Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

From Wikipedia in 2008:

It [the EU] had initiated the procedure to register CE marking as a 
Community collective trademark 
<https://en.wikipedia.org/wiki/Trademark>, and was in discussion with 
Chinese authorities to ensure compliance with European legislation.^[21] 
<https://en.wikipedia.org/wiki/CE_marking#cite_note-21>


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-23 19:43, Richard Nute wrote:


The CE mark is a first-party certification mark.  It means the 
manufacturer believes the product complies with all applicable EU 
directives and has documentation to prove compliance.  (The EU 
requires compliance to applicable directives.)


Manufacturers all over the world who do business in the EU apply the 
CE mark to all their products, not just those going to the EU.  Any 
entity, government or private, anywhere in the world, can accept or 
require the CE mark on products.  (Some countries do not accept 
first-party certification.)  For example, Iceland, Lichtenstein, and 
Norway are not in the EU but require the CE mark.


I was unable to find that the CE mark symbol has a copyright.

Best regards,

Rich

*From:* Michael Derby 
*Sent:* Monday, January 21, 2019 2:25 AM
*To:* ri...@ieee.org; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* RE: [PSES] Brexit requirements for UK manufacturers.

Regarding this:

  * *CE mark*is replaced by *UK mark*.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark 
as indicative of the relevant performance of the product?


I’m sure the UK could choose to accept a compliance ‘effort’ of 
similar level to that needed to CE Mark (for the EU).


But, the UK cannot have the CE Mark as their own compliance mark.

To place products onto the market in the UK (from within the UK, or 
from elsewhere), the UK customs, consumers, surveillance, etc., would 
need to know if the device is safe and not likely to cause 
interference, so some sort of marking would be needed.   The UK cannot 
copy the CE Mark, because the CE Mark is copyrighted by the EU.


So also, the UK could not legally state “The CE Mark is also our own 
mark”, because non-EU regions cannot have compliance marks which could 
be confused with the CE Mark.


This becomes especially problematic if a product is only marketed in, 
or permitted in, the UK; not the EU.


Michael.

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Re: [PSES] Brexit requirements for UK manufacturers.

[Richard Nute]

 

The CE mark is a first-party certification mark.  It means the manufacturer 
believes the product complies with all applicable EU directives and has 
documentation to prove compliance.  (The EU requires compliance to applicable 
directives.)  

 

Manufacturers all over the world who do business in the EU apply the CE mark to 
all their products, not just those going to the EU.  Any entity, government or 
private, anywhere in the world, can accept or require the CE mark on products.  
(Some countries do not accept first-party certification.)  For example, 
Iceland, Lichtenstein, and Norway are not in the EU but require the CE mark.  

 

I was unable to find that the CE mark symbol has a copyright.

 

Best regards,

Rich

 

 

From: Michael Derby  
Sent: Monday, January 21, 2019 2:25 AM
To: ri...@ieee.org; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Brexit requirements for UK manufacturers.

 

Regarding this:

 

*   CE mark is replaced by UK mark.

 

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?  

 

I’m sure the UK could choose to accept a compliance ‘effort’ of similar level 
to that needed to CE Mark (for the EU).

But, the UK cannot have the CE Mark as their own compliance mark.

To place products onto the market in the UK (from within the UK, or from 
elsewhere), the UK customs, consumers, surveillance, etc., would need to know 
if the device is safe and not likely to cause interference, so some sort of 
marking would be needed.   The UK cannot copy the CE Mark, because the CE Mark 
is copyrighted by the EU.

So also, the UK could not legally state “The CE Mark is also our own mark”, 
because non-EU regions cannot have compliance marks which could be confused 
with the CE Mark.

 

This becomes especially problematic if a product is only marketed in, or 
permitted in, the UK; not the EU.

 

 

Michael.

 

 

 


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Re: [PSES] Brexit requirements for UK manufacturers.

[Michael Derby]

Regarding this:

 

*   CE mark is replaced by UK mark.

 

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?  

 

I’m sure the UK could choose to accept a compliance ‘effort’ of similar level 
to that needed to CE Mark (for the EU).

But, the UK cannot have the CE Mark as their own compliance mark.

To place products onto the market in the UK (from within the UK, or from 
elsewhere), the UK customs, consumers, surveillance, etc., would need to know 
if the device is safe and not likely to cause interference, so some sort of 
marking would be needed.   The UK cannot copy the CE Mark, because the CE Mark 
is copyrighted by the EU.

So also, the UK could not legally state “The CE Mark is also our own mark”, 
because non-EU regions cannot have compliance marks which could be confused 
with the CE Mark.

 

This becomes especially problematic if a product is only marketed in, or 
permitted in, the UK; not the EU.

 

 

Michael.

 

 

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 17 January 2019 18:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

 

*   CE mark is replaced by UK mark.

 

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?  

 

Rich  

 

 

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Re: [PSES] Brexit requirements for UK manufacturers.

[Richard Nute]

 

they don’t trust manufacturer self-certification

 

I hold a different opinion.  

 

UL was founded because the “Palace of Electricity” at the Columbian Exposition 
in 1893 in Chicago kept catching fire.  William Henry Merrill was hired by the 
insurance underwriters to investigate the causes.  Merrill then founded 
Underwriters Laboratories to test products. 

 

At about this time, jurisdictions enacted electrical codes.  Written into some 
of these codes was a requirement that electrical materials be tested by UL or 
Factory Mutual (FM).  UL then sought to have its testing and certification 
written into all of the US codes. 

 

Then came OSHA.  The requirement was that electrical equipment used in the 
workplace was to be certified by an NRTL.  This was a most expedient way of 
assuring electrical safety in the workplace.  

 

So, rather than lack of trust at the time, the USA had a history of using 
third-party investigation and testing for which a manufacturer had little or no 
expertise.  Today, laws and regulations require NRTL certification, most of 
which are there because UL lobbied the jurisdictions for third-party 
certification.   

 

https://www.nfpa.org/about-nfpa/nfpa-overview/history-of-nfpa

 

Best regards,

Rich

 

 


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Re: [PSES] Brexit requirements for UK manufacturers.

[Schmidt, Mark]

Everyone is entitled to an opinion and I said “most likely would not”. I  have 
never had this problem so I do not know but I merely suggested that you read 
your contractual agreement with your NRTL.  I am also of the opinion that the 
FUS provided by a NRTL is a critical dimension to product integrity which is 
unlike the CE Mark. So to John’s point no I do not agree with your 
interpretation of what I said.


