The current situation is that if you are reselling the goods then you are placing them on the market whereby you will be considered to be the importer (if you have contract with the manufacturer detailing specific undertakings) or you will be considered to be the manufacturer outright. (There are two other functionaries who could be used in this situation, one of those being an Authorised Representative. Further information is given on our website). If the products do require CE marking, then this must be performed and completed before being placed on the UK (or EU) market.

If the item is expressly for your own use, then you are neither placing it on the market (see previous paragraph) nor putting it into service and so you do not need to do anything. If you are putting it into your own workplace for others (e.g. employees) to use, then it must be CE marked (if applicable) and also satisfy the in-service requirements concerning the minimum health and safety requirements for the use of work equipment by workers at work.

Last updated: 2021-07-09 12:24

In selling to the EU, there is no requirement, under normal circumstances, for you to send your Technical File to a European Authority unless you are requested to do so by them - and that, normally, will only take place when there are sufficient grounds for them to ask for it.

When selling to the EU, you will now need to comply with 2019/1020, the ‘MSA Regulation’. MSA stands for Market Surveillance Authorities. (In the UK, the MSA are such bodies as Trading Standards or the HSE). As there is no longer a link between the UK and the EU, any matters arising concerning product safety issues (e.g. product recalls) in the EU will be orchestrated by one of the EU MSAs; Trading standards will not become involved.

The EU MSA will seek contact with the ‘economic operator’ of the manufacturer in order to resolve any product safety issues. It is a mandatory requirement that if the manufacturer themselves are not established in the EU, then they must have a representative that is. This can be an authorised representative, who is one of four possible economic operators. Our sister company, Authorised Representative Service, provides this function if you would like more information on this subject.

Last updated: 2021-07-09 12:12

CE Marked and / or UKCA marked products are acceptable in GB (England, Scotland and Wales) until the January 1st 2022. After that date, all products sold in GB will need to carry the UKCA mark.

Goods being sold in Northern Ireland will need to be CE marked. Manufacturers in NI will make and sell their products using the CE mark but, as they are part of the UK, they can also sell their CE marked products in GB. Those products do not need to be UKCA marked.

Hence, in GB in 2022, you will only be able to buy/sell a product that is UKCA marked unless it was manufactured in NI, where a CE mark is acceptable.

Last updated: 2021-07-09 12:10