19 January 2022
It is now less than one year until the end of the standstill period whereby equipment carrying the EU Mark of Conformity (“wheel mark”) will no longer be accepted on UK ships. From 1st January 2023 new installations of equipment will need to carry the UK Mark of Conformity (“The Red Ensign”). Whilst some are hopeful of an EU/UK MRA, the Maritime and Coastguard Agency (MCA) advise that this is “an unlikely scenario, and to urge industry to undertake UK conformity procedures for their products in time ahead of the 1st January 2023 to avoid delays.” 1
The December 2021 publication of the MCA Merchant Shipping Notice – MSN 1874 (M+F) Amendment 5 provides guidance on obtaining approval in conformity with the Regulations to:
The requirements of MSN 1874 Amendment 5 follow the implementing regulation for the European Union MED ((EU)2021/1158), which means that there is currently no divergence of technical requirements. Manufacturers are required to perform conformity assessment in line with UK requirements; whilst there are a number of routes available most manufacturers will use Mod B (Type Approval) & Mod D (Production Quality Assurance).
Module B requires the manufacturer to make a submission, including test evidence, to the Notified Body. This evidence is assessed in conjunction with a Module D audit whereby the manufacturing facilities are assessed to ensure that they have suitable processes and procedures in place to ensure consistent production.
Whilst the MCA is planning industry engagement events and the issuing of further guidance around marine equipment to ensure that industry is clear on the requirements of UK conformity assessment1, manufacturers of equipment that falls under the scope of MSN 1874 (see Annex 5 for further details) are advised to start taking steps to ensure that they have UK Conformity ahead of the 1st Jan 2023 deadline.
Module B relies on the submission of documentation to the Appointed Body. However, Module D requires an on-site audit of manufacturing facilities which needs careful coordination.
Key message: Start looking at this now so as not to be disappointed later in the year.
TÜV SÜD BABT are an Appointed Body for UK Marine Marking for:
TÜV SÜD is well positioned to service both the United Kingdom and European Union markets. TÜV SÜD are:
We are offering a joint UK and EU Certification package; meaning that manufactures can save on duplication of effort when dealing with multiple Conformity Assessment Bodies. One of the main benefits to you is not having to arrange separate EU and UK Module D Audits.
Should you be interested in discussing how TÜV SÜD can support you please contact us.
Regulations 2016 SI 2016/1025 amended by 2019/470
United Kingdom Conformity Assessment Procedures for United Kingdom (equivalent to EU MED Implementing regulation)
1. MCA – Marine Equipment Survey Report - December 2021