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update:2020-03-11 NO.: DOC200302-01

Comments on the CE and UKCA Mark after Brexit

Before a deal is reached between the UK and the EU after Brexit, the following guidance will be applied to toys, and possibly to all CE marked products.

1.Regardless of the place of manufacture of the products, the requirements of the UK market:
  A.The UKCA mark will be the best option to show compliance with applicable UK regulations, though the CE mark will still be recognized in the UK market before January 1st, 2021..
  B.The UK will still recognize EU Notified Bodies before January 1st, 2021.
  C.The applicable scope of the UKCA mark will be the same as that of the CE mark, since the New Approach CE marking Directive has been transposed into UK law, so do the other applicable EU testing standards (usually ENs).
  D.There will be a specific Directive/Regulation or the General Product Safety Regulations for Non-CE marked products.

2.Regardless of the place of manufacture of the products, the requirements of the EU market:
  A.There is no change on the requirements of the CE mark.
  B.The EU will not recognize the UKCA mark nor UK Notified Bodies.
  C.The UK supplied toys should bear their company name and address. The EU distributors of UK supplied products will take on the tasks and responsibilities of the EU importers, not that of the distributors anymore.

3.Regardless of the place of manufacture of the products, the requirements of both the UK and EU markets:
  A.In future, both the UKCA mark and the CE mark will be needed for the "New Approach" products intended for both the UK and EU markets, since both markets will recognize their own mark and their own Notified Bodies only.

The above related to the products applies to both "self-certified" New Approach products (including if a third-party test lab has been used) and products where a Notified Body has been involved.

For more information, please check below information:
https://www.gov.uk/guidance/uk-product-safety-and-metrology-in-a-no-deal-brexit#toys
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/835271/toys-regulations-2011-no-deal-brexit-guidance.pd


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