From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org]
Sent: Friday, January 18, 2019 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

I believe Mark’s comment is over the top.  The NRTL test houses can be drawn 
into court cases and they will confirm that the product tested met the 
requirements of the standard.  Then the argument becomes whether or not all of 
the safety issues are properly covered in the standard; today the development 
of the standard is not under the sole control of the test house.  That leaves 
some of the responsibility on the standards development folks who seem to be 
working at arm’s length from the assessment.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Friday, January 18, 2019 7:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


So their certification is a sort of 'whitewash', nothing more, if, as you say, 
they bear no responsibility for the product actually being safe.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.woodjohn.uk=DwMFaQ=9mghv0deYPYDGP-W745IEdQLV1kHpn4XJRvR6xMRXtA=RsvNGGiEXp8Wa3AN0R9oJL3JV5vFvlTsmxQpMmBLBIw=pcyp3cbWnXJT_cPyPiPj6EkkEpafSl2lUuCj4wT2DjA=H9ot0UkYQiNoHH_cnTPiZggw-tpFASAzu2XFK5dvmDg=>

Rayleigh, Essex UK
On 2019-01-18 13:53, Schmidt, Mark wrote:
If you read in to the contractual agreements you sign for these OSHA NRTL’s 
they are responsible for basically nothing and most likely would not support 
you in a court of law. However, some reputable labs that I have worked with 
that are not recognized by OSHA I believe would. Bottom Line: the manufacturer 
is ultimately responsible for their product.

Mark


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This message is from the IEEE Product Safety Eng

Re: [PSES] **External**Re: [PSES] Brexit requirements for UK manufacturers.

[Jim Hulbert]

“Manufacturers are solely responsible for compliance with EMC standards for 
NA.”   Except for wireless radio equipment which generally does require TCB 
testing and issuance of an FCC ID or Canada ICES certification number.

Jim Hulbert

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Friday, January 18, 2019 8:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: **External**Re: [PSES] Brexit requirements for UK manufacturers.

Of course the manufacturer is responsible for the design.  Likely the 
manufacturers are not trusted by the public.  There is a long history, some of 
the US nationally recognized certification labs have been around since 1800s.  
One lab was founded by Thomas Edison.   Accreditation of the labs requires the 
labs to perform quarterly production line inspections to ensure that certified 
products continue to be built as original constructed.  The certification lab 
requires not only product certification but manufacturing facility 
certification to ensure they have proper procedures and equipment in place to 
perform any production testing that is required as part of product 
certification.  Note that this only applies to certification to safety 
standards.  Manufacturers are solely responsible for compliance with EMC 
standards for NA.

-Dave

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, January 18, 2019 3:05 AM
To: Nyffenegger, Dave; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


That puts the responsibility for compliance on the laboratory. It seems logical 
that the manufacturer should be responsible. Also, the lab can obviously only 
be responsible for those sample products that it tests, initially and during 
production.  Then there is the matter of insurance, unless the labs are legally 
exempt in some way, but that counteracts 'responsibility'. I suppose this has 
all been sorted out, but it was in place when the present European system was 
introduced, replacing a 'third-party testing and certification' system, started 
in Sweden on the US model and spread across Europe nation-by-nation.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2019-01-18 03:02, Nyffenegger, Dave wrote:
And another answer, North America doesn’t recognize the CE mark, not only 
because of standards differences but they don’t trust manufacturer 
self-certification.  They want certification by nationally recognized  
independent labs, for US OSHA recognized.

-Dave

From: Dennis Ward [mailto:dennis.w...@pctest.com]
Sent: Thursday, January 17, 2019 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ops should be “…the requirements of the EU are NOT all necessarily….”


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
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or attachments(s) are free from computer virus or other defect.  Thank you.


From: Dennis Ward <mailto:dennis.w...@pctest.com>
Sent: Thursday, January 17, 2019 11:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
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it fro

Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

I believe Mark’s comment is over the top.  The NRTL test houses can be drawn 
into court cases and they will confirm that the product tested met the 
requirements of the standard.  Then the argument becomes whether or not all of 
the safety issues are properly covered in the standard; today the development 
of the standard is not under the sole control of the test house.  That leaves 
some of the responsibility on the standards development folks who seem to be 
working at arm’s length from the assessment.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: John Woodgate  
Sent: Friday, January 18, 2019 7:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

So their certification is a sort of 'whitewash', nothing more, if, as you say, 
they bear no responsibility for the product actually being safe.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-01-18 13:53, Schmidt, Mark wrote:

If you read in to the contractual agreements you sign for these OSHA NRTL’s 
they are responsible for basically nothing and most likely would not support 
you in a court of law. However, some reputable labs that I have worked with 
that are not recognized by OSHA I believe would. Bottom Line: the manufacturer 
is ultimately responsible for their product.

 

Mark

 

 

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Re: [PSES] Brexit requirements for UK manufacturers.

[MIKE SHERMAN]

Another way to look at it: the NRTLs are responsible for the work that they do, 
which is primarily checking products against product safety standards. However, 
for the manufacturer, complying only with the requirements of a product safety 
standard may not be sufficient to field an adequately safety product.


Mike Sherman

Graco Inc.

> On January 18, 2019 at 9:50 AM John Woodgate  wrote:
> 
> 
> So their certification is a sort of 'whitewash', nothing more, if, as you 
> say, they bear no responsibility for the product actually being safe.
> 
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates http://www.woodjohn.uk
> Rayleigh, Essex UK
> 
> On 2019-01-18 13:53, Schmidt, Mark wrote:
> 
> > > 
> > If you read in to the contractual agreements you sign for these 
> > OSHA NRTL’s they are responsible for basically nothing and most likely 
> > would not support you in a court of law. However, some reputable labs that 
> > I have worked with that are not recognized by OSHA I believe would. Bottom 
> > Line: the manufacturer is ultimately responsible for their product.
> > 
> >  
> > 
> > Mark
> > 
> >  
> > 
> > 
> > > 


 

> -
> 
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> mailto:emc-p...@ieee.org >
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site 
> at http://product-compliance.oc.ieee.org/ can be used for graphics (in 
> well-used formats), large files, etc.
> 
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to 
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> David Heald mailto:dhe...@gmail.com >
> 


 

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

So their certification is a sort of 'whitewash', nothing more, if, as 
you say, they bear no responsibility for the product actually being safe.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-18 13:53, Schmidt, Mark wrote:


If you read in to the contractual agreements you sign for these OSHA 
NRTL’s they are responsible for basically nothing and most likely 
would not support you in a court of law. However, some reputable labs 
that I have worked with that are not recognized by OSHA I believe 
would. Bottom Line: the manufacturer is ultimately responsible for 
their product.


