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Brexit Update: Lucideon's EU Notified Body Status after 31 October 2019

This is an update on Lucideon's continuity programme in relation to our operation as a notified body under the Construction Products Regulations (EU) 305/2011 (CPR) in the event of a United Kingdom withdrawal from the EU on 31st October 2019, under a 'no-deal' Brexit.

Under the circumstances of a 'no-deal' Brexit, Lucideon has entered into an agreement with Technical and Test Institute for Construction Prague (TZUS), an established and respected Test House based in the Czech Republic that is also a notified body under the CPR. TZUS has the notified body number 1020 and is registered on the EU NANDO website as such.

As part of the agreement Lucideon will continue to work to the requirements of ISO 17025, the CPR and EA 2/17 and will continue to be audited by UKAS and will become a UK Approved Body (UKAC). In addition TZUS, as part of their due diligence, has performed audits at Lucideon to confirm that we are maintaining all standards of testing and performance. Lucideon is confident that by continuing to use our established labs and personnel, based in Stoke-on-Trent, we can continue to provide high quality testing in a convenient location while ensuring that clients will be issued with EU based certificates of conformity from TZUS.

When will the transfer take place?

In the event of a 'no-deal' Brexit our plan is that all testing as a notified body performed at Lucideon after the 31st October 2019 will be reported on test certificates issued by TZUS directly to you. The certificates will bear the TZUS notified body number so that they can be used to support applications for market approval for sale within the EU using a CE mark.

How will this work in practice?

You will enter into an agreement with TZUS who will subcontract the testing work to Lucideon. You can contact Lucideon directly and we can introduce you to TZUS in the first instance so that there will be no problems or delays. All samples will be delivered to Lucideon, as before, and the testing will be performed at Lucideon in Stoke-on-Trent. The test results, and all supporting documentation, will be passed to TZUS who will then issue certificates of conformity to you using their notified body number, 1020. You can then use these certificates of conformance to support the CE marking of your products. Please see the flow diagram on this page for more details.

Which notified body testing will this affect?

Lucideon will continue to provide testing to the following specifications:

Accreditation for the purpose of Notified Body taking into account EA2/17
Directive /Regulation Conformity Assessment Category of products Essential requirements
The Construction Products Regulation (EU) No 305/2011 Annex V – Testing Laboratory (AVCP) System 3 97/740/EC Masonry and related products (2/3): Tension straps (in walls and partitions). Joist hangers (in walls and partitions), Ties (in walls and partitions). EN 845-1:2013 + A1:2016
Annex V – Testing Laboratory (AVCP) System 3 97/740/EC Masonry and related products (2/3): Bed joint reinforcement (in walls and partitions) EN 845-3:2013 + A1:2016
Annex V – Testing Laboratory (AVCP) System 3 97/740/EC Masonry and related products (2/3): Lintels (in walls and partitions) EN 845-2:2013 + A1:2016
Annex V – Testing Laboratory (AVCP) System 3 98/436/EC Roof coverings, roof lights, roof windows and ancillary products (3/6): - Roofing tiles, slates, stones and shingles (for use subject to reaction to fire regulations) EN 1304:2005
Annex V – Testing Laboratory (AVCP) System 3 98/437/EC Internal and external wall and ceiling finishes (2/5):- Suspended ceilings (kits) (as internal or external finish in ceilings subject to safety in use requirements) EN 13964:2014
Annex V – Testing Laboratory (AVCP) System 3 99/470/EC Construction adhesives (1/2):- Adhesives for tiles (for internal and external uses in buildings and other civil engineering works). EN 12004:2007 + A1:2012

The following testing will not be immediately available but may be returned once TZUS has added them to its Schedule of Accredited testing on the EU NANDO website.

Accreditation for the purpose of Notified Body taking into account EA2/17
Directive / Regulation Conformity Assessment Category of Products Essential Requirements
The Construction Products Regulation (EU) No 305/2011 Annex V – testing laboratory (AVCP) System 3 98/436/EC Roof coverings, roof lights, roof windows and ancillary products (2/6): Roofing tiles, slates, stones and shingles (for use subject to reaction to fire regulations) EN 2304: 2005
Annex V – testing laboratory (AVCP) System 3 97/808/EC Flooring (2/2) Rigid flooring products. Components: paving units, tiles, mosaics, parquet, decking of mesh or sheet, floor gratings, rigid laminated floorings, wood based products (for internal uses including enclosed public transport premises). EN 14411: 2012
 

Process Flow Diagram

Process Flow Diagram

Existing notified body reports issued by Lucideon

Following a 'no-deal' Brexit the EU has ruled that test reports issued by UK based notified bodies in the past will no longer be valid and cannot be used to support CE marking of products to be placed on the market within the EU. This means that test reports issued in the past by Lucideon will not support the CE marking of those products already on the market in the EU after October 31st 2019.

Lucideon has been unable to negotiate a deal with existing EU based notified body labs for the reissue of the existing test reports with the notified body number of a testing laboratory based in the EU.  It would not be economically viable for Lucideon to establish a testing laboratory within the EU to cover the notified body testing. The only alternative is for those clients using Lucideon test reports to support the CE marking of existing products to have them retested by an EU based testing laboratory with notified body status for the testing required.

Existing clients, who decide to retest their products, should contact Lucideon and we will facilitate the testing of the products at Lucideon in Stoke-on-Trent along with the issue of a test report from TZUS, with a valid notified body number (1020) by the route described above. The new certificates will be valid to support CE marking of the products and allow access to the EU market.

UKCA Marking

Following Brexit the UK Government, via the Department for Business, Energy and Industrial Strategy (BEIS), plans to introduce the UKCA mark to replace the CE mark within the UK.  The UKCA mark will be necessary to place products covered by the Construction Products Regulation on to the UK market.

Lucideon will automatically become an UK Approved Body for the testing of products against the Construction Products Regulations. UKAS will remain the UK national accreditation body and will continue to assess that Lucideon conforms to all the requirements necessary to allow us to operate as UK Approved Body.

Test reports issued in the past by Lucideon as a notified body will continue to be valid to support UKCA marking of products. The UKCA mark can be used immediately after Brexit.

The EU will not recognise the UKCA mark and to place products on the EU market will require a CE mark.  The UK will continue to recognise the CE mark for a limited time, thought to be approximately two years.

The BEIS is running seminars and webinars between 9th October 2019 and 15th October 2019 for existing notified bodies to clarify specific details of how UKCA marking will work.  We will keep you updated on developments.

UK Government Advice

To remain up to date with the latest UK Government guidance look at the following websites:

If you have any queries, please contact:

Stephen Morrey +44 (0)1782 764214  stephen.morrey@lucideon.com
or Zoe Kinally +44 (0)1782 764278  zoe.kinally@lucideon.com

17 October, 2019

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