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After the UK leaves the EU on 31st December 2020, products covered by CE marking legislation will need to have name and address details of companies in both the EU and the UK in order to be legally placed on the market.
This could be a significant impact to companies based in the EU who, until now, were able to use their own name and address in order to sell products to the UK.
In the absence of any UK company, the person selling the products in the UK becomes responsible as the "importer". For example, before Brexit a company based in France could simply sell products labelled with his name and address to shops in the UK. After Brexit, those shops in the UK will become responsible as an importer.
Shops, or "distributors" to use the legal definition, have few responsibilities under CE marking legislation. Typically, they have to comply with authorities requests, keep a track of products and make sure they don’t do anything to make products non-compliant. Importers however have much more responsibility, they need to have access to full technical documentation and their names and addresses must appear on the product/packaging.
It is important for all manufacturers to make sure that their UK distributors understand the issues. It is possible UK distributors may not want the responsibility of being an importer. For manufacturers there is a problem too, each UK customer might be considered a different importer – that means different product/packaging markings for each customer and having to share technical documents with multiple parties.
The solution is to appoint an Authorised Representative (AR). AR’s act as the manufacturers contact point in the UK, meaning they can keep control of the responsibilities and their technical documentation. At also means that only one UK name and address is needed.
Ice compliance can help. We offer an Authorised Representative Service for the UK market. You can use our details as the contact point, thus making sure your business can continue to run smoothly. Together with our consultancy service, we can make sure your products, packaging and technical documentation are ready for Brexit.
There are lots of question around brexit, many of which are still unanswered. Please feel free to give me a call to talk through all of the issues and options - I'll do my best to answer all the questions you have.
There is no doubt that Brexit will cause confusion and extra work, but Ice Compliance can help make it as simple as possible.