Mark




-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

Yes, I know the whole story, and that the US/Canadian third-party 
testing and certification applies to safety and not EMC. It doesn't 
alter the fact that the EU replaced such a scheme in Europe 
(S/D/F/N/EMKO/BEAB etc.) by the present system for the reasons I outlined.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-18 13:32, Nyffenegger, Dave wrote:


Of course the manufacturer is responsible for the design.  Likely the 
manufacturers are not trusted by the public.  There is a long history, 
some of the US nationally recognized certification labs have been 
around since 1800s.  One lab was founded by Thomas Edison.   
Accreditation of the labs requires the labs to perform quarterly 
production line inspections to ensure that certified products continue 
to be built as original constructed.  The certification lab requires 
not only product certification but manufacturing facility 
certification to ensure they have proper procedures and equipment in 
place to perform any production testing that is required as part of 
product certification.  Note that this only applies to certification 
to safety standards.  Manufacturers are solely responsible for 
compliance with EMC standards for NA.


-Dave

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* Friday, January 18, 2019 3:05 AM
*To:* Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Brexit requirements for UK manufacturers.

That puts the responsibility for compliance on the laboratory. It 
seems logical that the manufacturer should be responsible. Also, the 
lab can obviously only be responsible for those sample products that 
it tests, initially and during production.  Then there is the matter 
of insurance, unless the labs are legally exempt in some way, but that 
counteracts 'responsibility'. I suppose this has all been sorted out, 
but it was in place when the present European system was introduced, 
replacing a 'third-party testing and certification' system, started in 
Sweden on the US model and spread across Europe nation-by-nation.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2019-01-18 03:02, Nyffenegger, Dave wrote:

And another answer, North America doesn’t recognize the CE mark,
not only because of standards differences but they don’t trust
manufacturer self-certification.  They want certification by
nationally recognized  independent labs, for US OSHA recognized.

-Dave

*From:*Dennis Ward [mailto:dennis.w...@pctest.com]
*Sent:* Thursday, January 17, 2019 3:01 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] Brexit requirements for UK manufacturers.

Ops should be “…the requirements of the EU are NOT all necessarily….”

Dennis Ward

This communication and its attachements contain information from
PCTEST Engineering Laboratory, Inc., and is intended for the
exclusive use of the recipient(s) named above.  It may contain
information that is confidential and/or legally privileged.  Any
unauthorized use that may compromise that confidentiality via
distribution or disclosure is prohibited.  Please notify the
sender immediately if you receive this communication in error, and
delete it from your computer system.  Usage of PCTEST email
addresses for non-business related activities is strictly
prohibited.  No warranty is made that the e-mail or attachments(s)
are free from computer virus or other defect.  Thank you.

*From:* Dennis Ward 
<mailto:dennis.w...@pctest.com>
*Sent:* Thursday, January 17, 2019 11:45 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all
necessarily the requirements of other regimes.  CE shows an
assumption of compliance to EU, it does not show or assume
compliance to any other regime unless that regime has identical
requirements or unless that regime is willing to accept other than
their own requirements to show compliance.

When and if Brexit occurs, it may take a while for the UK to
adjust what it sees as required conformity issues. So, it is
understandable, since existing standards produced by the EU bodies
are in their law, that they would still accept the mark for a
while.  How long, who knows.

Thanks

Dennis Ward

This communication and its attachements contain information from
PCTEST Engineering Laboratory, Inc., and is intended for the
exclusive use of the recipient(s) named above.  It may contain
information that is confidential and/or legally privileged.  Any
unauthorized use that may compromise that confidentiality via
di

Re: [PSES] Brexit requirements for UK manufacturers.

[Schmidt, Mark]

If you read in to the contractual agreements you sign for these OSHA NRTL’s 
they are responsible for basically nothing and most likely would not support 
you in a court of law. However, some reputable labs that I have worked with 
that are not recognized by OSHA I believe would. Bottom Line: the manufacturer 
is ultimately responsible for their product.

Mark

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, January 18, 2019 3:05 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


That puts the responsibility for compliance on the laboratory. It seems logical 
that the manufacturer should be responsible. Also, the lab can obviously only 
be responsible for those sample products that it tests, initially and during 
production.  Then there is the matter of insurance, unless the labs are legally 
exempt in some way, but that counteracts 'responsibility'. I suppose this has 
all been sorted out, but it was in place when the present European system was 
introduced, replacing a 'third-party testing and certification' system, started 
in Sweden on the US model and spread across Europe nation-by-nation.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.woodjohn.uk=DwMDaQ=9mghv0deYPYDGP-W745IEdQLV1kHpn4XJRvR6xMRXtA=RsvNGGiEXp8Wa3AN0R9oJL3JV5vFvlTsmxQpMmBLBIw=ffG43VJWnFi9_Tpsp1d_RgltGKMUY9UQlSflJLWfPIs=t1nqTqG9LYXCjN8A588LxWsYmJvmmg8TYA5cL6sWESM=>

Rayleigh, Essex UK
On 2019-01-18 03:02, Nyffenegger, Dave wrote:
And another answer, North America doesn’t recognize the CE mark, not only 
because of standards differences but they don’t trust manufacturer 
self-certification.  They want certification by nationally recognized  
independent labs, for US OSHA recognized.

-Dave

From: Dennis Ward [mailto:dennis.w...@pctest.com]
Sent: Thursday, January 17, 2019 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ops should be “…the requirements of the EU are NOT all necessarily….”


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Dennis Ward <mailto:dennis.w...@pctest.com>
Sent: Thursday, January 17, 2019 11:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Richard Nute mailto:ri...@ieee.org>>
Sent: Thursday, January 17, 2019 10:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.



  *   CE mark is replaced by UK mark.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?

Rich


-


This message is from the IEEE Product Safety Engineering Society emc-pstc

Re: [PSES] Brexit requirements for UK manufacturers.

[Nyffenegger, Dave]

Of course the manufacturer is responsible for the design.  Likely the 
manufacturers are not trusted by the public.  There is a long history, some of 
the US nationally recognized certification labs have been around since 1800s.  
One lab was founded by Thomas Edison.   Accreditation of the labs requires the 
labs to perform quarterly production line inspections to ensure that certified 
products continue to be built as original constructed.  The certification lab 
requires not only product certification but manufacturing facility 
certification to ensure they have proper procedures and equipment in place to 
perform any production testing that is required as part of product 
certification.  Note that this only applies to certification to safety 
standards.  Manufacturers are solely responsible for compliance with EMC 
standards for NA.

-Dave

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, January 18, 2019 3:05 AM
To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


That puts the responsibility for compliance on the laboratory. It seems logical 
that the manufacturer should be responsible. Also, the lab can obviously only 
be responsible for those sample products that it tests, initially and during 
production.  Then there is the matter of insurance, unless the labs are legally 
exempt in some way, but that counteracts 'responsibility'. I suppose this has 
all been sorted out, but it was in place when the present European system was 
introduced, replacing a 'third-party testing and certification' system, started 
in Sweden on the US model and spread across Europe nation-by-nation.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2019-01-18 03:02, Nyffenegger, Dave wrote:
And another answer, North America doesn’t recognize the CE mark, not only 
because of standards differences but they don’t trust manufacturer 
self-certification.  They want certification by nationally recognized  
independent labs, for US OSHA recognized.

