News about Brexit: 

Announcement from UK government


The government will continue to recognise the CE marking for 2 years, therefore allowing businesses until 31 December 2024 to prepare for the UKCA marking. Businesses can also use the UKCA marking, giving them flexibility to choose which marking to apply.

Our recommendation:

TÜV Thüringen recommends that manufacturers progress with UKCA certification before the end of 2024. 

Latest news about Brexit: Easements for UKCA marking


The U.K. Government has announced new rules to facilitate the transfer to UKCA marking from 1 January 2023. The published easements allow conformity assessment activities completed under the EU regulations (CE Marking) to continue to be accepted to support the UKCA marking of an item until the certificate underpinning the EU regulation certification expires, or 31 December 2027, whichever comes sooner.


  • … from the 1st January 2023, the UKCA mark must be used for placing goods on the market in Great Britain.
  • However, the procedures for marking UKCA are modified.

Exemplary facilitations in the area of pressure equipment are listed here:

  • Permanent Joining Procedures:
    Permanent joining procedures acc. to european pressure equipment directive, certified before 1st January 2023, will be accepted for use on UKCA marked items until 31st December 2027.
  • Permanent Joining Personnel:
    Approvals of permanent joining personnel acc. to european pressure equipment directive , certificate before 1st January 2023, will be accepted for use on UKCA marked items until the certification expires (for those certificates with an expiry route option), or until 31st December 2027 (for those with the prolongation route – prolongation must be up to date).
  • NDE Personnel:
    Approvals of NDE personnel acc. to european pressure equipment directive, certified before 1st January 2023, will be accepted for use on UKCA marked items until the certificate expires (where it will then require a UK approval of the new one).
  • MModule B type examination certificates:
    Certificates acc. to european pressure equipment directive issued before 1st January 2023, can be used to support the module B aspect of UKCA marked items conformity assessment until their expiry date, or the 31st December 2027, whichever is sooner.  
  • Module D/D1/E/H/H1 Certificates:
    ZModule D/D1/E/E1/H/H1 certificates acc. to european pressure equipment directive , issued before 1st January 2023, can be used to support the conformity assessment of UKCA marked items until their expiry date.
  • Material Manufacturers QS Certificates:
    Certificates acc. to european pressure equipment directive, issued before 1st January 2023 can be used to support material manufacturers quality system certification for materials for UKCA marked equipment until their expiry date.

Certificates acc. to european pressure equipment directive for any of the above to be issued on or after the 1st January 2023 are not subject to this agreement, and must be certified by an appropriate UK Body in order to be used for UKCA marked equipment.

 That means:

  • Completed CE-marked pressure equipment components, imported under contract into the GB market by 31.12.2022, do not need to be re-tested/re-certified or UCKA marked. However, the products should still be checked to ensure they meet the requirements of EU law before they are further supplied and a record should be kept of documentation which demonstrates the product was imported into GB under contract before the 31 December 2022.
  • Pressure Equipment manufacturers can continue from 1 January 2023 to purchase ‘CE’ marked spare parts for ‘CE’ marked equipment placed on the GB market before 11pm on 31 December 2022. However, if the product or system has been subjected to important changes, overhauling its original performance, purpose, or type, it would be considered ‘new’ and must comply with GB regulatory requirements, including being UKCA marked from 11pm on 31 December 2022.
  • Pressure equipment or assemblies do not need to have the UKCA mark physically affixed when being placed on the GB market until after 11p.m. on 31.12.2025. Until then the UKCA marking can be in an accompanying document or label. Similarly, importer information does not need to be affixed on pressure equipment or assemblies imported from the EEA until after 11 p.m. on 31.12.2025, and can instead be on the packaging or in an accompanying document until that date. From 01.01.26 this information needs to be on the good unless the specific product regulation permits otherwise (e.g., due to the size or nature of the good).
  • However, these rules need to be officially approved by the UK government. As of today, this has not yet been done.

Brexit and no end: What entrepreneurs have to pay attention to since January 1, 2022

Not only is Britain’s exit from the European Union (Brexit) fraught with many uncertainties at political level, many entrepreneurs in Thuringia have also waited for clear answers about numerous questions concerning conformity assessments and certifications for years:
  • Can companies based in the EU continue to export their products with CE marking into the economic area of the United Kingdom after January 1, 2022?
  • Will conformity assessments and certificates issued by notified bodies in Britain keep their validity in the EU after January 1, 2022 or is their re-certification required?
  • Will CE conformity assessments issued by notified bodies of the EU still be accepted for the export to Britain after January 1, 2022?
  • Under what conditions can products from Britain continue to be marketed in the EU?
  • What meaning does the new UKCA sign have and what is it required for – or also, what is it not required for?
  • What does the legislator understand under “old approach and new approach products” and how do I see, in which category my products fall?
  • What special regulations apply to the export to Northern Ireland?
  • What special regulations apply to the import of products from Northern Ireland?
You will receive competent answers to all these questions concerning conformity assessments in connection with the Brexit from the experts of TÜV Thüringen e.V. Central contacts for product certifications are Mr. Harald Prokopp and, for further conformity assessment and certification subjects, Mr. Raoul Michel.


