Brexit affecting parts from EU
- Thread starter Shaun Witts
- Start date
Fair enough Dave. I would call it sarcastic, but it is completely factual. I'll be writing something similar but without the snark for our clients.
Dear mods, the following is not political, it is a description of the realities of the UK-EU Trade and Co-operation Agreement for manufacturers of certain goods. But I accept you may feel it does not belong here, so in that case please feel free to delete.
(PS. Do not use the following as a guide if you are a manufacturer affected by these changes. Get some proper bloody advice!)
OK Robert, you asked for it!
Say you make something covered by an EU regulation or directive, that needs 3rd party assessment, like PPE, a construction product, or a pressure device. Up until 31st December, you got your certificate and applied the CE mark. Job done.
From 1st January it all changes. And it doesn’t change but also changes most in Northern Ireland.
So, you want to sell your FFP2 mask in the European Union (EU), which now obviously does not include the UK. OK, you still need a CE mark. Is your certificate from an EU27 (not UK) body? Yes? Good, carry on CE marking.
Oh, you had a UK certificate? Oh sorry, no CE mark for you. Did you transfer it to an EU27 body? No? tough, get a new one.
Ah, but you want to sell in the UK as well. Congratulations, your UK certificate can be used in the UK. Except you have to change all your labels and remove the CE mark, and put on the UKCA mark. User Information and Declarations? Yes please, all changed. Oh, we’ll let you off doing it all straight away, as long as everything has a piece of paper with the UKCA mark we’ll let you have 2 years to change the markings. Except for some things.
Ah, but you DO have an EU27 certificate? That’s all right then! You can still CE mark and sell it in the UK! For one year! That’s right, you can sell your Concrete flue liners until December 31st 2021, and then you will have to get a second certificate from a UK body, and use the UKCA mark. Two certificates, two marks, two sets of paper. Easy peasy.
Oh wait, we forgot Northern Ireland. You see, when I said UK, I didn’t really mean the United Kingdom of Great Britain and Northern Ireland. I mean Great Britain. The big bit, England and Scotland and Wales. Yes, to sell in Great Britain you need a UK conformity assessment approval and to use the UKCA mark. Not a Great Britain approval, with a GB mark, oh no, it’s a UK mark.
Northern Ireland has its protocol, because of the Good Friday Agreement. Which means no land border. Which means, that it still follows some EU rules. And that means that the CE mark is accepted. That’s right, with your EU27 certificate you can CE mark your steam boiler and sell it in Northern Ireland.
Ah, but what about all those UK (sorry) GB businesses supporting UK test houses? That’s alright, Northern Ireland is also following the UK rules as well as the EU rules. You can sell your product in Northern Ireland. With a CE mark. But not just a CE mark, a CE mark AND a UK mark. And not just any old UK mark, but a CE mark with a UK(NI) mark. That’s right, with a UK certificate you can CE mark your steel joist as long as you put those magic letters after it. But don’t try and sell it in the Republic with that mark on. Or in the UK (sorry) GB. Oh no.
Ah, but what if you are actually IN Northern Ireland? And you make what is known as a Northern Ireland qualifying good? Well, congratulations, the best of both worlds! If you have an EU27 certificate, you can sell your Fire suit in NI, and of course in the rest of the EU. Ah but wait, didn’t Boris promise ‘unfettered access’ to the UK (sorry) GB market? Yes he did! So, you have a CE marked commercial grade carpet, which you can sell in the rest of the UK (sorry) Great Britain! That’s right, a NI business CE marking NI qualifying goods with a French (or German, Spanish, Polish, Slovenian…) certificate can continue to sell CE marked bursting discs long after your competitors have had to get a UK certificate! Huzzah!
Welcome to my world.
Great post, it’s good to get some insight into how this whole murky world actually works from someone involved in the nitty gritty.
As further details have emerged, it seems likely that stuff ordered from EU might be getting cancelled either because it now all requires a Customs declaration (even if no duty is being charged) or because anyone selling into the UK (or should that be GB?) must apparently collect the UK VAT on behalf of the UK government.
Or perhaps both.