-Dave

From: Dennis Ward [mailto:dennis.w...@pctest.com]
Sent: Thursday, January 17, 2019 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ops should be “…the requirements of the EU are NOT all necessarily….”


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Dennis Ward <mailto:dennis.w...@pctest.com>
Sent: Thursday, January 17, 2019 11:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Richard Nute mailto:ri...@ieee.org>>
Sent: Thursday, January 17, 2019 10:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.



  *   CE mark is replaced by

Re: [PSES] Brexit requirements for UK manufacturers.

[Andrew Wood]

I typed this reply yesterday, but didn’t get around to hitting send.
In the mean time Pete has said pretty much the same thing….


Hi Laura,
The UK mark caught my eye as well, but I am not aware of any details about it 
so far.
The Schedule 25 of the draft SI (Statutory Instrument) refers to“UK 
marking” means the marking in the form published in accordance with Article 
30(1) of RAMS

But Article 30 of RAMS or “Requirements for accreditation and market 
surveillance….” 
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0030:0047:en:PDF
refers to details of the CE mark.
So that is a bit of a dead end.

Andy

Best Regards,

Andrew Wood
Compliance Manager - Hazardous Areas

[cid:image003.png@01D4AF17.C6930720]

  Visit the NEW SPOT Thermometer website at  
www.spotthermometer.com<http://www.landinst.com/products/viralert-fever-screening-system/overview>

LAND Instruments International | Stubley Lane, Dronfield, Derbyshire, S18 1DJ, 
England
DDI: +44 (0)1246 581592  | E-mail: 
andrew.w...@ametek.com<mailto:andrew.w...@ametek.com>| Web: 
www.landinst.com<http://www.landinst.com/>

From: Laura Stevens 
Sent: 17 January 2019 16:03
To: Andrew Wood 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


***NOTICE*** This came from an external source. Use caution when replying, 
clicking links, or opening attachments.
Hi Andrew,

Your summarization of the changes was very helpful.  The replacement of the CE 
mark by a UK mark caught my attention.  Are you aware of any documentation 
released by the UK on what the new UK mark may look like?

Thank you
Laura Stevens
Sr. Compliance Engineer

[https://docs.google.com/uc?export=download=0B1Ay_asZz_CfMXVnTUREUVVuMmc=0B1Ay_asZz_CfZlF1ODkyajRxQWRsazY5VWtiZVFqeHFSbkhzPQ]
2221 W Camden Road,
Glendale, WI 53209
Phone: 414-228-5688


On Thu, Jan 17, 2019 at 4:45 AM Andrew Wood 
mailto:andrew.w...@ametek.com>> wrote:
Just to clear up a bit of confusion (whilst staying well clear of politics)

The link given by Scott ie 
http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>
Is to the 619 page draft legislation, but the link takes you straight to 
Schedule 25 which is for the ATEX information.
Using the navigation options you can open the entire document as a web page or 
pdf.

The aim of this document is a quick fix in the event of no further deals or 
agreements.
It is a document to amend a series of existing regulations and makes the bare 
minimum changes.
For ATEX, Schedule 25 amends the Equipment and Protective Systems Intended for 
use in Potentially Explosive Atmospheres Regulations 2016.
The 28 pages of changes can be summarised as:


  *   Harmonised standards (published in the OJ) become Designated standards 
approved by the Secretary of State
  *   Notified Bodies become Approved Bodies (and the Nando database is 
replaced by  a UK equivalent)
  *   EU Declaration of Conformity drops “EU” to become a Declaration of 
Conformity
  *   CE mark is replaced by UK mark.
There are various other minor logical changes referring to instructions being 
in English etc and generally changing references from EU to UK.
The basic structure and approval process seems to be as close as practical to 
the existing requirements.

A very quick look suggests that there are similar changes for the following 
Regulations that might be of interest:
Machinery Safety in Schedule 12
EMC in schedule 20
LVD in schedule 23
Pressure equipment in schedule 24
Radio equipment in schedule 29


The deal rejected earlier this week relates to the withdrawal agreement, which 
aimed to establish a transition period (so that for example the UK would carry 
on using the CE mark and the EU Notified Bodies would keep their status etc etc 
in return for a series of rights and obligations on both sides)

The 619 draft legislation is the default position (for product safety etc) if 
there is nothing else decided in the meantime.

Andy

Best Regards,

Andrew Wood
Compliance Manager - Hazardous Areas

[cid:1685c8a475f692e331]

  Visit the NEW SPOT Thermometer website at  
www.spotthermometer.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.landinst.com_products_viralert-2Dfever-2Dscreening-2Dsystem_overview=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=DtrRITJJ3AXmh976pLlMyy_xPPFdztIq7yzMgrASwUg=dwj1r1fAJ2YEqMuygXLECXxGL63psM0qDo8FXxhYqEE=>

LAND Instruments International | Stubley Lane, Dronfield, Derbyshire, S18 1DJ, 
England
DDI: +44 (0)1246 581592  | E-mail: 
andrew.w...@ametek.com<mailto:andrew.w...@ametek.com>| Web: 
www.landinst.com<https://urldefense.proofpoint.com/v

Re: [PSES] Brexit requirements for UK manufacturers.

[Nyffenegger, Dave]

And another answer, North America doesn’t recognize the CE mark, not only 
because of standards differences but they don’t trust manufacturer 
self-certification.  They want certification by nationally recognized  
independent labs, for US OSHA recognized.

-Dave

From: Dennis Ward [mailto:dennis.w...@pctest.com]
Sent: Thursday, January 17, 2019 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ops should be “…the requirements of the EU are NOT all necessarily….”


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Dennis Ward 
Sent: Thursday, January 17, 2019 11:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Richard Nute mailto:ri...@ieee.org>>
Sent: Thursday, January 17, 2019 10:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.



  *   CE mark is replaced by UK mark.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?

Rich


-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
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For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
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-


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Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

Andrew,   Thanx for the pointer to this proposed comprehensive 
Brexit update to the UK Legislation.  This was a lot of work pulling this 
together.  Hopefully it will be used to provide a smooth transition from the 
present CE marked equipment to the new UK marking.  

 

I searched it thoroughly for the new replacement marking for CE 
(UK marking) and primarily found a reference to some other legislation; nowhere 
did I find a symbolic representation for the marking.  

 

So the actual marking seems still in doubt.  I still like my 
combo approach – ukCEeu – which brings the requirements together in the same 
way that the usNRTLc marking does for North America.  

 

However, Gert’s unique proposal seems intriguing; the letters 
UK could be shown in the Bowler Hat but I would insist on maintaining the 
mustache.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Andrew Wood  
Sent: Thursday, January 17, 2019 2:28 AM
To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Brexit requirements for UK manufacturers.

