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BREXIT TODAY – 04 March 2019

Delivering a deal negotiated with the EU remains the UK Government’s top priority but neither SGS, nor any other Notified Body, can make any guarantees with respect to the post-Brexit position.

At present, we see the following possible scenarios:

  • A UK/EU withdrawal deal is agreed, and certification continues as usual during the Implementation Period running until December 2020. Mutual Recognition Agreements may be agreed during this time to allow the continued functioning of UK Notified Bodies after this date; or
  • The UK leaves the EU without a deal and UK Notified Bodies are no longer recognized by the EU and UK-issued certificates are no longer valid; this continues to be the position of the EU Commission; or
  • There is an extension of Article 50 and certification continues as usual for an agreed period of time. It is highly likely that such an extension will result in some sort of deal with an implementation period similar to that in the first scenario.


We are pleased to announce that 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) in the event of a no deal Brexit.

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


The UK Government have communicated its intention to create a new UK mark and has confirmed that all current UK Notified Bodies will transfer as Approved Bodies for the new scheme. This does not apply to Medical Devices or Transportable Pressure Equipment but UK Government has confirmed that all other sectors will transfer automatically in the event of a hard Brexit.

For companies selling only into the UK, this will remove the need to seek EU notification and very quickly provide a route to market in the UK for new products.


A major area of concern for many of our customers are the future arrangements governing the physical movement of goods across European borders. Again, we want to assure our customers that we are working closely with our European Affiliates to ensure we will have in place an effective network that can deliver whatever documentation and certification requirements are required for the movement of goods post-Brexit.


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