Or perhaps both.
Been thinking about this since last night , so just want to apologise to anyone who has taken offence or thinks that I am taking sides.
This has been 4 1/2 years waiting for me, to find out on Boxing Day what was and was not agreed.
Apologies again for the rant and the tone, but that is what the legislation and the deal actually say.
This has been 4 1/2 years waiting for me, to find out on Boxing Day what was and was not agreed.
Apologies again for the rant and the tone, but that is what the legislation and the deal actually say.
As this is now UK law surely it’s no longer a political discussion, but a discussion on the realities of how we in the UK can source parts as members of the global community. Surely, we are in no worse position than those members in Australia when it comes to getting VW parts? (Although with cheaper delivery hopefully!)
Dear mods, the following is not political, it is a description of the realities of the UK-EU Trade and Co-operation Agreement for manufacturers of certain goods. But I accept you may feel it does not belong here, so in that case please feel free to delete.
(PS. Do not use the following as a guide if you are a manufacturer affected by these changes. Get some proper bloody advice!)
OK Robert, you asked for it!
Say you make something covered by an EU regulation or directive, that needs 3rd party assessment, like PPE, a construction product, or a pressure device. Up until 31st December, you got your certificate and applied the CE mark. Job done.
From 1st January it all changes. And it doesn’t change but also changes most in Northern Ireland.
So, you want to sell your FFP2 mask in the European Union (EU), which now obviously does not include the UK. OK, you still need a CE mark. Is your certificate from an EU27 (not UK) body? Yes? Good, carry on CE marking.
Oh, you had a UK certificate? Oh sorry, no CE mark for you. Did you transfer it to an EU27 body? No? tough, get a new one.
Ah, but you want to sell in the UK as well. Congratulations, your UK certificate can be used in the UK. Except you have to change all your labels and remove the CE mark, and put on the UKCA mark. User Information and Declarations? Yes please, all changed. Oh, we’ll let you off doing it all straight away, as long as everything has a piece of paper with the UKCA mark we’ll let you have 2 years to change the markings. Except for some things.
Ah, but you DO have an EU27 certificate? That’s all right then! You can still CE mark and sell it in the UK! For one year! That’s right, you can sell your Concrete flue liners until December 31st 2021, and then you will have to get a second certificate from a UK body, and use the UKCA mark. Two certificates, two marks, two sets of paper. Easy peasy.
Oh wait, we forgot Northern Ireland. You see, when I said UK, I didn’t really mean the United Kingdom of Great Britain and Northern Ireland. I mean Great Britain. The big bit, England and Scotland and Wales. Yes, to sell in Great Britain you need a UK conformity assessment approval and to use the UKCA mark. Not a Great Britain approval, with a GB mark, oh no, it’s a UK mark.
Northern Ireland has its protocol, because of the Good Friday Agreement. Which means no land border. Which means, that it still follows some EU rules. And that means that the CE mark is accepted. That’s right, with your EU27 certificate you can CE mark your steam boiler and sell it in Northern Ireland.
Ah, but what about all those UK (sorry) GB businesses supporting UK test houses? That’s alright, Northern Ireland is also following the UK rules as well as the EU rules. You can sell your product in Northern Ireland. With a CE mark. But not just a CE mark, a CE mark AND a UK mark. And not just any old UK mark, but a CE mark with a UK(NI) mark. That’s right, with a UK certificate you can CE mark your steel joist as long as you put those magic letters after it. But don’t try and sell it in the Republic with that mark on. Or in the UK (sorry) GB. Oh no.
Ah, but what if you are actually IN Northern Ireland? And you make what is known as a Northern Ireland qualifying good? Well, congratulations, the best of both worlds! If you have an EU27 certificate, you can sell your Fire suit in NI, and of course in the rest of the EU. Ah but wait, didn’t Boris promise ‘unfettered access’ to the UK (sorry) GB market? Yes he did! So, you have a CE marked commercial grade carpet, which you can sell in the rest of the UK (sorry) Great Britain! That’s right, a NI business CE marking NI qualifying goods with a French (or German, Spanish, Polish, Slovenian…) certificate can continue to sell CE marked bursting discs long after your competitors have had to get a UK certificate! Huzzah!
