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This topic provides a high level overview of Brexit, focusing particularly on the impact of Brexit on our regulatory landscape.



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Content Overview

Brexit refers to the withdrawal of the United Kingdom from the European Union (EU) and the European Atomic Energy Community. On 31 January 2020, the UK left the EU and entered a transition period. On 31 December 2020, the transition period ended and the United Kingdom left the EU single market and customs union.

The EU-UK Trade and Cooperation Agreement was agreed upon in December 2020, and this agreement entered into force on 1 May 2021. A number of EU Exit Regulations were enacted to remedy deficiencies in retained EU law post-Brexit. This topic does not cover export, import or customs related laws.

Special rules apply to Northern Ireland, especially regarding product safety because of the Northern Ireland Protocol. The Northern Ireland Protocol came into force on 1 January 2021. For as long as it is in force, Northern Ireland will align with relevant EU rules relating to the placing on the market of manufactured goods.

Brexit has had a significant impact on product safety markings. As a result of Brexit two new markings have been introduced:

  • UKCA: The UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.
  • UKNI: The UKNI marking is a new conformity marking for products placed on the market in Northern Ireland which have undergone mandatory third-party conformity assessment by a body based in the UK. This mark is to be accompanied with the CE mark.

Coverage Included

Our regulatory content in C2P is historically comprehensive with a robust QA process to ensure quality, consistency and accuracy. Below is a high level summary of our coverage for this topic:
  • UK: European Union (Withdrawal) Act 2018 “Great Repeal” Bill
  • UK: REACH etc. (Amendment etc.) (EU Exit) Regulations, SI 2019/758
  • UK: Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations, SI 2019/696
  • UK: Construction Products (Amendment etc.) (EU Exit) Regulations, SI 2019/465
  • UK: Communications Act (e-Commerce) (EU Exit), Draft Regulations, July 2020
  • UK: Ecodesign for Energy-Related Products and Energy Information (Amendment) (EU Exit) Regulations, S.I. 2019/539
  • EU: EU-UK Trade and Cooperation Agreement, December 2020
  • Placing manufactured goods on the market in Great Britain, Guidance Document, December 2020
  • Placing manufactured goods on the market in Northern Ireland, Guidance Document, December 2020

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