UK: Brexit

What Impact Will Brexit Have on Standards and Compliance for Hazardous Area Industries?

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Will the UK still be able to have input into the European and International standards?

Generally as these standards become available or go through a maintenance update, they are harmonised into the European standards Cen or Cenelec for IEC electrical standards. These standards are then adopted by EU member states (in the UK they are adopted as a British Standard). Occasionally there will be notes at the beginning of a standard for local requirements, these can be numerous in some countries, but are becoming unusual in the UK. Generally we are very well represented on standards committees, and any problems we foresee in a standard are normally solved at the committee stage. Standards are not a legal requirement, but they normally help manufacturers and users meet their legal obligations. They also create a high standard of best practice for products and create a level playing field for products entering a market and a standardisation of products produced for that market.

Will our notified bodies for Potentially Explosive Atmospheres retain EU notified body status after Brexit?

This is an important issue. The EU has 67 notified bodies in this segment. Eight of them are in the UK, compared to twelve in Germany, ten in Italy, six in Poland, and three in Turkey, other EU members such as France have two, one, or no notified bodies.


Turkey is perhaps the exception that proves the rule, which may help Brexit negotiations. Turkey is not even a member of Efta, but this decision was issued by the Customs Union Joint Committee in document 2006/654/EC for “the elimination of technical barriers to trade in a particular product” and facilitate the progress of Turkey’s application to join the EU”. This does ring alarm bells if we have declared that we are leaving the Customs Union. The current UK notified Bodies will require a similar decision from the Customs Union Joint Committee to the one above. The notified bodies in the UK are well respected internationally and have a wealth of technical experience. They do a large amount of business with European and international companies requiring Certificates of Conformity for Atex to sell their products in the EU. This includes products from America, China, and internationally, as well as those manufactured anywhere within the EU. Manufacturers not only require new prototypes testing, but continually modify and update their products. If this is to continue in the UK after Brexit, the sooner a Joint Customs Union Committee agreement is reached to clarify the situation, the better.

The UK notified bodies need to be at the front of the negotiation agenda once Brexit is formalised. There are 188 bodies listed by the EU, who can test and issue Certificates of Conformity with directives covering everything from Shipping and Rail to manufactured products, medicines etc. These range from the UK accreditation company Ukas to specialist companies like SGS Baseefa, an Aemt member. These bodies use their specific expertise to test for conformity with every mandatory Directive including Atex, Machinery Directive, Marine Equipment Directive, Pressure Equipment Directive, Lifts Directive, Low Voltage Directive, etc. The list is long and covers every area. To facilitate trade agreements with the EU, the UK Government will probably negotiate to abide by most of the directives, such as Atex.

The 188 bodies involved in testing and accreditation are world class companies employing staff with very specialist technical abilities. Many of them stand on International Standards Committees and facilitate a huge amount of international trade in the oil, chemical and other industries. It is imperative that the UK Government ensures that Brexit and a split from the Customs Union does not jeopardise the incredibly valuable work that these companies carry out internationally, and ensure that this industry, maintains its leading place on the world class stage.

There are many active groups looking after the interests of the industry, who will continue to communicate with the marketplace about developments and changes, as well as providing sensible advice to government committees. However, now is the time to address these issues.

The mechanisms are in place to continue to ensure compliance doesn’t become any more complex or onerous, and that our ability to do business successfully remains largely unaffected by this particular aspect of Brexit.

For information see EU Website