 

Just to clear up a bit of confusion (whilst staying well clear of politics)

 

The link given by Scott ie 
http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25 
<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>
 

Is to the 619 page draft legislation, but the link takes you straight to 
Schedule 25 which is for the ATEX information.

Using the navigation options you can open the entire document as a web page or 
pdf.

 

The aim of this document is a quick fix in the event of no further deals or 
agreements.

It is a document to amend a series of existing regulations and makes the bare 
minimum changes.

For ATEX, Schedule 25 amends the Equipment and Protective Systems Intended for 
use in Potentially Explosive Atmospheres Regulations 2016.

The 28 pages of changes can be summarised as:

 

*   Harmonised standards (published in the OJ) become Designated standards 
approved by the Secretary of State
*   Notified Bodies become Approved Bodies (and the Nando database is 
replaced by  a UK equivalent) 
*   EU Declaration of Conformity drops “EU” to become a Declaration of 
Conformity
*   CE mark is replaced by UK mark.

There are various other minor logical changes referring to instructions being 
in English etc and generally changing references from EU to UK.

The basic structure and approval process seems to be as close as practical to 
the existing requirements.

 

A very quick look suggests that there are similar changes for the following 
Regulations that might be of interest:

Machinery Safety in Schedule 12

EMC in schedule 20

LVD in schedule 23

Pressure equipment in schedule 24

Radio equipment in schedule 29

 

 

The deal rejected earlier this week relates to the withdrawal agreement, which 
aimed to establish a transition period (so that for example the UK would carry 
on using the CE mark and the EU Notified Bodies would keep their status etc etc 
in return for a series of rights and obligations on both sides)

 

The 619 draft legislation is the default position (for product safety etc) if 
there is nothing else decided in the meantime.

 

Andy

 

Best Regards,

Andrew Wood
Compliance Manager - Hazardous Areas

 



 

  Visit the NEW SPOT Thermometer website at  www.spotthermometer.com 
<http://www.landinst.com/products/viralert-fever-screening-system/overview> 

 

LAND Instruments International | Stubley Lane, Dronfield, Derbyshire, S18 1DJ, 
England

DDI: +44 (0)1246 581592  | E-mail:  <mailto:andrew.w...@ametek.com> 
andrew.w...@ametek.com| Web: www.landinst.com <http://www.landinst.com/> 

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > 
Sent: 16 January 2019 19:47
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

***NOTICE*** This came from an external source. Use caution when replying, 
clicking links, or opening attachments.

Scott et al,

 

I haven’t read the 600+ UK legislation report (which was 
apparently rejected this week in the Parliament) but I am searching for the new 
UK marking – perhaps ukCEeu?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.per

Re: [PSES] Brexit requirements for UK manufacturers.

[Dennis Ward]

Ops should be “…the requirements of the EU are NOT all necessarily….”


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.


From: Dennis Ward 
Sent: Thursday, January 17, 2019 11:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Richard Nute mailto:ri...@ieee.org>>
Sent: Thursday, January 17, 2019 10:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.



  *   CE mark is replaced by UK mark.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?

Rich


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Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

This is an important issue. It's one thing for the UK to accept European 
standards (ENs) /*as standards*, /but the European Court decision that 
ENs are 'part of EU law' changes the picture considerably.  If UK 
continues to endorse ENs as BS ENs after the transition period, it is 
accepting EU laws without any means of contributing to, or challenging, 
them, because continued membership of CEN and CENELEC, where UK will 
continue to have voice and vote, is subservient to approved decisions of 
the 'HAS Consultants' and the Commissions lawyers, who now have a veto 
over the content and wording of EN standards that support Directives and 
Regulations.  That is a 'very soft Brexit' indeed; UK would be a 
semi-autonomous dependency.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-17 19:44, Dennis Ward wrote:
When and if Brexit occurs, it may take a while for the UK to adjust 
what it sees as required conformity issues. So, it is understandable, 
since existing standards produced by the EU bodies are in their law, 
that they would still accept the mark for a while.  How long, who knows.


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Re: [PSES] Brexit requirements for UK manufacturers.

[Dennis Ward]

Simple answer – because the requirements of the EU are all necessarily the 
requirements of other regimes.  CE shows an assumption of compliance to EU, it 
does not show or assume compliance to any other regime unless that regime has 
identical requirements or unless that regime is willing to accept other than 
their own requirements to show compliance.
When and if Brexit occurs, it may take a while for the UK to adjust what it 
sees as required conformity issues. So, it is understandable, since existing 
standards produced by the EU bodies are in their law, that they would still 
accept the mark for a while.  How long, who knows.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: Richard Nute 
Sent: Thursday, January 17, 2019 10:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.



  *   CE mark is replaced by UK mark.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?

Rich


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Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

I suspect that only applies during the 'transition period', simply to 
avoid an instant change in the requirements. If it were a permanent 
arrangement, no 'UK Mark' would ever be required.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-17 18:57, Richard Nute wrote:


Andy answered my question in posting the reference:

Products that have undergone the complete process of manufacturing and 
conformity assessment (i.e. which are ready for placing on the market) 
can still be placed on the UK market with a CE Marking after 29 March 
2019.


Rich

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Re: [PSES] Brexit requirements for UK manufacturers.

[Richard Nute]

 

Andy answered my question in posting the reference:

 

Products that have undergone the complete process of manufacturing and
conformity assessment (i.e. which are ready for placing on the market) can
still be placed on the UK market with a CE Marking after 29 March 2019.

 

Rich

 


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Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

The UK can and will recognize the CE Mark after Brexit (if and when), 
but British manufactures will not be allowed to put it on their 
products, because it is 'Conformité Européen'.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-17 18:50, Richard Nute wrote:


  * *CE mark*is replaced by *UK mark*.

Hmm.  I wonder why the UK or any country can’t recognize the CE mark 
as indicative of the relevant performance of the product?


Rich

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Re: [PSES] Brexit requirements for UK manufacturers.

[Richard Nute]

 

*   CE mark is replaced by UK mark.

 

Hmm.  I wonder why the UK or any country can’t recognize the CE mark as 
indicative of the relevant performance of the product?  

 

Rich  

 

 


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Re: [PSES] Brexit requirements for UK manufacturers.

[Laura Stevens]

Hi Andrew,

Your summarization of the changes was very helpful.  The replacement of the
CE mark by a UK mark caught my attention.  Are you aware of any
documentation released by the UK on what the new UK mark may look like?

