Forums and strong relationships with government and industry, we are closely involved with developments.

We will do everything we can to help our clients 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.

We are firmly committed to remaining a major EU NoBo for Industrial and Marine Directives. 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 are already approved as a NoBo for the Lifts Directive in France by COFRAC: our NoBo number 2748.

We are progressing notified body appointments for the following directives and regulations 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)
  • Outdoor Noise Directive (OND)
  • Machinery Directive (MD)
  • Simple Pressure Vessel Directive (SPVD)
  • Rail Interoperability Directive (RID)
  • Marine Equipment Directive (MED)
  • Transportable Pressure Equipment Directive (TPED)

We recently obtained accreditation from the national accreditation council in the Netherlands, RvA, qualifying us for appointment as a NoBo. This enabled us to seek appointment by the various ministries in the Netherlands for the EU Directives listed below. The first of these applications was accepted by the Dutch ministry, which advised the EU Commission accordingly. Our appointment has subsequently been delayed by an objection submitted to the European Commission by an EU member government. LR is one of several companies impacted by similar objections.

We have been informed that the EC is now imposing stricter requirements on applications for all new EU Notified Body appointments in the Netherlands. Both the Dutch Accreditation Council RvA and the Dutch Competent Authority oppose this approach, but to challenge it would take many months.

Therefore, in close association with the Dutch Accreditation Council RvA and the Dutch Competent Authority, we are now implementing changes to the way we work to comply with the EC, which we anticipate will take six to eight weeks. When completed, we expect to receive notification well in advance of the 31 October Brexit date.

As soon as the EU Commission confirms LRV B.V.’s appointment as an EU NoBo, we will be provided with a new Notified Body number and will issue new certification.

New UK Approval Regime

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 expect to be appointed as a Conformity Assessment Body, the UK’s equivalent of a NoBo for the full range of Directives for which we are currently appointed.

As always, we will continue to keep you updated with new developments as and when they occur.

  • 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 current withdrawal date (31 October 2019).

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

    We are currently awaiting the outcome of the EU Commission investigation into the objection to our appointment as a NoBo. Once our appointment is confirmed, our clients will be able to transfer their current certificates from LRV Ltd to LRV B.V. Our NoBo 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.

  • How much will it cost to get new certificates?

    It is our intention to transfer clients’ approvals from our UK NoBo 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.

  • Will the use of the UKAS mark for accredited 9001 certificates still be recognised in Europe after Brexit?

    ISO 9001 certificates will remain globally valid, regardless of Brexit negotiations.

    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.

    If there is a “No Deal” Brexit scenario or a deal which does not allow the EU to continue to recognise UK based Certification Bodies then material manufacturers who use their ISO 9001 certification to demonstrate product conformity to the Pressure Equipment Directive will require their certification to be granted by a Conformity Assessment Body within the EU27 member states. As an organisation with multiple accreditations, including within the EU27, we can readily provide affected clients with an ISO 9001 certificate issued under EU27 accreditation.

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