3 minute read
Post-Brexit Pump conformity – what you need to know
Post-Brexit Pump conformity – what you need to know
BPMA’s Steve Schofield looks at what manufacturers and users of pumps and pumping systems need to know about product standards and legislation, following the UK’s exit from the EU.
For 47 years, the UK has followed the rules on placing pumps on the European market, subsequently adhering to all the necessary legislation and standards.
In 2000 the EU published its ‘Blue Guide’ on implementing EU product rules for the first time. Since then, there have been updated versions to ensure that readers have the correct information to place goods onto the EU market legally. The pump sector has adopted the Blue Guide to ensure the correct interpretation is used. However, now the UK has left the EU, there is no obligation to follow the rules originating from Brussels.
It would be crazy to think that UK legislators would or even could write new rules specifically for the UK market, there are too many. So what next?
Many EU Directives have already been adopted into UK law. They are known as a Statutory Instrument (SI), and UK legislators have now removed any reference to the EU or EU courts and inserted UK references. Legislators have also confirmed that a UK version of the Blue Guide will be written and circulated during 2021.
To conform to EU legislation, the easiest method is to work to a harmonised standard that subsequently offers legislative information and a route to conformity. This is no longer applicable to the UK market, so if industry wishes to follow a similar route, then it now needs to work to UK Designated Standards – a list of which can be found at www.gov.uk/guidance/designatedstandards.
The main documentation that should accompany a pump is called the EU Declaration of Conformity in Europe, and for the UK market this will now be called the UK Declaration of Conformity (UK DOC). The information required on the UK DOC is largely the same as is required on an EU Declaration of Conformity. However, this can vary depending on the application legislation, but generally should include:
• Name and full business address or that of your authorised representative.
• The product’s serial number, model or type identification.
• A statement stating the author takes full responsibility for the product’s compliance.
• The details of the approved body which carried out the conformity assessment procedure (if applicable).
• The relevant legislation with which the product complies.
• Your name and signature.
• The date the declaration was issued.
• Any supplementary information (if applicable).
The UK DOC will also need to list:
• Relevant UK legislation – rather than EU legislation (www.bit.ly/EU2UK).
• UK designated standards (www.bit.ly/EU2UK2).
Any pump placed on the UK market will need to show the UKCA marking.
The UK standards are currently the same in substance and with the same reference as the EU standards.
Finally, any pump placed on the UK market will need
to show the UKCA (UK Conformity Assessed) marking, a new UK product marking used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods that previously required the CE marking.
The UKCA marking alone cannot be used for goods placed on the market in Northern Ireland, which require the CE marking or UKNI marking for the foreseeable future. The UKCA marking came into effect on January 1, 2021. However, to allow businesses time to adjust to the new requirements, they can still use the CE marking until January 1, 2022 (in most cases).
The CE marking is only valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and a CE mark is placed on a product based on those new rules, this product cannot be sold in Great Britain, even before December 31, 2021. chevron-
