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BREXIT & Certification Today – 8 January 2021

The UK left the EU on Friday 31 January 2020. Until 31 December 2020, certification continued as before with certificates issued by UK Notified Bodies remaining valid in the EU and certificates issued by EU Notified Bodies remaining valid in the UK.

On 24 December 2020, a post Brexit deal was agreed between the EU and the UK. However, a mutual recognition agreement in respect of certification was not reached. Consequently, certificates issued by UK Notified Bodies ceased to be recognized in the EU after 31 December 2020 and certificates issued by EU Notified Bodies will cease to be recognised in Great Britain (England, Scotland and Wales) after 31 December 2021.

The SGS Group can continue, through our European and UK networks, to provide clients with certification services for products to be placed on the EU and/or on the UK markets.

ATEX, PPE, MID Machinery and RED

SGS in Finland (SGS Fimko) has been appointed as a Notified Body for ATEX, Personal Protective Equipment (PPE) and Measurement Instruments Directive (MID) with its scope extended under Machinery and Radio Equipment Directive (RED). This allows SGS to provide continued Notified Body approvals through its UK operations (SGS Baseefa and SGS United Kingdom Ltd).

SGS United Kingdom Ltd is also working with SGS Portugal for Notified Body Services for PED, TPED and SPVD.

For further information, please contact:

Medical Devices

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

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

To register an interest for CE marking to MDR/IVDR or the new UK Conformity Assessed mark (UKCA), MDSAP, FDA’s 3P510k and ISO 13485:2016 please e-mail SGS Medical UK.

Forestry Update – UK Timber Regulation

The European Timber Regulation (EUTR) and Forest Law Enforcement Governance and Trade (FLEGT) no longer apply in Great Britain (England, Scotland and Wales).

EU Timber Regulation Guidance for Business and Industry confirms that:

The “Timber and Timber Products Placing on the Market Regulations” (UKTR) and “UK FLEGT Regulations” apply in Great Britain from 1 January 2021, but the requirements remain the same as under EUTR.

The UKTR confirms that:

“Any natural or legal person who buys and sells timber or timber products already placed on the GB (England, Scotland and Wales) market – a trader – or first places timber or timber products on the GB market – an operator – is responsible for compliance.”

Learn more

Northern Ireland

Special arrangements apply for Northern Ireland. Again, EU Timber Regulation Guidance for Business and Industry confirms the following:

While NI remains part of the UK customs union, EU Timber regulations are in force. If you are acting as an operator or a trader in Northern Ireland you should follow the specific guidance at: 
UK Timber Regulation: Imports and Exports of Timber and Timber Products

In summary this states that if you are moving timber to or from NI, you should be aware of the following:

  • There will be no new Due diligence checks on timber flowing from NI to GB
  • Due diligence checks will take place on timber flowing from GB to NI
  • Due diligence checks will take place on timber entering NI directly from non-EU countries. They will not take place if entering directly from an EU or EEA country

UK Notified Bodies Certificates and Trade Solely within the UK

Certificates issued by UK Notified Bodies continue to be valid in the UK after 31 December 2020 and we will continue our normal certification activities for clients, 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 UKCA mark is a new UK product marking, available for use now, which is mandatory for goods being placed on the market in Great Britain from 1 January 2021. It covers most goods which previously required the CE marking. Learn more at UKCA Mark.

However, in order to allow businesses time to adjust, most CE marked goods that meet EU requirements (where these match UK requirements) can continue to be placed on the market in Great Britain until 1 January 2022 where EU and UK requirements remain the same. This includes goods which have been assessed by an EU recognised notified body.

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

UKCA Webinars

The Department for Business, Energy & Industrial Strategy is hosting a series of webinars which will discuss UKCA marking to place goods on the market in Great Britain. Click here to view the webinars and register.


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 1 January 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 at Customs Brokerage


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:

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