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Brexit impact in relation to Marine and Industrial Equipment Directive

Lloyd's Register is committed to providing the best service we can to all of our clients; operating and communicating with integrity at all times. We remain resolute in our drive to work collaboratively with businesses and organisations around the globe to make the world a safer place. We will continue to keep you updated with new developments as and when they occur.

On 1 February 2020, the UK entered into a ‘departure transition period’, which is designed to give both the UK and EU some breathing space while a new trade agreement is negotiated. This period is due to last up to 31 December 2020.

During this time, the EU Notified Body (EU NoBo) services we currently provide to your business remain unaffected.

We will do everything we can to help our clients retain their access to EU and UK markets. As negotiations progress through the transition period, 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:

  • Pressure Equipment Directive (PED) in Germany (Lloyd’s Register Deutschland GmbH EU NoBo number 0525), Spain (Lloyd’s Register España EU NoBo number 0094) and the Netherlands (Lloyd’s Register Netherland BV NoBo number is 0343)
  • Lifts Directive in France by COFRAC: our NoBo number 2748
  • Transportable Pressure Equipment Directive (TPED) in the Netherlands (Lloyd’s Register Netherland BV, NoBo number 0343)
  • Construction Products Regulation (CPR) in the Netherlands (LRV B.V. EU NoBo number 2814)
  • Machinery Directive (MD) in the Netherlands (LRV B.V. EU NoBo number 2814) and Spain (Lloyd’s Register España EU NoBo number 0094)

We are progressing notified body appointments for the following directives and regulations:

  • ATEX (File Retention Only)
  • Simple Pressure Vessel Directive (SPVD)

With regards to Marine Equipment Directive (MED), we are progressing a recommendation from the German Body, BSH to the EU for the notified body appointment for Lloyd’s Register Deutschland GmbH.

We are also in the process of extending the scopes of accreditation to cover our current service offerings with our German Notified Body, Lloyd’s Register Deutschland GmBH and our Spanish Notified Body, LR España to cover all eventualities.

New UK Approval Regime

In addition to pursuing EU NoBo appointments to maintain support for our clients to access the European markets, we are also working closely with UK regulatory bodies to continue to support clients in accessing UK markets post the transition period under the UKCA regime

The UKCA mark regime will come into effect when the Brexit transition period ends on 31 December 2020.

On the 31 December 2020, Lloyd’s Register Verification LRV Ltd) will become a Conformity Assessment Body (CAB) for the UK regulatory system, after which we can offer Conformity Assessment services for equipment requiring the UKCA mark. The scope of services will reflect that currently listed for LRV Limited on the NANDO website. LRV's UKCA number will be 0038.

Please note that from 1 January 2021:

  • The UK government will introduce a "standstill" period which means that from 1 January 2021, the UK will accept compliant equipment marked with either the CE mark with an EU27 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 EU27 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 from a UK Conformity Assessment Body and EU Notified Body.
  • 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 EU27 need to both UKCA and CE mark their equipment if there is no Mutual Recognition Agreement (which is still in discussion between the UK and the EU27).

Please note that until 1 January 2023:

MED approved equipment can continue to be placed on UK ships.

We are also supporting the UK/EU negotiating team in building a case for a Mutual Recognition Agreement to include the activities of Conformity Assessment Bodies.

  • How long will my existing Lloyd's Register certificates remain valid for?

     The UK is currently in a ‘departure transition period’, which is designed to give both the UK and EU some breathing space while a new trade agreement is negotiated. This period is due to last up to 31 December 2020.

    During this time, the EU Notified Body services we currently provide to your business remain unaffected and you can continue to use the CE mark and our Notified Body No: 0038.

    Post Brexit, 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.

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

    We are working with affected customers to transfer their current certificates to an alternative LR EU NoBo.

  • 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.

    Post Brexit, 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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