Page 21 - Industrial Technology magazine February 2021 issue

MACHINE BUILDING

UK machine builders exporting to Europe
As well as the EU 27 member states, the new trade deal
effectively includes Iceland, Liechtenstein and Norway
(members of the European Free Trade Association, EFTA),
plus Switzerland, which has a Mutual Recognition
Agreement (MRA) with the EU. In addition, Turkey,
Andorra and San Marino have Customs Union Agreements
with the EU. Northern Ireland can also be treated the
same way by GB machine builders, thanks to the protocol
mentioned earlier.
CE marking of machines destined for these markets
continues almost exactly as before. The vital difference is
that it is no longer acceptable to name a person in the UK
as being authorised to compile the technical file. This is
because the UK is no longer in the EU. The person named
on the DoC or DoI must be established in the EEA
(European Economic Area) and can be a person or a
business.
GB machine builders may have a subsidiary,
distributor or representative willing to undertake this role
but, if these options are not available, then a simple, quick
and cost-effective option is the service provided by Hold
Tech Files, based in the Republic of Ireland. Hold Tech
Files has created a web-based service for manufacturers of
machines, partly completed machines and safety
components covered by the Machinery Directive. After
signing a mandate and paying a fee (all fees are published
on the website and there are no ‘hidden extras’), the
relevant file can be uploaded to a secure server. Payment
of a one-off fee entitles the manufacturer to name Hold
Tech Files on the DoC or DoI for a period of ten years.
Where Annex IV machinery has previously been
conformity assessed by a Notified Body based in the UK, in machines, partly-completed machines and machine on 16 July 2021. The aim is to strengthen the
the EU is no longer recognising these EC type-examination safety components being held up at customs and failing to requirements for market surveillance by Member States
certificates. In most cases UK Notified Bodies have reach customers on time. but there are important implications for machine builders.
already transferred accreditations to other EU-based The new regulation introduces requirements relating to an
Notified Bodies. Machine builders should satisfy Rules of origin ‘economic operator’ and machines cannot be placed on
themselves that this has been done or, if not, obtain Aside from the technical aspects of CE marking, UK-based the market unless there is an economic operator
certification from an EU Notified Body as a matter of machine builders exporting to the EU now need to established in the EU.
urgency. consider the complex rules of origin. This relates to In addition to acting as the person authorised to
The points outlined above are very important for UK customs declarations and is outside the scope of this compile Technical Files for machine builders, Hold Tech
machine builders exporting to the EU. Because there are present article. Nevertheless, it would be remiss not to Files can also act as the Authorised Representative to
no ‘CE police’, some machine builders have previously draw machine builders’ attention to the need for them to enable UK machine builders to comply with the need for
taken the view that a minor non-compliance with the CE address this issue as well. an EU-based economic operator from 16 July 2021
marking process would be unlikely to cause a problem. European Regulation 2019/1020 on market onwards.
Now, however, incorrect documentation could easily result surveillance and compliance of products comes into force MORE INFORMATION: www.holdtechfiles.eu

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