Starting from January 1, 2021 the UK is not a part of the EU anymore. However, the leaving of the GB from the EU faced some issues. One of such issues was the border between Northern Ireland and the Republic of Ireland as the latter remains a member of the EU. Neither the government of the GB nor the government of the Republic of Ireland want to create a visible border between the Republic of Ireland and Northern Ireland.

That is why the UK and the EU have agreed on a new invisible "regulatory" border between Northern Ireland and Great Britain (England, Scotland and Wales) and signed the so-called Northern Ireland Protocol.

According to the Protocol, Northern Ireland follows the relevant EU rules on placing goods to the market that are proved by the presence of the EU conformity mark on such goods. So, EU conformity marks remain applicable in Northern Ireland to show that the product meets EU legislation. In most cases, we talk about CE marking.

However, if you use a UK notify body for third-party conformity assessment you need to put a special conformity mark starting from January 1, 2021.  This mark consists of four letters: UKNI (sometimes referred to as the UK(NI) mark or the UK(NI) indication). The UKNI mark must always be applied together with the CE mark.  

When you put the product to the EU market, you must use the CE marking on its own, without the UKNI marking. This means that goods that are intended for being sold on the EU market cannot be assessed against EU rules by a body based in the UK.

Thus, when the product is going to be put on the market of Northern Ireland, the applicable mark depends on the involved assessment body:

• If the product was assessed by using an EU notified body, the CE mark should be used on the product and it is enough to put the product on the NI market;
• If the product was assessed by using an UK notified body, the UK(NI) mark must be used together with the CE mark to put the product on the NI market.

The information has been prepared by the GMA Consult Group team. GMA Consult Group provides a full cycle of international type approval and global market access services for IT, Telecom, and industrial electrical products in all countries throughout the world. With proven expertise in worldwide regulations, compliance, certification, and conformity assessment, GMA Consult Group can help your company speed up the access to any market with almost zero efforts from your side.

Need your own guide to the world of certification and approvals? Don't hesitate to contact us via info@gma.trade.

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