Brexit Overview

The United Kingdom has left the EU and is now a ‘third country’. For products sourced in Great Britain (England, Scotland and Wales) UK (GB) and placed on the Irish market, EU legislation applies. This means that Irish companies may have new or additional obligations arising from Brexit. The Health and Safety Authority is a Competent Authority for a range of EU Regulations and Directives which govern the import, use and placing on the market of a range of products from chemicals to machinery to pressure equipment and lifts. We also provide the Irish National Accreditation Board (INAB) which is responsible for accreditation of conformity assessment bodies required under specific EU laws.

Chemicals

One key area impacted is that of chemicals and chemical products. Irish companies sourcing chemicals from UK (GB) are now EU importers. As a result, they may have to take on the responsibility for the registration, authorisation, notification and other essential safety information requirements for these chemical products. Such obligations arise from a number of specific EU Regulations; the REACH Regulation (Registration, Evaluation and Authorisation of Chemicals), the CLP Regulation (Classification, Labelling and Packaging of Chemicals), the Detergent Regulations and the Rotterdam Regulation. Further information is available in other section of these webpages covering REACH, CLP, Detergents and Export/Import Regulations.

Machinery

Irish companies importing machinery from UK (GB) are impacted as they are making it available on the EU market for the first time. They are responsible for ensuring the appropriate conformity assessment is carried out by the manufacturer in compliance with the safety requirements in the Machinery Directive (2006/42/EC). Further information is available on these webpages at: https://www.hsa.ie/eng/topics/brexit/market_surveillance_%E2%80%93_industrial_products/

Transportable Pressure Equipment (TPE)

Irish companies who, up until now, have used UK (GB) notified bodies to carry out inspections of TPE now need to use alternative bodies from within the EU. In addition, Irish companies who distribute TPE sourced in UK (GB) are now importers and thus their obligations under the TPE Directive (2010/35/EU) have changed. Further information is available on these webpages at https://www.hsa.ie/eng/topics/brexit/transportable_pressure_equipment/

Notified Bodies

Irish companies who, up until now, have used UK (GB) notified bodies to carry out conformity assessments and inspections now need to use a notified body from within the EU, as UK (GB) notified bodies are no longer recognised. The Irish National Accreditation Board (INAB) provides accreditation to applicant conformity assessment bodies (CABs) which test, certify and inspect products/ services. Apart from meeting the requirements of accreditation and notifying authorities, CABs must demonstrate they are permanently established in Ireland. Further information is available on these webpages at https://www.hsa.ie/eng/Topics/Brexit/Accreditation/