Yes. Another. I am sorry.
Following on from the REACH post below, you can see the UK have been busy publishing draft regulations ready for a withdrawal. Very Busy!
Clicking on the hyperlink above will take you the page of all of the draft regulations the UK has been busily preparing.
It seems that these drafts prepare us for a "hard exit" - where the UK is no longer part of the EU, its institutions and regulatory bodies. It separates us from things like ECHA and the framework for the marketing of goods. As best as I can tell, they transpose EU law exactly, warts and all, but demand UK specific implementation where it was previously EU wide, such as:
A UK importer address will be needed
A UK responsible person is needed
UK specific registrations are needed after Brexit day
UK notified body activity will no longer be valid for the EU
A UK mark in place of the CE mark
Of course, the EU told everyone about this last year...
What should I do?
Don't Panic! It is the UK's stated intention that all of the regulations should remain the same and, from the small bits I have read, it seems they are sticking to that promise. It also seems they are trying to implement an 18 months period of transition, wherever they can.
If a product was safe under the meaning of the law before, it will remain safe under the meaning of the law after.
I recommend the following:
Map the EU regulations that you currently need to comply with
Consider who is the responsible entity: importer manufacturer etc
Consider how the EU will treat you after Brexit (will you need a new address since your current one is in the UK?)
Consider how the UK will treat you after Brexit (will you need a new address since your current one is in the EU)?
Look at registrations, notifications and other EU input and be prepared to copy the same into any new UK framework
Ensure your EU products are properly labelled - Some EU member states may start enforcing quickly
Hold tight on making changes to UK products, the UK are yet to finalise the regulations and we don't know what the UK mark will look like yet
If you haven't done this sort of exercise, you must do it now. I'm afraid to say that the "unlikely event of no deal" is becoming more likely day-by-day.
Happy Brexiting!
Photo by John Cameron on Unsplash