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BREXIT Today – 16 December 2020

The UK left the EU at 11pm on Friday 31 January 2020. Certification will continue as usual until 31 December 2020. This means that certificates issued by UK Notified Bodies will remain valid in the EU; technical files can remain in their current location and clients can continue to place products on the market in the UK and EU until 31 December 2020.

The terms of any long-term trade agreement between the EU and UK will ultimately determine whether certificates issued by UK Notified Bodies will continue to be recognized in the EU, and vice versa after 31 December 2020. Whilst we still hope that Mutual Recognition Agreements (MRAs) of some sort will be finalized there is no certainty.

The SGS Group can continue, through our European and UK networks, to provide clients with certification services regardless of the outcome of any EU/UK trade negotiations. We will post further guidance specifically regarding UK Notified Bodies as the outcome of the negotiations becomes clearer but in the interim please see below for details of how the SGS Group can assist you.

ATEX, PPE, MID Machinery and RED

SGS in Finland (SGS Fimko) has been appointed as a Notified Body for ATEX, PPE and MID with its scope extended under Machinery and RED. This allows SGS to provide continued Notified Body approvals through its UK arm (SGS Baseefa and SGS United Kingdom Ltd) even if no form of MRA is agreed.

For further information, please contact:

  • ATEX – Equipment and protective systems intended for use in potentially explosive atmospheres – Phil Oates, tel: +44 (0)1298 766627
  • PPE – Personal Protective Equipment
    • Article 10/Module B – Kelvin Shepherd, tel: +44 (0)1934 522917
    • Article 11/Module C2/D – Kevin Foy, tel: +44 (0)776 8408545
  • MID – Measurement Instruments Directive, 2014/32/EU – Zee Ellahi, tel: +44 (0)191 377 2000
  • MD – Machinery Directive, 2006/42/EC – Zee Ellahi, tel: +44 (0)191 377 2000
  • RED – Radio Equipment Directive, 2014/53/EU – Zee Ellahi, tel: +44 (0)191 377 2000
  • EMC – Electromagnetic Compatibility, 2014/30/EU – Zee Ellahi, tel: +44 (0)191 377 2000
  • PED – Pressure Equipment Directive – Mark Homer, tel: +44 (0)121 541 4717
  • TPED – Transport Pressure Equipment Directive – Mark Homer, tel: +44 (0)121 541 4717
  • SPVD – Simple Pressure Vessel Directive – Mark Homer, tel: +44 (0)121 541 4717

Medical Devices

SGS Belgium (NB 1639) provides services under the Medical Device Directive (MDD) for current clients and is in the process of getting designation for Medical Devices Regulation (MDR) which will replace the MDD in 2021. SGS Finland is also in the process of seeking designation under the new MDD.

SGS United Kingdom Limited UK (NB 0120) will provide services for the UKCA scheme.

If you want to make an inquiry or to register an interest for CE marking to MDR or UKCA, MDSAP and ISO 13485:2016 send an e-mail to

Forestry Update – UK Timber Regulation

The European Timber Regulation (EUTR) and Forest Law Enforcement Governance and Trade (FLEGT) will no longer apply in Great Britain (England, Scotland and Wales) from 1 January 2021. You should prepare for the rules that will apply to buying and selling timber and timber products from 1 January 2021.

Learn more

UK Notified Bodies Certificates and Trade Solely within the UK

Certificates issued by UK Notified Bodies will continue to be valid in the UK after 31st December 2020 and we will continue our normal certification activities, unless instructed otherwise. If you deal solely within the UK, you will not need to transfer unless you are aware of other influences which you need to address.

The New UK Mark

The UK Conformity Assessed (UKCA) mark is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market, which require the CE marking or UK(NI) marking. See further government guidance on placing goods on the Northern Ireland market.

Learn more


A major area of concern for many of our customers is the future arrangements governing the physical movement of goods across European borders.

As of January 1, 2021, customs declarations must be filed for all shipments between the UK and the EU. This new obligation can create additional risks, costs and delays for your company.

To make compliance easy for you, we have customs solutions available in the UK and all neighbouring countries. We offer a one-stop shop, with services ranging from automated to completely outsourced, supported by in-house software solutions, to help you with your Brexit customs declarations.

Learn more


Please visit this section regularly to keep up to date with the latest guidance and updates.

Technical notices concerning the regulation of chemicals in the UK in a no-deal scenario:

Updates from SGS:

Don’t second guess the future

Check current trade with EU countries. Prepare for the transition period, and beyond.

Contact the experts