Thank you
*Laura Stevens*
Sr. Compliance Engineer


2221 W Camden Road,
Glendale, WI 53209
Phone: 414-228-5688


On Thu, Jan 17, 2019 at 4:45 AM Andrew Wood  wrote:

> Just to clear up a bit of confusion (whilst staying well clear of politics)
>
>
>
> The link given by Scott ie
> http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>
>
> Is to the 619 page draft legislation, but the link takes you straight to
> Schedule 25 which is for the ATEX information.
>
> Using the navigation options you can open the entire document as a web
> page or pdf.
>
>
>
> The aim of this document is a quick fix in the event of no further deals
> or agreements.
>
> It is a document to amend a series of existing regulations and makes the
> bare minimum changes.
>
> For ATEX, Schedule 25 amends the *Equipment and Protective Systems
> Intended for use in Potentially Explosive Atmospheres Regulations 2016*.
>
> The 28 pages of changes can be summarised as:
>
>
>
>- *Harmonised* standards (published in the *OJ*) become *Designated*
>standards approved by the *Secretary of State*
>- *Notified Bodies* become *Approved Bodies* (and the Nando database
>is replaced by  a UK equivalent)
>- *EU Declaration of Conformity* drops “EU” to become a *Declaration
>of Conformity*
>- *CE mark* is replaced by *UK mark*.
>
> There are various other minor logical changes referring to instructions
> being in English etc and generally changing references from EU to UK.
>
> The basic structure and approval process seems to be as close as practical
> to the existing requirements.
>
>
>
> A very quick look suggests that there are similar changes for the
> following Regulations that might be of interest:
>
> Machinery Safety in Schedule 12
>
> EMC in schedule 20
>
> LVD in schedule 23
>
> Pressure equipment in schedule 24
>
> Radio equipment in schedule 29
>
>
>
>
>
> The deal rejected earlier this week relates to the withdrawal agreement,
> which aimed to establish a transition period (so that for example the UK
> would carry on using the CE mark and the EU Notified Bodies would keep
> their status etc etc in return for a series of rights and obligations on
> both sides)
>
>
>
> The 619 draft legislation is the default position (for product safety etc)
> if there is nothing else decided in the meantime.
>
>
>
> Andy
>
>
>
> Best Regards,
>
> Andrew Wood
> Compliance Manager - Hazardous Areas
>
>
>
>
>
> *  Visit the NEW SPOT Thermometer website at  www.spotthermometer.com
> <http://www.landinst.com/products/viralert-fever-screening-system/overview>*
>
>
>
> *LAND** Instruments International **|* Stubley Lane, Dronfield,
> Derbyshire, S18 1DJ, England
>
> *DDI:* +44 (0)1246 581592  *|** E-mail: **andrew.w...@ametek.com
> **|* *Web:* www.landinst.com
>
>
>
> *From:* Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
> *Sent:* 16 January 2019 19:47
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Brexit requirements for UK manufacturers.
>
>
>
> NOTICE*** *This came from an external source. Use caution when
> replying, clicking links, or opening attachments.
>
> Scott et al,
>
>
>
> I haven’t read the 600+ UK legislation report (which was
> apparently rejected this week in the Parliament) but I am searching for the
> new UK marking – perhaps ukCEeu?
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 23427
>
> Tigard, ORe  97281-3427
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> p.perk...@ieee.org
>
>
>
> *From:* Scott Xe 
> *Sent:* Wednesday, January 16, 2019 5:57 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Brexit requirements for UK manufacturers.
>
>
>
> Hi Ian,
>
>
>
> Your assumption is correct but may have more than your thought.  You can
> read the following draft for greater detail.
>
>
>
> http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25
> <

Re: [PSES] Brexit requirements for UK manufacturers.

[Andrew Wood]

Ian
I don't know if you have seen the guidelines on this page?
https://www.gov.uk/government/publications/trading-goods-regulated-under-the-new-approach-if-theres-no-brexit-deal/trading-goods-regulated-under-the-new-approach-if-theres-no-brexit-deal

Andy

From: McBurney, Ian 
Sent: 16 January 2019 10:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit requirements for UK manufacturers.


***NOTICE*** This came from an external source. Use caution when replying, 
clicking links, or opening attachments.
Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities.

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company. -


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/
 can be used for graphics (in well-used formats), large files, etc.

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-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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For help, send mail to the list administrators:
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[Andrew Wood]

Just to clear up a bit of confusion (whilst staying well clear of politics)

The link given by Scott ie 
http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>
Is to the 619 page draft legislation, but the link takes you straight to 
Schedule 25 which is for the ATEX information.
Using the navigation options you can open the entire document as a web page or 
pdf.

The aim of this document is a quick fix in the event of no further deals or 
agreements.
It is a document to amend a series of existing regulations and makes the bare 
minimum changes.
For ATEX, Schedule 25 amends the Equipment and Protective Systems Intended for 
use in Potentially Explosive Atmospheres Regulations 2016.
The 28 pages of changes can be summarised as:


  *   Harmonised standards (published in the OJ) become Designated standards 
approved by the Secretary of State
  *   Notified Bodies become Approved Bodies (and the Nando database is 
replaced by  a UK equivalent)
  *   EU Declaration of Conformity drops “EU” to become a Declaration of 
Conformity
  *   CE mark is replaced by UK mark.
There are various other minor logical changes referring to instructions being 
in English etc and generally changing references from EU to UK.
The basic structure and approval process seems to be as close as practical to 
the existing requirements.

A very quick look suggests that there are similar changes for the following 
Regulations that might be of interest:
Machinery Safety in Schedule 12
EMC in schedule 20
LVD in schedule 23
Pressure equipment in schedule 24
Radio equipment in schedule 29


The deal rejected earlier this week relates to the withdrawal agreement, which 
aimed to establish a transition period (so that for example the UK would carry 
on using the CE mark and the EU Notified Bodies would keep their status etc etc 
in return for a series of rights and obligations on both sides)

The 619 draft legislation is the default position (for product safety etc) if 
there is nothing else decided in the meantime.

Andy

Best Regards,

Andrew Wood
Compliance Manager - Hazardous Areas

[cid:image003.png@01D4AE4F.48F2D430]

  Visit the NEW SPOT Thermometer website at  
www.spotthermometer.com<http://www.landinst.com/products/viralert-fever-screening-system/overview>

LAND Instruments International | Stubley Lane, Dronfield, Derbyshire, S18 1DJ, 
England
DDI: +44 (0)1246 581592  | E-mail: 
andrew.w...@ametek.com<mailto:andrew.w...@ametek.com>| Web: 
www.landinst.com<http://www.landinst.com/>

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
Sent: 16 January 2019 19:47
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.


***NOTICE*** This came from an external source. Use caution when replying, 
clicking links, or opening attachments.
Scott et al,

I haven’t read the 600+ UK legislation report (which was 
apparently rejected this week in the Parliament) but I am searching for the new 
UK marking – perhaps ukCEeu?

