Hi Folks
Don’t count 100% on there being no more EU exits if – and I’m quite serious – more extreme Right Wing politicians get into power in their respective member countries as quite a few of them are very nationalistic and anti-EU! NB: that is NOT meant in any way to be a “politically-biased comment”, just an observation on what is actually going on in some member countries across the EU ! John E Allen W. London, UK. From: Glyn Payne <[email protected]> Sent: 09 November 2022 17:51 To: [email protected] Subject: Re: [PSES] Intertek message FYI: Important Update: Pending Regulatory Change to UKCA Program Hi John, Fingers crossed there will be no more EU exits, though it would make producing safety guides in all EU languages a bit easier! All the best, Glyn From: John Mcbain <[email protected] <mailto:[email protected]> > Sent: 08 November 2022 21:08 To: Glyn Payne <[email protected] <mailto:[email protected]> > Cc: [email protected] <mailto:[email protected]> Subject: Re: [PSES] Intertek message FYI: Important Update: Pending Regulatory Change to UKCA Program Hi Glyn - Thanks for your comments! I understand that each EU country implements the EU regulations for itself, although homogeneous application is expected (after the discussion and voting you mentioned). However, as I said in my previous message, I was selfishly looking only at the additional product regulatory work for me, if every country in the EU decided to follow the example of the UK and implement separate national regulations, marking and documentation instead of the uniform CE Marking and Declaration of Conformity. I am not particularly interested in sovereignty, but I am interested (dismayed, actually) at the thought of doing 10 times more work with the same resources and absolutely no value added. Best regards, John McBain On Tue, Nov 8, 2022 at 9:00 AM Glyn Payne <[email protected] <mailto:[email protected]> > wrote: Hi John, “I would hate to see the other countries in the EU decide to seize national sovereignty and implement their own regulations,” Good point, however the Sovereignty bit was always a red herring since any Directive issued by the EU is already agreed by the Commission, who are the member governments, so the UK Government would be party to any Directive in the first place. The Commissions Directive is then voted on by the MEPs, which of course included elected UK MEPs, and if passed then the Directive is issued to all member states for them to implement in a way that is compatible with their Sovereign Laws. In the UK’s case, before a Directive became UK Law it was scrutinised and voted on by UK MPs, then scrutinised and voted on by the House of Lords, before it ultimately becomes part of UK Sovereign Law. No EU Directive could ever be imposed in individual sovereign governments without the agreement of their Parliaments. All the best, Glyn Payne. From: John Mcbain <[email protected] <mailto:[email protected]> > Sent: 07 November 2022 22:08 To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] Intertek message FYI: Important Update: Pending Regulatory Change to UKCA Program My apologies to everyone - I did not intend to drift into a political discussion! My question was meant to be focused on the product safety / regulatory concerns that arose after Brexit (that is, ones that did not previously exist), NOT whether sovereignty is good or bad in any other way. >From just that single-minded perspective I found in my own job that Brexit >created more work without adding an iota of value to the product. Also from >that selfish point-of-view I would hate to see the other countries in the EU >decide to seize national sovereignty and implement their own regulations, >their own markings and their own paperwork. 😖 In other words from the narrow product safety / regulatory position (which is how I was looking at it), "encouraging [the UK] to exit from the EU" did the OPPOSITE of the "removal of unnecessary trade barriers". It may or may not have had other beneficial results - a political argument for which this is NOT the forum - but for me it just meant more paperwork that previously had not existed. Along the same lines in the US - the National Electric Code (NEC) is a guide for the thousands of Authorities Having Jurisdiction (AHJ) within the country - in other words "sovereignty" within their city / county / state - to decide what applies to their bailiwick. Does this make life easier for those trying to build or install a product if the standards vary across the country? Certainly not! Which of course is one reason why UL / Intertek / CSA / other NRTLs have been successful. But that is another discussion. Best regards, John McBain On Mon, Nov 7, 2022 at 11:18 AM Lfresearch <[email protected] <mailto:[email protected]> > wrote: Easy John, but first address my key issue with the EU: surrender of sovereignty. Period. Second, EU is not the only trading market, something missed by members of the community. It’s a fact the CE mark adds way more cost than the return on investment