1.
UL and the UL logo are trademarks of UL LLC © 2022.
What Brexit Means for the PPE
and Marine Regulations in
Europe and the UK
Brexit and UKCA webinar
UL AND THE UL LOGO ARE TRADEMARKS OF UL LLC © 2022. ALL RIGHTS RESERVED. THIS DOCUMENT MAY NOT BE COPIED WITHOUT
WRITTEN PERMISSION FROM UL AND ONLY IN ITS ENTIRETY. THE DOCUMENT IS FOR GENERAL INFORMATION PURPOSES ONLY AND IS
NOT INTENDED TO CONVEY LEGAL OR OTHER PROFESSIONAL ADVICE. THE INFORMATION PROVIDED IN THIS DOCUMENT IS CORRECT
TO THE BEST OF OUR KNOWLEDGE, INFORMATION AND BELIEF AT THE DATE OF ITS PUBLICATION.

2.
What we are going to
discuss
• What is Brexit?
• Overview of the EU regulatory
environment
• Overview of the new U.K. legislation and
marks
• What this means for you
• How UL can help

3.
What is Brexit?

4.
The UK and
Europe
EU27

5.
The UK

6.
Overview of the EU regulatory environment

7.
EU regulations and marks
PPE Regulation Marine Equipment Directive
(EU) 2016/425 2014/90/EU

8.
Placing PFD’s on the EU market
PPE Regulation
Category 2
PPE Regulation
Category 3
Marine Equipment
Directive
Market placement General market General Market
Placement on board EU
flagged ship
Products Buoyancy Aids
Lifejackets; Immersion
Suits; Abandonment
Suits
Lifejackets; Immersion
Suits; Lifebuoys;
Thermal Protective Aids
Required
Modules/Certificates
B B + (C2 or D) B + (D; E; or F)
Typical Standards EN ISO 12402-5
EN ISO 12402-4;
EN ISO 12402-3;
EN ISO 12402-2;
EN ISO 15027
MSC.81(70) / LSA Code
2017
UL and the UL logo are trademarks of UL LLC © 2022.

9.
Overview of the new UK legislation
and marks

10.
EU and UKCA regulations and marks
EU
PPE Regulation Marine Equipment Directive
(EU) 2016/425 2014/90/EU
U.K.
Personal Protective Equipment Regulations
(Regulation (EU) 2016/425 as introduced to
U.K. law and amended)
Merchant Shipping (Marine Equipment)
Regulations 2016 SI 2016/1025
(EU) 2016/425 amended
by SI 2019/696
Merchant Shipping (Marine Equipment
(Amendment, etc.) (EU Exit)
Regulations 2019 SI 2019/470

11.
How the regulations will work
• The requirements of the EU Regulations
and Directives became U.K. law and
remain substantially the same.
• Any responsible person or authorized
representative appointed must be based
in the U.K.
• Current EU Harmonised Standards
will be published as U.K. Designated
Standards.
• There is currently no system in place to
update Designated Standards should EN
standards be reviewed and amended.
• Market Surveillance remains the same
for the U.K.:
• PPE at work — Health and Safety
Executive
• PPE for private users — Trading
Standards
• Office for Product Safety and Standards
controls the strategy

12.
PPE regulation implementation period
U.K.
• The United Kingdom Conformity Assessed (UKCA)
regime applies since Jan.1, 2021.
• Since Jan. 1, 2021, goods can be placed on the U.K.
market with the CE or UKCA marking until Jan. 1,
2023.
• Starting January 2023, goods can only be placed on
the U.K. market with the UKCA marking.
• UKCA marking Category 2 products require a Module
B certificate issued by a U.K. Approved Body.
• UKCA marking Category 3 products require a Module
B and either a Module C2 or D certificate issued by a
U.K. Approved Body.
• Until Jan. 1, 2023, UKCA marking can be applied by
a label affixed to the product or on accompanying
packaging.
EU
• Since Jan. 1, 2021, certificates issued by
U.K. Notified Bodies are no longer valid
for placing products on the EU market.
• EU Notified Bodies must establish an
entity and register as an Approved Body
in the U.K. to issue the UKCA marking.

13.
Marine shipping regulations implementation
period
U.K.
• The United Kingdom Red Ensign
regime applies since Jan. 1, 2021.
• Since Jan. 1, 2021, goods can be placed
on U.K. flagged ships with a Wheel mark
or Red Ensign mark until Jan. 1, 2023.
• Starting January 2023, goods can
only be placed on U.K. ships with a
Red Ensign mark.
• Red Ensign mark products require
a Module B and either a Module D,E
or F certificate issued by a U.K.
Approved Body.
EU
• From Jan. 1, 2021, certificates issued by
U.K. Notified Bodies are no longer valid
for placing products on the EU market.
• EU bodies must establish an entity and
register as an Approved Body in the U.K.
to issue a Red Ensign mark.

14.
Northern Ireland (the exception)
• The exception to the UKCA mark is
the Northern Ireland Protocol.
• The protocol was developed to avoid a
hard border between Northern Ireland
and Ireland.
• It remains with the consent of the
people of Northern Ireland, and a
vote will happen every four years.
The first vote will take place in 2024.
• Northern Ireland remains in regulatory
alignment with the EU, meaning:
• CE marked products continue to be accepted
in Northern Ireland.
• If a U.K. Approved Body carries out the
assessment for goods going to Northern
Ireland, then the UKNI mark is applied.
• Northern Ireland has unfettered access to the
rest of the Great Britain market, meaning CE and
UKNI products can be placed on the Great Britain
market from manufacturers in Northern Ireland.
• UKCA marked products alone cannot be placed
on the Northern Ireland market.

15.
What marks
are required
where?
Source: www.gov.uk/guidance/using-the-ukni-marking

16.
What this means for you

17.
Major changes
that might
affect you
Manufacturers with U.K.
Notified Body:
Require certificates issued by
an EU27 Notified Body to place
goods on the EU market.
Manufacturers with EU
Notified Body:
To place goods on the U.K.
market, manufacturers will need
to obtain certificates from a
U.K. Approved Body this year.

18.
How UL can help

19.
How UL can help
UL International (Netherlands) B.V.
• Accredited by RvA to issue Module B/C2/D
under PPE Regulation (EU) 2016/425.
• Accredited by RvA to issue Module B/D/E/F
under Marine Equipment Directive
2014/90/EU.
UL International (U.K.) Ltd.
• Accredited by UKAS to issue Module B/C2/D
under PPE Regulation (EU) 2016/425
(EU Exit).
• Accredited by UKAS to issue Module B/D/E/F
under Merchant Shipping Regulations.
UL can provide market access services for
both the U.K. and EU at the same time.

20.
Michael Kirkland
Senior project engineer
Michael.Kirkland@ul.com
Questions?

21.
UL and the UL logo are trademarks of UL LLC © 2022.
Thanks for listening