Post-Brexit Implications

Implications for accreditation in the regulated sectors post-Brexit

Source: Irish Health & Safety Authority

The European Commission has clearly stated that United Kingdom Accreditation Service (UKAS) accreditation and certificates and reports issued by Conformity Assessment Bodies (CABs) accredited by UKAS will not be recognised with respect to the EU Regulatory system, as of 1st January 2021, for example regarding Notified Bodies for the purposes of CE Marking, EU Emission Trading System, EU Food and Feed regulations, EU Cybersecurity act, and other EU legislation.

It is important that all Irish authorities and business satisfy themselves on the appropriate certificates for regulatory purposes and consider obtaining testing/inspection and certification services from INAB accredited organisations. The European Commission has issued notices in certain regulated sectors which may be found at here. For organisations already accredited who need to extend their scope of accreditation to promote trade in Irish goods and services, or for those who are considering accreditation, please contact INAB here.

For queries in relation to accreditation, please email inab@inab.ie or submit a question through the ContactUs form on the INAB web portal here.

The Republic of Ireland & the EU

INAB which is a Division of HSA is Irelands National Accreditation Body
UKAS in the UK is the UK’s National Accreditation Body.

In terms of EU Regulation 765/ 2008 Accreditation & Market Surveillance, it is only UK test certificates issued by a UKAS labs that are no longer recognised within the EU as the UK are not a member state.

It is understood that the Acoustical Laboratory in the National Standards Authority of Ireland NML maintain the National Reference Standards for the calibration of Class 1 and 2 SLMs and SLCs. Typically they calibrate these in accordance with IEC 61672 and IEC 60942, and use the tolerances given in each to declare compliance or otherwise.

While the NSAI is not accredited to ISO 17025, they do operate a Quality Management System in accordance with this standard. This is reviewed annually by Euramet’s Technical Committee on Quality (TC-Q). They are peer-reviewed technically by an expert from another NMI in each area every couple of years and also have ISO 9001 certification.

Recognition of Calibration Certificates: NSAI National Metrology Laboratory.

To download the International Recognition of Calibration Certificates issued by NSAI NML, click on the image below.

Statement: European Accreditation (EA) Statement on continuing recognition of UKAS under the EA MLA

January 27th, 2021|Multilateral Agreement

27 January 2021

The Brexit transition period formally ended on 31st December 2020 meaning that European Union legislation no longer applies to the United Kingdom (UK), so in this respect, it is no longer bound by Regulation (EC) No 765/2008 setting out the requirements for accreditation in the European Union (EU) nor by Regulation (EU) 2019/515 on the mutual recognition of goods.

Consequently, UKAS certificates will no longer be considered as a proof of “accreditation” within the meaning of Regulation (EC) No 765/2008 and certificates and reports issued by Conformity Assessment Bodies (CABs) accredited by UKAS are no longer recognised with respect to the EU Regulatory system as of 1st January 2021, e.g. regarding Notified Bodies for the purposes of CE Marking, EU Emission Trading System, EU Food and Feed regulations, EU Cybersecurity act, and other European Union legislation.

On 30th December 2020, the EU, the Euratom and the UK have signed a Trade and Cooperation Agreement (TCA) on a provisional basis, pending ratification. It provides for free trade in goods, ensure fair competition and limited mutual market access in services, as well as for cooperation mechanisms in a range of policy areas. However, the TCA does not change what was stated in the paragraphs above.

UKAS is a signatory of the EA Multilateral Agreement (EA MLA) which is a signed agreement between the EA Members whereby the signatories recognize and accept the equivalence of the accreditation systems operated by the signing members, and also the reliability of the conformity assessment results provided by CABs accredited by the signing members.

As signatory to the EA MLA the accreditation system operated by UKAS continues to be accepted by the other signatories as equivalent to their own accreditation system and declare, when requested, conformity assessment results (e.g. reports or certificates) issued by CABs accredited by UKAS for the relevant scope to the EA MLA, to the ILAC Mutual Recognition Arrangement (ILAC MRA) and to the IAF Multilateral Recognition Arrangement (IAF MLA) as reliable as those issued by CABs accredited by themselves.

For any further information regarding EU/UK trading please contact the relevant National authority appointed by Member States for the specific EU legislation, or the corresponding UK authority.

EA Statement on continuing recognition of UKAS under the EA MLA can be downloaded here.

For more information about the EA MLA, please visit the following page.

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