Department of Industrial Service

Manager of Specialty Department:
Harald Prokopp

+49 3641 3997-29
+49 3641 3997-60

Mail to Harald Prokopp


Certification Body of TÜV Thüringen for Management Systems and Personnel

Manager: Raoul Michel

+49 3641 3997-41
+49 3641 3997-71

Mail to Raoul Michel

Guideline about the Brexit and the activities of the notified body for pressure equipment of TÜV Thüringen e.V.

1. Do consequences exist for the conformity assessment of products after the Brexit?

Unfortunately, yes. The hitherto so successful model of the free movement of goods within Europe does no longer exist for Great Britain after the country’s exit from the EU.

2. Are manufacturers of machinery and apparatuses now faced with entirely new requirements when exporting goods to Britain?

Luckily not yet. Each European member state was forced to transpose the European directives into national law. This has been done in Britain with the „Pressure Equipment Safety Regulations“ (PESR), to name just one example. The PESR is an almost 1:1 equivalent of the European Pressure Equipment Directive (PED).
3. The CE sign will therefore continue to be recognized in Britain?

Unfortunately, only up to the end of 2022. The date of marketing becomes relevant in this case. Even if the material requirements are similar, they are no longer identical. Britain has now the status of a third country and has set up its own procedures for this purpose. Hence, instead of the CE marking a UKCA marking will be required from January 1, 2023.

4. Can then European notified bodies continue carrying out conformity assessments for specific products?

No. Only bodies recognized by UKAS, the British accreditation authority, will be allowed to do it. Most of the European notified bodies are not recognized in this respect. On the other way round, former British notified bodies are no longer allowed to carry out CE conformity assessments, either.

5. Can TÜV Thüringen e.V. offer its clients a solution?

Yes, absolutely. TÜV Thüringen e.V. cooperates with its partner organization HPi-CEproof in the field of the PESR (i.e. the British Pressure Equipment Regulation). Further fields of cooperation are in the pipeline and will be added depending on the market needs. With TÜV Thüringen e.V. you thus have a reliable partner on your side that can cover almost the entire international requirements concerning test and certification services for pressure equipment.

6. How will customer inquiries concerning UKCA certification orders be dealt with and processed?

Everything will be done through the offices of TÜV Thüringen e.V and your local contact you know. We have adapted our internal processes accordingly and will provide flanking support during the application procedure.

7. How will existing material certificates be treated which have been issued according to the PED?

They will be accepted until the end of 2022. From January 1, 2023 onwards, the QS system of the material manufacturer must be certified according to the British PESR or a 3.2 certification will be issued for the material, if no PESR QS system assessment is available.

8. How will individual expert opinions on materials (PMA) be treated in the future?

As before, draft PMA are to be checked by the notified body, in this case by HPi. This will be done with every draft and specifically for the application concerned. We do not expect any additional difficulties in this respect.

9. How will existing welder examinations (welder qualification tests) be treated that have been passed according to PED?

All products must conform to the PESR from January 1, 2023 onwards, which concerns the joining processes with the personal qualifications as well. The certification of welding and joining personnel pursuant to Directive 2014/68/EU, Annex I, No. 3.1.2, will be sufficient for products that have been manufactured by December 31, 2022 and the production of which can be traced by a documentation. Welders must then be certified pursuant to the PESR for all products manufactured thereafter, although the normative basis, usually ISO 9606, is the same. It is, however, important that welders need to apply for the certification pursuant to the PESR from this point in time onwards, i.e. apart from the scope of validity of the Pressure Equipment Directive. The certification will then be carried out parallel in accordance with the PESR .

10. How will existing procedure tests and qualifications be treated?

The same requirements as described in section 8 above will apply to the certification of joining processes.

11. How will reports about non-destructive tests (zfP) and the relevant personnel qualifications pursuant to the PED be treated?

They must conform to the PESR from January 1, 2023 onwards. TÜV Thüringen e.V. can establish the relevant contacts with the accredited bodies in the UK. The procedure will be carried out in the same way as described in section 8 hereof.

12. How will existing type approvals pursuant to the PED be re-assessed pursuant to the PESR?

The type approvals will be „re-assessed“ at the manufacturer’s request and have to be adapted to the PESR in this respect. The type approval must be applied for pursuant to the PESR. Do not hesitate to get in touch with TÜV Thüringen e.V., we shall be pleased to support you in this process.

13. Will certain particularities have to be observed as regards Q modules?

Here again, the same requirements will apply as already described in section 8 above. It is possible to get a double certification with CE and UKCA. The certification will thus be carried out on the basis of the same assessment/audition.

14. Which set of design rules can be applied in accordance with the PESR?

The same requirements of the set of rules under the PED apply to the set of rules under the PESR. All set of rules are basically applicable, as long as they conform to the fundamental safety requirements of the PESR. Sets of rules harmonized with the PED (e.g. EN standards) as well as sets of rules adapted to the PED, e.g. AD 2000, can therefore be applied without any problems. TÜV Thüringen e.V. has far-reaching experience with the application of the ASME BPV code under the PED which applies, of course, to the scope of the PESR as well.

15. Will therefore the harmonized standards for materials (EN 10028 etc.) and products, such as EN 13445, continue to be valid in Britain?

Yes, Britain contributed intensively to the work in the European standardization bodies in the past, so that these harmonized standards and sets of rules largely constitute nowadays the state of the art in the United Kingdom.