When the citizens of the United Kingdom voted for their country to leave the European Union, they must not have been thinking about the self-inflicted damages they will be causing by no longer being part of the CE mark program. When the UK begins the transition from the EU on March 29, 2019, they will become an “exporter” to the European Union. Soon thereafter, the citizens will begin to realize what a disaster they have created for their own country.
UK will be an Exporter to the EU: Did anyone really think it through before they voted for Brexit? When they become an “exporter” to the EU, UK manufacturers will learn just what it means to have to clear customs to enter the EU. The virtual “Great Wall of Europe” created by the CE mark program will work to help keep UK products out of Europe in the same fashion that the rest of the world now experiences. No CE mark and no CE documentation means no entry. One example is shipments through the Chunnel Tunnel – how will that work since UK goods will no longer be allowed to freely enter France without inspection? France will need to prepare for routing all incoming UK Chunnel shipments through an EU customs inspection process that includes CE verification.
Isn’t the UK already CE Compliant? Yes and No. The only enforcement of the CE mark program is at the ports of entry for goods imported into the EU. So, although UK goods have been expected to comply since the beginning of the CE program, nobody has ever checked the accuracy and quality of UK CE documentation before. This concern is easily tested = UK manufacturers are encouraged to review their Technical Report Forms (TRF’s) that document compliance with the harmonized standards = do your TRF’s include comments for every clause? A high quality TRF has an explanation provided for every clause = how the product complies with the clause or why the clause is not applicable. Every clause! Now look at your TRF’s = are they “blank”?
Blank TRF’s with no details are undefendable in court and represent a large potential liability for the company. In addition, without the engineering rationale, the manufacturer cannot review each pass/fail/not-applicable decision presented by the test lab to insure that the manufacturer is in agreement with each compliance decision. Unfortunately, many CE labs inside the EU do not provide reports that include comments. This has been allowed to occur because there is no enforcement of the CE mark program to manufacturers producing products within the EU = free trade within the EU without inspection. As soon as the UK is on longer part of the EU, UK manufacturers will lose their free trade rights within the EU and suddenly be subjected to EU customs inspections and tremendously increased scrutiny by EU authorities. Keep in mind that the EU is not happy with the decision by the United Kingdom to leave the EU = it is not expected that the EU will provide an easy path for UK products to enter the EU. Consequently, UK manufacturers are strongly advised to immediately increase the quality of their CE Technical Report Files and the CE Test Reports they contain. Do not wait - you only have one year and this process will take time.
UK Losing their Notified Bodies? Oh no! What if you used a UK Notified Body for your CE compliance? If the UK is no longer part of the EU, guess what? The UK can no longer have its own Notified Bodies! Will the UK NB’s lose their accreditation? Will your CE-Notified Body issued certificates remain valid? UK manufacturers may want to develop a backup plan if this affects you.
No Goods on UK Shelves? The CE Mark program is also a tremendous benefit for EU consumers = freedom to purchase products made anywhere in the EU without taxes, tariffs, and importing fees. In addition, consumers can rely on the well-established CE mark program, to insure they purchase products that comply with regulatory requirements which most notably include product safety. But a complete exit from the EU includes the CE mark program.
How will the UK replace the CE mark program?
How long will that process take?
Will foreign manufacturers be willing to meet another/different set of compliance requirements, and potentially build a different version of their product, just to sell in the UK?
Clearly some manufacturers will abandon the UK market, but how many? Some foreign manufacturers will decide to sell in the UK but they will reduce their offerings. Consequently, Brexit could result in a substantial drop in available goods and available choices to consumers in the UK. Will this force the United Kingdom to accept CE marked products even though they are no longer part of the CE mark program? It would appear that the UK will have to accept the CE mark, at least through the Brexit transition period.
UK Manufacturers to Say Goodbye to 400 Million EU Consumers: One of the primary intents for establishing the CE mark program was to create a market the size of the North American market for the benefit of EU manufacturers. The CE Mark program has literally created a virtual “Great Wall of Europe” to protect the giant EU market for EU manufacturers. Free trade with 400 million consumers is a clear benefit for those manufacturers within the EU. Why would the United Kingdom throw away this huge benefit to become an island dependent on import/export with the EU?
Is it too late for the UK to vote again?
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