of performance improvement. Not having to do this simplifies the route to market compliance and hence makes the product cheaper. I could go on, but I have to teach today, I’d be happy to resume the discussion later. BUT, reemphasize my first point: surrender of sovereignty. Period. Cheers, Derek. On Nov 7, 2022, at 1:04 PM, John Mcbain <[email protected] <mailto:[email protected]> > wrote: Hello Lfresearch - Would you please explain to me how you reconcile "removal of unnecessary trade barriers" and "encouraging for England [note: actually UK] to exit from the EU"? Those views seem to be mutually incompatible, since Brexit has raised new non-tariff trade barriers (additional certifications, markings, etc.). Best regards, John McBain On Mon, Nov 7, 2022 at 10:14 AM Lfresearch <[email protected] <mailto:[email protected]> > wrote: I think most people have learned to not listen to MSM, but rely on individuals in groups like this to further knowledge. It’s highly beneficial to have working members, most without a dog in the fight, in multiple economic zones. That said, and to counterpoint a different position, I was originally in favor of England joining the EU many years ago since the idea of removing barriers to free trade is highly appealing. HOWEVER, what has transpired while populations have been asleep at the wheel is nothing other than a power grab of sovereignty: Totally unacceptable and it was highly encouraging for England to exit from the EU and I hope other will follow. I have a hope that the UK and the rest of the world can work toward the removal of unnecessary trade barriers and standardization. Something I devote many hours a day promoting. Cheers, Derek. On Nov 7, 2022, at 11:45 AM, Doug Powell <[email protected] <mailto:[email protected]> > wrote: Thanks John, As you can imagine mainstream media tends to give us a filtered view, with various unspoken motivations. This is the very reason I do not rely upon a single source. And of course, guidance provided on https://www.gov.uk <https://www.gov.uk/> should always be viewed in its official capacity. I appreciate your insider's perspective, -Doug Douglas E Powell Laporte, Colorado USA <https://www.linkedin.com/in/coloradocomplianceguy/> LinkedIn (UTC -06:00) Mountain Time (US-MDT) On Mon, Nov 7, 2022 at 9:58 AM <[email protected] <mailto:[email protected]> > wrote: Doug & co I can only speak for myself and what I have seen & heard in the mainstream broadcast media (don’t do Twitter, FB etc!). The majority viewpoint seems to be that it is far too late to do anything in the short-medium term about re-joining the EU, even if there was another referendum on the subject that said “Yes, Rejoin”. None of the main-stream political parties are pushing for it (at least those in England, but there are very different views held by some parties in Wales, N. Ireland and especially the SNP in Scotland!). Thus I can’t see it happening “anytime soon”, if at all! FWIW: To state my personal perspective, I was very much in favour of the UK joining in the first place many years ago because of my experiences of the many “technical barriers to trade” which made exporting to the then (IIRC!) Common Market countries really difficult due to all the differences between them. Then, in the Referendum I was very much in favour of Remaining in the EC & very disappointed in the (marginal!) result (my opinion of those who voted to leave was/still is fairly unprintable – something about “cutting off your nose to spite your face”!) John E Allen W. London, UK From: Doug Powell <[email protected] <mailto:[email protected]> > Sent: 07 November 2022 16:15 To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] FW: Intertek message FYI: Important Update: Pending Regulatory Change to UKCA Program I've been watching the latest UK news with interest. From my perspective in the US news media, it seems with the financial, energy, and PM woes, there is a small movement discussing how BREXIT may have been a mistake. Possibly John Allen can elaborate about how the locals feel about this, Is there any real possibility of reverting to EU membership, or not? thanks, -Doug Douglas E Powell Laporte, Colorado USA <https://www.linkedin.com/in/coloradocomplianceguy/> LinkedIn (UTC -06:00) Mountain Time (US-MDT) On Mon, Nov 7, 2022 at 8:53 AM Richard Georgerian <[email protected] <mailto:[email protected]> > wrote: Greetings all, As a follow-up to John Allen’s email below – Has the UK submitted and/or passed any legislation for the UKCA labelling easement until December 31, 2025? Otherwise, the UKCA labelling starts on December 31, 2022. I went to the www.gov.uk <http://www.gov.uk/> website and there is no mention of the specific legislation. Just the announcement that the UK intends to submit legislation for the easement. Thank-you, …Richard Georgerian Compliance Engineer HID Global From: John E Allen <[email protected] <mailto:[email protected]> > Sent: Thursday, August 4, 2022 9:01 AM To: [email protected] <mailto:[email protected]> Subject: [PSES] FW: Intertek message FYI: Important Update: Pending Regulatory Change to UKCA Program For anyone who has not seen this or something similar! John E Allen W.London, UK From: Intertek <[email protected] <mailto:[email protected]> > Sent: 03 August 2022 12:58 To: [email protected] <mailto:[email protected]> Subject: Important Update: Pending Regulatory Change to UKCA Program The UK Government has announced its intention to introduce new regulation as a principle ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ <http://links.intertek.mkt4245.com/els/v2/pwaLHKk2DmCr/WFpETTVWYjJqaDhRL3kwZmJzejB4VE05NlQwVlBlNUtvRGx0dDVOaWNGZ0RZYmtrdCtybytMRVJxb0UwWVhzRnBkaWZROWJwcnJiU1BjTWdxc0J4MDduTUxhQWx0R1k2d2c1TTNWR2ZSMFE9S0/b3grNmY2R3BIM2RhZ1VheDBwYlVydUt2VjRQV3piYUtiOHgvbTNvSGIyd3g0eVQrVEVMbEtJWElxS0V0U2lZNjZveVQzQTFUSjF3YjZnaWhyNDNLR2E5b0dZUFduUFgvZGhlQVZBLzM1YncxYVY1TE8zcU5EVitsbnRmMGNBMDBEUENMaE9QTmVudmhvM1Q1MXJrcmZQZkR1MkZtRXo2bU1wVVgrWTlIVFY0PQS2> <https://cdn.intertek.com/mail/images/2018_template/tqa_white.png> The UK is pending a regulatory change to their UKCA Program The UK Government has announced its intention to introduce new regulation as a principle so to reduce the costs involved for the re-certification/re-testing of products for UKCA marking. This new regulation, when introduced (no timelines given), and based on the summary notice criteria, will effectively increase the acceptance of CE marking of products as a means of meeting UKCA marking requirements. Until this new regulation is introduced, the current framework, timelines and conformity assessment process for UKCA marking remains, in that from 01 January 2023, CE marking will no longer be accepted when placing product onto the Great Britain Market. The full details of the UK Government announcement can be found <http://links.intertek.mkt4245.com/els/v2/K6~VJWdr~zQZ/WFpETTVWYjJqaDhRL3kwZmJzejB4VE05NlQwVlBlNUtvRGx0dDVOaWNGZ0RZYmtrdCtybytMRVJxb0UwWVhzRnBkaWZROWJwcnJiU1BjTWdxc0J4MDduTUxhQWx0R1k2d2c1TTNWR2ZSMFE9S0/> here. Please refer to the 22 June update. <http://links.intertek.mkt4245.com/els/v2/_k~8BzWqA_QR/WFpETTVWYjJqaDhRL3kwZmJzejB4VE05NlQwVlBlNUtvRGx0dDVOaWNGZ0RZYmtrdCtybytMRVJxb0UwWVhzRnBkaWZROWJwcnJiU1BjTWdxc0J4MDduTUxhQWx0R1k2d2c1TTNWR2ZSMFE9S0/> READ THE UPDATE On Introduction of The New Regulation In summary, product conformity assessment will see the following changes: * Completed conformity assessment activities carried out on product under EU requirements (including existing testing, certification, and contractual arrangements relating to the quality control or auditing of existing certificates) undertaken by non-UK conformity assessment bodies (EU Notified Bodies accredited by their national accreditation body) for CE certification before 1 January 2023 to be used by manufacturers to declare existing product types as compliant with UKCA. * Products must still bear UKCA marking and will need to undergo conformity assessment with a UK Approved Body at the expiry of the certificate or after 5 years (31 December 2027), whichever is sooner. * Manufacturers to apply the UKCA mark without the need for any UK-recognised CAB involvement and continue to place their goods on the market, on the basis of their existing CE type examination completed before 31 December 2022, for the lifetime of the certificate issued, or until 31 December 2027 (whichever is sooner). * Conformity assessment procedures not completed and supported by a CE certificate issued before 1 January 2023, these products are considered ‘new’ products. This also includes where goods are subject to important changes, overhauling its original performance, purpose, or type requiring new certification. Any ‘new’ good must comply with GB regulatory requirements, including the requirement for conformity assessment by a UK approved body from 1 January 2023. The new legislation when introduced concerning UKCA marking effect only the following UK Regulations: * Noise Emission in the Environment by Equipment for Outdoor Use Regulations 2001 * Supply of Machinery (Safety) Regulations 2008 Ecodesign for Energy-Related Products Regulations 2010 * Toys (Safety) Regulations 2011 * Explosives Regulations 2014 * Pyrotechnic Articles (Safety) Regulations 2015 * Electromagnetic Compatibility Regulations 2016 * Simple Pressure Vessels (Safety) Regulations 2016 * Lifts Regulations 2016 * Pressure Equipment (Safety) Regulations 2016 * Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 * Non-automatic Weighing Instruments Regulations 2016 * Measuring Instruments Regulations 2016 * Recreational Craft Regulations 2017 * Radio Equipment Regulations 2017 * Regulation 2016/425 on personal protective equipment as it applies in GB * Regulation 2016/426 on gas appliances as it applies in GB <https://cdn.intertek.com/mail/images/2018_template/location.png> Our Address Intertek Day Ave Knowlhill Milton Keynes MK5 8NL <https://cdn.intertek.com/mail/images/2018_template/chat.png> Urgent Testing Need? 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