Some of you may have noticed that under certain CE Marking Directives (at the moment: Machinery, PPE and Construction Products), the list of Harmonised Standards has disappeared from the Official Journal.

This is the new format that the European Union will be using to publish Harmonised Standards and is as a result of Regulation (EU) No. 1025/2012 on European Standardisation and a number of European Court of Justice rulings.

The essence of these rulings is that lists of Harmonised Standards must now be issued as Legislative (L) notices and not Informative (C) notices. The change to legislative notices also means that the European Union is unable to issue ‘Consolidated Lists’ and therefore the amended notices will now have specific lists of new references and withdrawn references.

The upshot of this is that Harmonised Standards will no longer be listed on the web page itself but will be listed within .pdf files referenced on the web page. At the moment, two files are referenced; the legacy consolidated list and the new specific list. The best way to assess whether a Standard is harmonised is to first search the consolidated list, then the specific list to assess whether a Standard has been withdrawn or introduced. How the system will work when there are multiple amendments remains to be seen.

If you need any help and support in identifying or applying Harmonised Standards then please call us on 01564 792349.

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UPDATE: As you may have recently heard, the date of the UK’s Departure from the European Union has been delayed until May 22^nd if the UK Parliament agree the Withdrawal Agreement or until April 12^th if it doesn’t. We look at how this may affect your CE Marking obligations.

Note: At the time of writing, this extension has not received the parliamentary consent which it requires in order enact either of those two dates into UK law.

We recently updated our members on the UK Government plans to introduce a ‘UKCA’ mark. This mark has been introduced to enable manufacturers to place their products on the UK market in a ‘No Deal’ scenario where they are unable to CE Mark. Where Manufacturers are still able to apply the CE mark, they should do so. The amending legislation has now passed through parliament and will become UK law only if the UK leaves the EU without a withdrawal agreement. The UK Government has published updated guidance here:

The amending legislation covers two other important functions: to transfer UK Notified Bodies to ‘Approved Body’ status and to mirror the EU Official Journal to give harmonised Standards ‘Designated Standard’ status in the UK. There are also a number of other amendments to enable UK law to mirror legacy EU legislation as closely as possible.

Our advice to manufacturers in the event of a ‘No Deal Brexit’ remains unchanged; unless you fall into one of the two categories below, you should continue to CE Mark your products as before:

– Manufacturers who use a UK Notified Body should contact that body ASAP to understand their ‘Post Brexit’ plans or if, indeed the UKCA mark is more appropriate

– Manufacturers who distribute through an EU supply chain should understand that the economic operator status of that supply chain will change which may require changes to packaging.

Manufacturers of Machinery are also reminded that if they intend to place products on the EU market following a ‘No Deal Brexit’, they should nominate the person who is responsible for compiling the Technical File who must be located within the EU.

The CE Marking Association will continue to follow the Brexit process and consider its effects on CE Marking for UK Manufacturers; we will publish updates as they become available however if you wish to discuss any topics related to CE Marking, then please get in contact.

Harmonised Standards, although not forming part of the legislative requirements (with some exceptions e.g. Construction Products), offer the ‘best practice’ route to demonstrating conformity to the relevant CE Marking legislation. A number of common Standards have undergone either amendment or re-issue which has spawned a number of queries regarding which revisions of Standards should be used.

A Standard becomes ‘harmonised’ when its reference is published on the Official Journal of the European Union (OJ), this will only happen once the European Union is satisfied that the new Standard meets the requirements to offer a presumption of Conformity to the legislation, and after that Standard has been published by the relevant Standards body.

As such, the ‘current’ revision of the Standard as quoted on, for instance; the BSi website may not be published on the OJ and it may instead be a withdrawn or superseded revision that offers presumption of Conformity.

Three very common electrical safety standards currently fall into this category and therefore manufacturers should take care when selecting the appropriate Standard; EN 60204-1:2006 + A1:2009, EN 60335-1:2012 + A11 2014 and EN 61010-1:2010 should be used for CE Marking purposes despite having been superseded by EN 60204-1:2018, EN 60335-1:2012 + A13:2019 and EN 61010-1:2010 + A1:2019 respectively.

Once harmonised, the OJ will indicate a ‘Transition Period’ during which either revision of the Standard may be used, the previous revision only ceasing to offer presumption of conformity at the end of this transition period.

The CE Marking Association will monitor these three very common electrical safety standards and we will issue another communication when we become aware of a new revision being published on the Official Journal.

If you require any help and support with CE Marking under the Low Voltage Directive, then please call us on 01564 792349.

Over 140 people attended the three CE Marking Seminars given at the Southern Manufacturing Show earlier this month which looked at the CE Marking process in general as well as exploring recent or imminent changes to legislation and of course, Brexit!.

Members of our Technical Team were on hand to help and advise both before and after the seminars. If you are interested in ongoing support for your CE Marking requirements, we offer membership of the CE Marking Association, details of which can be found here.

We look forward to welcoming you at similar events in the future, please keep an eye on our website for details of future seminars.

A copy of the presentation is available to download here (.pdf – 4.0Mb)

The CE Marking Association is once again attending the Southern Manufacturing & Electronics Show (Farnborough International) providing CE marking seminars. This year, Representatives of the CE Marking Association will give an overview of the CE marking process, discuss the implications of BREXIT and look forward to any changes in product legislation. At the end of the presentation, there will be an opportunity to ask our team any questions on CE Marking.

The show runs from the 5th – 7th February 2018 and our seminar times are:

Tuesday 5th February @ 12:00pm (Seminar Room 2) – CE Marking 2019 & Beyond (Tim Harrison* – CE Marking Association) Wednesday 6th February @ 12:00pm (Seminar Room 1) – CE Marking 2019 & Beyond (Mike Foster* – CE Marking Association) Thursday 7th February @ 10:00am (Seminar Room 1) – CE Marking 2019 & Beyond (Jim Kennard* – CE Marking Association) * Presenter TBC

The show and our seminars are free to attend and there is free parking on-site. It is not too late to register your attendance; visit the industrysouth.co.uk website or register on the day.

We hope to see you at the show.

If you would like to follow up any CE Marking questions, then please feel free to get in contact.