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: Scott Xe mailto:scott...@gmail.com>>
Sent: Wednesday, January 16, 2019 5:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Hi Ian,

Your assumption is correct but may have more than your thought.  You can read 
the following draft for greater detail.

http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>

I have learnt that recently the UK government published draft Regulations of 
619 pages in case of no deal Brexit.  Unfortunately, I could not locate it yet. 
 Hope other team mates can help to explore greater info.

Thanks and regards,

Scott


Sent from 
Mail<https://urldefense.proofpoint.com/v2/url?u=https-3A__go.microsoft.com_fwlink_-3FLinkId-3D550986=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=tNgLpR60YYVpkOf-LesloJ5ciMT0fkI6ChjUwtZLiE4=>
 for Windows 10

From: McBurney, Ian<mailto:ian.mcbur...@allen-heath.com>
Sent: Wednesday, 16 January 2019 08:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] B

Re: [PSES] Brexit requirements for UK manufacturers.

[Gert Gremmen]

May i suggest: XXX   BC (British Compliance) , where XXX is the NoBo number

An example would be 250 BC.  (confusion with Before Christ is really 
unintended)


As a marking to replace the CE marking is suggest:

Afbeeldingsresultaat voor bowler hat clip art

The moustache is optional.

Gert


On 16-1-2019 20:46, Pete Perkins wrote:


Scott et al,

    I haven’t read the 600+ UK legislation report (which 
was apparently rejected this week in the Parliament) but I am 
searching for the new UK marking – perhaps ukCEeu?


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org>

*From:* Scott Xe 
*Sent:* Wednesday, January 16, 2019 5:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Brexit requirements for UK manufacturers.

Hi Ian,

Your assumption is correct but may have more than your thought.  You 
can read the following draft for greater detail.


http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

I have learnt that recently the UK government published draft 
Regulations of 619 pages in case of no deal Brexit.  Unfortunately, I 
could not locate it yet.  Hope other team mates can help to explore 
greater info.


Thanks and regards,

Scott

Sent from Mail <https://go.microsoft.com/fwlink/?LinkId=550986> for 
Windows 10


*From: *McBurney, Ian <mailto:ian.mcbur...@allen-heath.com>
*Sent: *Wednesday, 16 January 2019 08:55 PM
*To: *EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject: *[PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30^th March 2019


but so far nothing has been published by the relevant authorities.

From my understanding, if the UK leaves the EU without an agreement, 
the UK will be outside the EU and there are different requirements for 
UK based manufacturers.


I believe the existing manufacturers Declaration of conformity 
documents will still be valid but that a nominated representative in 
the EU will now be required. We plan to nominate our distributor in 
the EU (i.e. Germany) as the importer to satisfy this requirement.


Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com <mailto:ian.mcbur...@allen-heath.com>

Allen & Heath Ltd is a registered business in England and Wales, 
Company number: 4163451. Any views expressed in this email are those 
of the individual and not necessarily those of the company.


-


This message is from the IEEE Product Safety Engineering Society 
emc-pstc discussion list. To post a message to the list, send your 
e-mail to mailto:emc-p...@ieee.org>>


All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html


Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
graphics (in well-used formats), large files, etc.


Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)

List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

-


This message is from the IEEE Product Safety Engineering Society 
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e-mail to mailto:emc-p...@ieee.org>>


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Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
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Instructions: http://www.ieee-pses.org/list.html (including how to 
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

-


This message is from the IEEE Product Safety Engineering Society 
emc-pstc discussion lis

Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

Scott et al,

 

I haven’t read the 600+ UK legislation report (which was 
apparently rejected this week in the Parliament) but I am searching for the new 
UK marking – perhaps ukCEeu?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Scott Xe  
Sent: Wednesday, January 16, 2019 5:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

Hi Ian,

 

Your assumption is correct but may have more than your thought.  You can read 
the following draft for greater detail.

 

http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

 

I have learnt that recently the UK government published draft Regulations of 
619 pages in case of no deal Brexit.  Unfortunately, I could not locate it yet. 
 Hope other team mates can help to explore greater info.

 

Thanks and regards,

 

Scott

 

 

Sent from Mail <https://go.microsoft.com/fwlink/?LinkId=550986>  for Windows 10

 

From: McBurney, Ian <mailto:ian.mcbur...@allen-heath.com> 
Sent: Wednesday, 16 January 2019 08:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Brexit requirements for UK manufacturers.

 

Dear Colleagues.

 

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019

but so far nothing has been published by the relevant authorities. 

 

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

 

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

 

Please can you let me know if my assumptions are correct?

 

Thanks in advance.

 

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com <mailto:ian.mcbur...@allen-heath.com> 

 

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company. 

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 
<http://www.ieee-pses.org/list.html> 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org> >
Mike Cantwell mailto:mcantw...@ieee.org> > 

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org> >
David Heald mailto:dhe...@gmail.com> > 

 

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 
<http://www.ieee-pses.org/list.html> 
List rules: http://www.ieee-pses.org/listrules.html 

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David Heald mailto:dhe...@gmail.com> > 


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not pe

Re: [PSES] Brexit requirements for UK manufacturers.

[Charlie Blackham]

Scott

> You have to replace your existing manufacture name and address on the product 
> to your new Germany one.

You don’t – the “manufacturer” is the “manufacturer” where ever they are 
located. Importers and other participants in the supply chain have different 
responsibilities depending on where the manufacturer is located, and additional 
labelling may be needed, but it doesn’t replace.

>Scott: You have to employ EU Notified Body for EU markets or one that has dual 
>status of EU and UK Notified Body.

Unfortunately, there is no such organisation. A Notified body is accredited by 
a single accreditation body and if the technical file is transferred to another 
NB in a different country, even if it has the same name over the door, the NB 
review must be re-performed against that NB’s own procedures.

There are NB offices in the UK (and Europe) operating under MRAs with the EU 
that will be able to continue unaffected after BREXIT

regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: 16 January 2019 14:15
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Brexit requirements for UK manufacturers.

Dear Charlie & Ian,

May I add some additional comments on the following.

Regards,

Scott

Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10

From: Charlie Blackham<mailto:char...@sulisconsultants.com>
Sent: Wednesday, 16 January 2019 09:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ian

My understanding is:

  *   You only need a “representative” in the EU if required in the applicable 
Directive(s), otherwise your importer in Germany only need to act as an 
“importer”
Scott: You have to replace your existing manufacture name and address on the 
product to your new Germany one.

  *   You will also have an issue with Notified Body certificates/opinions 
issued from UK accredited NBs as these organisations will no longer be NBs 
under the Directives.
Scott: You have to employ EU Notified Body for EU markets or one that has dual 
status of EU and UK Notified Body.

