Brexit Impact

UK Manufacturers & Brexit

A hot topic of discussion in the recent press relates to current Brexit negotiations, and how any result may impact UK appliance manufacturers confirming compliance with current or new legal requirements should the UK leave the European Union (EU) without a deal on October 31st. It is important for HETAS approved manufacturers to be aware of their impending responsibilities should any significant changes take place and a “No Deal” situation reached.

Downing Street Sign

Possible Changes

There are a wide number of factors that will need to be considered by appliance manufacturers when preparing for Brexit, however HETAS has highlighted below some of the immediate key changes highlighted by government, which includes some potential changes to the way in which manufacturers are required to CE mark products against any new UK specific regulations launched. These potentials if a no deal Brexit situation is reached include;

  • The UK will adopt the Construction Products (EU Exit) Regulations 2019 which will come into force on the exit day.
  • All existing harmonised EN standards for solid fuel appliances which are mandated against the current CPR will become UK designated standards to the CPR (EU Exit) regulations. In the short term, the UK will adopt identical requirements to their European equivalent, including the current BS EN test series of series and is likely to include any standards under immediate development i.e. BS EN 16510-1.
  • The UK will look to adopt a new UK recognised conformity assessment mark for products specifically sold within the UK market (UKCA), a similar process to the EU CE mark but with additional requirements. 
  • Construction products currently affixed with EU CE mark will be able to continue to be sold as appropriate for a time limited period. This time period is only short term, and deadlines are not currently specified by legislation so it is important that contingency plans are put in place in case of any short turnaround times.
  • UK notified bodies will be granted a new “UK approved body” status and listed on a UK specified database and be able to undertake assessment against UK standards. They will however lose status as EU recognised NB and undertake assessment against EU only standards from the withdrawal date.
  • Rules around affixing the new UK conformity mark will remain the same as current CE mark, require 3rd party assessment by an independent test facility, a UKCA data plate to be drawn up and a Declaration of Performance to be issued. Once these are completed, the UKCA can be affixed.
  • Manufacturers will not initially need to use the new UK mark if they are in compliance with EU CE mark, and have had the product tested by an EU recognised notified laboratory. Again, this is time limited without any current stipulated guidelines.

Further information on Brexit and manufacturer responsibilities can be found on the technical area of HETAS at or via email at

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