Brexit and NB (Notified Bodies):
What You Need to Know
The latest updates and frequently asked questions around the hot topic of Brexit and NB (Notified Bodies)

If you are a manufacturer or distributor based in the UK or situated in the EU and need to know more about how Brexit and changes to NB’s (Notified Bodies) may affect you, this page is dedicated to answering the most topical questions on this subject.

Note: All answers are correct as of 18th January 2021.

Frequently Asked Questions

Do you have to have different notified bodies for the CE and UKCA Marks?

UKCA and UKNI Marks require that third party assessment activities carried out are done by a UK Approved Body, while CE Marking assessment activities need to be carried out by an EU Notified  Body. The BBA has formed a partnership with an EU Notified Body to prevent any duplication of activity and to facilitate an efficient process for our clients.

Is there an equivalent to EOTA (European Organisation for Technical Assessment) under the new system?

At the moment no there isn’t, but this is under discussion. The BBA has been asked whether they we would be prepared to stay as an observer on EOTA, which we’ve agreed to, but would hope for a more active role.

It is likely that there will be a UK equivalent to EOTA and the BBA are, together with other UK TABS, engaging with MHCLG to progress this, but there has been no official UK guidance as yet.

Where a UK notified body has carried out tasks or issued certification in relation to the AVCP (Assessment or Verification of Performance) for a product before 1st January 2021, can that approval be used to support affixing a UKCA Mark?

Yes, this existing Certification is acceptable and no further action is necessary.

Will testing carried out by a UK Notified Body which was EU Notified at the time of testing, still be accepted in support of CE Marking by an EU Notified Body?

Both the UK and the EU wish to minimise duplication of efforts and costs by the manufacturers.

At present it does appear that the EU will refuse to accept such testing and that retesting by an EU Notified Body will be required.  There is some reason to believe that this position may change as a result of the negotiated Agreement, but the details are unclear and require interpretation. We are waiting for further guidance for UK Government.

As soon as we have additional clarity around this topic, we will confirm the situation.

Will EU and UK notified bodies cooperate?

There are differences of opinion, but essentially yes, as far as is possible.

The Agreement allows the use of subcontracting by Notified Bodies, including organisations in the ‘other Party’s territory’. Again the practical meaning of this has yet to be defined.

In Government guidance it states that EU Notified Bodies are required to share information with UK Approved Bodies, when requested by a certificate holder. The UK approved body should do the same with EU Notified Bodies.

This will help facilitate the issue of new certificates of conformity were needed, without the need to repeat the entire certification process.

Will any Notified Bodies in Europe be able to be UK approved? Or do the UK Approved Bodies need to be based in the UK?

The UK Approved Bodies need to be based in the UK.

I have a Notified Body test report or thermal report from the BBA – what is the status?

If you are selling within the UK and wish to update your CE Marking to UKCA Marking, the BBA will be able to reissue your report under its UK Notified Body number. The BBA will be able to do this from January 1st 2021. If your product changes in the future, and you wish to continue selling on the UK Market, you will need to have the product reassessed by the BBA.

The report will not be accepted by the EU in support of CE marking and, unless further agreement is reached, retesting will be necessary.

Ask a Question

If your question isn’t answered below, get in touch and we’ll do our best to help with any query during these turbulent times.

Marking Type
Thank you for your message. It has been sent.
There was an error trying to send your message. Please try again later.

For up to date details, questions and answers around UKCA Marking, UKNI Marking,CE Marking and questions the BBA have been asked to answer, check out the dedicated webpage here: