Brexit affects many industries since the regulations are changing. One the affected industries is automotive. Both UK and EU is updating the regulations related to type approvals of products. How Brexit affects the type approvals? In this post, we tried to summarize fundamental changes. For further details, please check the recent official announcements of the EU and UK.
We have listed four items summarizing the Brexit effects of type approvals in automotive industry:
1. UN-ECE type approvals are not affected, whether they have been issued in the UK or by another contracting party.
The UK is also a contracting party to the United Nations Economic Commission for Europe’s 1958 Agreement (UN-ECE) and will continue to recognise UN-ECE approvals for systems and components issued by other contracting parties where the UK is a signatory.
2. EU type approvals will not be valid for the UK market. EU type approvals issued in the UK will not be valid for the EU market.
From 1 January 2021, existing EU type approvals issued by EU-27 Type Approval Authorities will no longer be automatically accepted in GB for the purpose of registering vehicles for use on the road, other than for vehicles already in the UK on 31 December 2020. EU type approvals issued in the UK (e11 type approvals) will no longer be valid in the EU for the same purpose.
3. GB type approval will be started for the UK market.
The GB type approval scheme will be introduced in two stages:
* Issue of provisional GB type approvals from 1 January 2021 (end of the transition period)
* Conversion of provisional GB type approvals to comprehensive GB type approvals and issue of comprehensive GB type approvals for new products (expected in Spring 2021)
4. How is Northern Ireland affected by Brexit?
Northern Ireland will apply special regulations due to current status of it. After the end of the transition period, the Protocol on Ireland/Northern Ireland (“IE/NI Protocol”) applies. The IE/NI Protocol is subject to periodic consent of the Northern Ireland Legislative Assembly, the initial period of application extending to 4 years after the end of the transition period. Below cases are listed by European Commission of EU on 14 July 2020:
Motor vehicles placed on the market in Northern Ireland have to comply with EU type-approval legislation;
Motor vehicles manufactured in Northern Ireland and shipped to the EU are not imported products;
Motor vehicles shipped from Great Britain to Northern Ireland are imported products;
The importer and the manufacturer’s representative may be established in Northern Ireland;
Where provisions of Union law require a unique code indicating a Member State, it shall be indicated as “UK(NI)”; Type-approvals as well as revisions or extensions to such approvals granted by an EU approval authority are valid in Northern Ireland, i.e. motor vehicles can be placed on the market, registered and entered into service in Northern Ireland based on an EU type-approval.