The future of UK standards post-Brexit April 2021

As the dust settles on the EU-UK Trade and Cooperation Agreement, there is still significant uncertainty as to what the implications of the agreement will be and how this may affect business.  

Up until the end of last year the UK continued to trade within the single market, allowing the free movement of products on the basis they carried a CE mark where applicable. CE marking is a manufacturer’s declaration that a product complies with European health, safety, and environmental protection legislation, and applies to a distributor if they are placing the product on the market.   In total there are 21 directives that cover CE marking, and products may be covered by more than one Directive or Regulation.

As of 1 January 2021, the UKCA (UK Conformity Assessed) mark replaced CE marking in the UK, except in Northern Ireland.  Taking the Construction Products Regulations (CPR) as an example, the UK enacted the Construction Products (Amendment etc.) (EU Exit) Regulations 2020, which imported the EU Construction Regulations into UK domestic law, with various amendments to be consistent with the UK’s status as a former EU Member State.  Key changes include the introduction of a new Approved Body status for UK Notified Bodies and importing existing harmonised European standards into UK law, now known as “designated standards”.

Under the CPR, products already placed on the UK market can continue to be sold with a CE mark until 1 January 2022 to give businesses time to adjust, at which point products being sold will need to comply with the requirements of the UKCA mark.   For some product types there will be a requirement for retesting, likely in accordance the same standard for CE marking requirements, with the only difference being one is referenced as a harmonised European standard and the other a designated standard.

From a standards perspective, an extension of the UK’s membership (through BSI) of CEN (The European Committee for Standardization) -CENELEC (European Committee for Electrotechnical Standardization) was agreed in February 2020 under a transition agreement until 31 December 2021.   This extension allows more information to be gathered on the political situation within the EU and the UK, and its impact on market access through standards, and at the time of writing there has been no confirmation as to what the shape of the UK’s membership will be.

Interested in finding out more on the impact of your products or testing requirements? please contact us at:

European sales enquiries: BSRIA UK: ¦ +44 (0) 1344 465 540

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