Timber Trade & Brexit

CE Marking in a No Deal Brexit - September 2019

Executive Summary

  • UK Notified Bodies will no longer be able to support CE marking
  • UK Notified Bodies will automatically become UK Accreditation Bodies
  • Products placed on the UK market will still require accreditation
  • UK Manufacturers can choose CE marking or the new UK Accreditation mark.
  • Products exported to EU or delivered directly from outside EU must be CE marked
  • Manufacturers must transfer away from current UK Notified Body to continue CE marking
  • Manufacturers must change logo to start using new UK Accreditation mark
  • Manufacturers who mark without a notified body (level 4) can choose CE or UK marking

 

If you are currently using a UK notified Body such as BM TRADA or CATG to support CE marking for products you are placing on the market, for instance:

  • Strength Graded Timber
  • Plywood manufactured outside the EU
  • Wood Based Panels manufactured in the UK or outside the EU

 

You should speak to your UK Notified Body to discuss the options available. If you do nothing you are at risk that the construction products you are currently placing on the UK or EU market may no longer be accepted after 1st November.

 

For more information visit https://www.gov.uk/guidance/construction-products-regulation-if-there-is-no-brexit-deal and for more information about the new UK Accreditation mark, including samples, visit https://www.gov.uk/guidance/prepare-to-use-the-ukca-mark-after-brexit

Buying & selling timber

To continue to comply with the EUTR, EU and EEA businesses would be required to apply due diligence to imports from the UK. As a result, it is likely that UK-based exporters would need to provide relevant documentation about the source and legality of their timber exports to EU and EEA-based importers to enable their customers to meet their due diligence obligations under the EUTR.

 

The documents UK businesses should provide will need to allow EU importers of UK products to fulfil the due diligence requirements of the EUTR given above. EU and EEA businesses importing timber from the UK that is covered by a CITES import permit will not need to conduct due diligence.

 

The TTF’s technical notice provides further detail on the impact of a ‘No-Deal’ Brexit on the timber industry.

Construction Products Regulation & CE Marking

The Construction Products Regulation CPR is classified as a “new approach” regulation and so the following information comes from the government guidance paper “Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal”

 

A critical statement within this Government guidance is:

“Products that meet EU requirements can continue to be placed on the UK market without any need for retesting or re-marking, including where they have demonstrated compliance with EU requirements after exit day.”

 

This means that as a UK Manufacturer or Importer placing CE marked goods for construction on the UK market your business can, in the event of a deal or a no deal scenario, continue to operate legally without significant change.

 

Members are advised to check with their Notified Body to confirm they have the necessary arrangements in place.

 

As a consequence of leaving the EU, there will be changes in the longer term principally because the UK will no longer be able to participate in the EU structures developed for implementation of the Construction Products Regulation. This means to pursue the stated objective of “frictionless trade” the UK is developing a parallel system in which:

  • The Construction Products Regulation will become UK law.
  • Existing harmonised standards such as – EN.14250 for Trussed Rafters (used to demonstrate conformity with EU essential requirements) will become UK ‘designated standards’, used to demonstrate conformity with UK essential requirements. Which, immediately following exit these will be identical to EU essential requirements.
  • Notified bodies based in the UK will be granted new UK ‘approved body’ status and listed on a new UK database.
  • Approved bodies will be able to assess products for the UK market against UK essential requirements. Which, immediately after exit day in a ‘no deal’ scenario, will be identical to EU essential requirements.
  • A new UK conformity mark is being developed by the UK government which manufacturers selling goods on to the UK market will then be able to affix before placing a product on the UK market.

 

For UK manufacturers wishing to export and place CE marked goods for construction on the EU market, your business can, in the event of a deal or a no deal scenario, continue to operate legally provided the notified body you are using is registered in an EU member state or has a partnership arrangement with such a body.

 

Click here for more information.

Trading & Moving Endangered Species Protected by CITES

This includes both endangered animals and plants. Find the government’s paper here.

FAQs on CE Marking in a No Deal Brexit

TTF’s guide on which products will or won’t have import tariffs in a No Deal Brexit

Temporary rates of customs duty on imports if the UK leaves the EU with no deal