Welcome to my world.
Good way of pointing out that half the people that are struggling including those in the EU are the ones that should have pulled their finger out their....... and got it done/arranged sooner. The UK gov has been spending a fortune advertising on pretty much all platforms to ensure UK businesses are ready. I expect (cannot confirm) the EU countries have been doing the same.
Lets not forget the same regs would have been needed if we did not get a deal. Let me just say I am not pointing the finger at anyone as I know its all been up in the air with mis information but for years we have known we were leaving, not staying. I just hope.... actually I know those who are struggling WILL get it sorted as they are brains and backbones of the country. Keep it up guys.
I do however feel for those manufacturers who have a huge amount of stock that does not meet regs but then again they have had a long time to get it shifted.
Brexit was always going to bring problems and stop some things. I wanted some parts (not car parts) and again they would not sell to the UK. They said they expect it to be the case until the end of January until they get everything sorted BUT wake up..... do you really need to buy it from that company or from that country. If they will not sell to you buy elsewhere. We just have to cope with it the best we can. Annoying I totally understand.
Last edited:
It's all very well to say various people/companies had plenty of time to prepare, but every single company I have dealt with in the last few months has said the same. There was scant information, and what there was, was constantly changing and often incorrect legally and practically.
Anyhoo, just opened an email this morning confirming my suspicions, that a 6 week job in France and Italy this summer is off. The job is still happening, but it will be crewed by non UK technicians. Great. Just looking at chat on various Whatsapp groups, and we reckon thats about 2000 people losing work. That's quite a lot of tax revenue lost to HMRC.
Anyhoo, just opened an email this morning confirming my suspicions, that a 6 week job in France and Italy this summer is off. The job is still happening, but it will be crewed by non UK technicians. Great. Just looking at chat on various Whatsapp groups, and we reckon thats about 2000 people losing work. That's quite a lot of tax revenue lost to HMRC.
UN. NATO . CE...then IMDG IATA CFR ... if I remember years back you where allowed to use items or regulations as long as it meet minimum standards to keep trade moving and lots of safety gear was test to an international standard recognised by most countries
Common Sense.....what’s that ......Pandora’s box has been open’d
Common Sense.....what’s that ......Pandora’s box has been open’d
I agree, and describing the real difficulties you're having as a business owner isn't political, it's factual, however, predictions of doom and gloom and long term economic damage from Brexit are just conjecture and one sided at that. As you rightly say, we are fortunate to live in a country with freedom, and countries like that have referendums on important matters and accept the results of referendums.
Having worked around the world I don’t think anything will be as bad as trying to import into India and Brazil. Weeks of questioning on COO of each component, what is the percentage of each material by weight in the assembly. Not uncommon for it to drag on for 6 months. I think if my history is correct we gave India bureaucracy, it keeps people in jobs.
Just carried out a search on Tyreleader on two sizes of tyre that I use on the van.
When I've purchased sets of tyres from this site before, the tyres came from dealers on the continent. There's a marked hit reduction on the number of brands and tyres now available, in these two sizes, whether it be summer, winter or all season tyres, when compared to previous searches on the site, pre brexit.
When I've purchased sets of tyres from this site before, the tyres came from dealers on the continent. There's a marked hit reduction on the number of brands and tyres now available, in these two sizes, whether it be summer, winter or all season tyres, when compared to previous searches on the site, pre brexit.
Just as a footnote, tried the same searches using tyreleader.ie (Irish site) instead of tyreleader.co.uk . Low and behold, all the original pre brexit options are there.
Too early to say whether they’ll reappear I suppose, but could be something to do with this?
EU firms refuse UK deliveries over Brexit tax changes
Some EU specialist firms stop delivering to the UK because of tax changes that took effect on 1 January.
www.bbc.co.uk
My favourite one.
Funnily enough, I was doing exactly the the same thing last night, looking for tyres for the car. Type in .de or .fr and low and behold the full range. A bit odd really, and a bloody shame as all of the big name online tyre sellers are EU based.