  *   Equipment “placed on the market” in the UK before 30th March has free 
movement within EU after 30th March


Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: McBurney, Ian 
mailto:ian.mcbur...@allen-heath.com>>
Sent: 16 January 2019 10:21
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities.

From my understanding, if the UK leaves the EU without an agreement, the UK 
will be outside the EU and there are different requirements for UK based 
manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com<mailto:ian.mcbur...@allen-heath.com>

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)<http://www.ieee-pses.org/list.html>
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrato

Re: [PSES] Brexit requirements for UK manufacturers.

[Scott Xe]

Dear Charlie & Ian,

May I add some additional comments on the following.

Regards,

Scott

Sent from Mail for Windows 10

From: Charlie Blackham
Sent: Wednesday, 16 January 2019 09:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

Ian

My understanding is:
• You only need a “representative” in the EU if required in the applicable 
Directive(s), otherwise your importer in Germany only need to act as an 
“importer”
Scott: You have to replace your existing manufacture name and address on the 
product to your new Germany one.
• You will also have an issue with Notified Body certificates/opinions issued 
from UK accredited NBs as these organisations will no longer be NBs under the 
Directives.
Scott: You have to employ EU Notified Body for EU markets or one that has dual 
status of EU and UK Notified Body.
• Equipment “placed on the market” in the UK before 30th March has free 
movement within EU after 30th March


Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: McBurney, Ian  
Sent: 16 January 2019 10:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities. 

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company. 
-

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discussion list. To post a message to the list, send your e-mail to 

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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

I think 'no deal' is very unlikely. The trouble is, that so are all the 
other possibilities. ;-)


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-16 13:56, Scott Xe wrote:


Hi Ian,

Your assumption is correct but may have more than your thought.  You 
can read the following draft for greater detail.


http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

I have learnt that recently the UK government published draft 
Regulations of 619 pages in case of no deal Brexit.  Unfortunately, I 
could not locate it yet.  Hope other team mates can help to explore 
greater info.


Thanks and regards,

Scott

Sent from Mail  for 
Windows 10


*From: *McBurney, Ian 
*Sent: *Wednesday, 16 January 2019 08:55 PM
*To: *EMC-PSTC@LISTSERV.IEEE.ORG 
*Subject: *[PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30^th March 2019


but so far nothing has been published by the relevant authorities.

From my understanding, if the UK leaves the EU without an agreement, 
the UK will be outside the EU and there are different requirements for 
UK based manufacturers.


I believe the existing manufacturers Declaration of conformity 
documents will still be valid but that a nominated representative in 
the EU will now be required. We plan to nominate our distributor in 
the EU (i.e. Germany) as the importer to satisfy this requirement.


Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, 
Company number: 4163451. Any views expressed in this email are those 
of the individual and not necessarily those of the company.


-


This message is from the IEEE Product Safety Engineering Society 
emc-pstc discussion list. To post a message to the list, send your 
e-mail to mailto:emc-p...@ieee.org>>


All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html


Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
graphics (in well-used formats), large files, etc.


Website: http://www.ieee-pses.org/
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unsubscribe)

List rules: http://www.ieee-pses.org/listrules.html

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David Heald mailto:dhe...@gmail.com>>

-


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Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
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-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Website:  http://www.ieee-pses.org/
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[Scott Xe]

Hi Ian,

Your assumption is correct but may have more than your thought.  You can read 
the following draft for greater detail.

http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

I have learnt that recently the UK government published draft Regulations of 
619 pages in case of no deal Brexit.  Unfortunately, I could not locate it yet. 
 Hope other team mates can help to explore greater info.

Thanks and regards,

Scott


Sent from Mail for Windows 10

From: McBurney, Ian
Sent: Wednesday, 16 January 2019 08:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities. 

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company. 
-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html
Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.
Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html 
For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell  
For policy questions, send mail to:
Jim Bacher 
David Heald  


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Website:  http://www.ieee-pses.org/
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Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[Charlie Blackham]

Ian

My understanding is:

  *   You only need a "representative" in the EU if required in the applicable 
Directive(s), otherwise your importer in Germany only need to act as an 
"importer"
  *   You will also have an issue with Notified Body certificates/opinions 
issued from UK accredited NBs as these organisations will no longer be NBs 
under the Directives.
  *   Equipment "placed on the market" in the UK before 30th March has free 
movement within EU after 30th March


Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: McBurney, Ian 
Sent: 16 January 2019 10:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities.

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Website: http://www.ieee-pses.org/
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David Heald mailto:dhe...@gmail.com>>

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All emc-pstc postings are archived and searchable on the web at:
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Jim Bacher:  
David Heald: 

Re: [PSES] Brexit requirements for UK manufacturers.

[Graevinghoff Andreas (ETAS/EHS2)]

Dear Ian,

There was an article from Susanne Wende from Noerr LLP regarding Brexit in the 
latest issue of InCompliance Magazine:

https://incompliancemag.com/article/brexit-and-its-impact-on-market-access/

The article considers 3 different Brexit scenarios, main aspects are


·   Distributors/Importers

·   Notified Bodies

·   Authorized Representatives

Best regards,

Dr. Andreas Grävinghoff

ETAS GmbH
Head of CoC Product Compliance Engineering
Borsigstraße 24
70469 Stuttgart
Germany
http://www.etas.com

Phone  +49 711 3423-2600
andreas.graevingh...@etas.com

Managing Directors: Friedhelm Pickhard, Bernd Hergert, Christopher White
Chairman of the Supervisory Board: Dr. Walter Schirm
Registered Office: Stuttgart; Registration Court: Amtsgericht Stuttgart HRB 
19033


From: McBurney, Ian 
Sent: Mittwoch, 16. Januar 2019 11:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019
but so far nothing has been published by the relevant authorities.

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] Brexit requirements for UK manufacturers.

[John Woodgate]

We discussed this here only a few days ago. Yes, you need an authorized 
representative within the EU.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-01-16 10:21, McBurney, Ian wrote:


Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30^th March 2019


but so far nothing has been published by the relevant authorities.

From my understanding, if the UK leaves the EU without an agreement, 
the UK will be outside the EU and there are different requirements for 
UK based manufacturers.


I believe the existing manufacturers Declaration of conformity 
documents will still be valid but that a nominated representative in 
the EU will now be required. We plan to nominate our distributor in 
the EU (i.e. Germany) as the importer to satisfy this requirement.


Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com

Allen & Heath Ltd is a registered business in England and Wales, 
Company number: 4163451. Any views expressed in this email are those 
of the individual and not necessarily those of the company. -



This message is from the IEEE Product Safety Engineering Society 
emc-pstc discussion list. To post a message to the list, send your 
e-mail to mailto:emc-p...@ieee.org>>


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http://www.ieee-pses.org/emc-pstc.html


Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
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Website: http://www.ieee-pses.org/
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David Heald mailto:dhe...@gmail.com>>



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