In preparation for BREXIT at the end of this year, Steve Noakes, General Manager of Pyroban Ltd provides a clear message about what BREXIT means for Pyroban and our customers.
First, there is no need for confusion. Pyroban is a Great British (GB) manufacturer already doing business worldwide and is ready to supply to every customer in the EU from the 1st January 2021.
A set of baseline principles are established from The ‘Blue Guide’ on the implementation of EU products rules 2016 published by the EU Commission for selling product into the European Union after BREXIT*.
*This assumes GB will not have any special arrangements with the Union from 31/12/2020 and is what Pyroban is prepared to adhere to.
What does BREXIT mean in practice for Pyroban customers and ATEX?
In reality, the post BREXIT process is very similar to what we do today for materials handling equipment conversions and the supply of engine kits, packages, and components.
Just like we do today, we must:
- Create Technical Construction File (TCF)
- Verify each product unit is compliant to Union Harmonisation Legislation (Directive ESHRs)
- Label the product
- Apply CE marking
- Issue EU DoC
- Provide Instructions for use
We have already transferred certificates issued by ATEX NoBos (Notified Body) to one of their EU based facilities. Our accreditations to ATEX and IECEx are ready for post BREXIT requirements.
Processes for bringing customer fork trucks into Pyroban for Ex conversion are understood and being finalised including arrangements for import duties, tariffs, etc.
Our preparations for the UKCA marking requirement from 1st January 2022 are well underway for our GB based customers.
In summary, we are ready to support EU based customers with EU end users, whether our customer has GB facilities within their group or not. Likewise, for GB customers with GB end users.
Pyroban is proud of its active involvement in standards committees over the last 40 years and post BREXIT the UK will still retain active participation in EU standards work. Customers can be assured that Pyroban will remain a key member of the EN1755 standard committee specific to the Materials Handling industry and will maintain our presence on the EN1834-1:2000 committee which is has migrated to ISO 80079-41..
Like all manufacturers, we cannot control shipping delays that may occur in the first few weeks of BREXIT and have increased necessary materials stock levels just in case, to avoid production delays. We have also been managing customer expectations for those that are expecting deliveries during the initial few weeks.
The specific details of the EU Commission rules for Pyroban ATEX equipment
The principles from the ‘Blue Guide’ clarify that:
- Direct Sales to distributors, integrators, and end-users is possible from outside the Union (i.e. from Pyroban into Europe)
- The manufacturer (i.e. Pyroban) can commercially transact product covered solely by the ATEX or LVD (Low Voltage) Directives intended for use in the Union Market without establishing themselves in a Member State, or appointing an Authorised Representative, or involving an importer.
- The manufacturer outside the Union (i.e. Pyroban) may apply the CE marking and issue the EU DoC (declaration of conformity)
- Product covered by the Machinery Directive (this applies to Pyroban in some cases) intended for use in the Union Market where the manufacturer issues the EU DoC or EU DoI requires the manufacturer to either be established in a Member State, or appoint an Authorised Representative, or involve an importer, or appoint an authorised person established in a Member State (whose role is limited to compile the TCF if required by Union Market Surveillance). Pyroban has appointed an authorised person established in Pyroban Sarl for this purpose.
The majority of Pyroban sales fall within the category of CE marked components, equipment, assemblies manufactured in GB under ISO9001 self-declaration, or 3rd party certification with the Trade Name of manufacture (Pyroban) and commercially sold to distributors, integrators, OEMs, or end-users and shipped to them from the manufacturer’s facility (Pyroban in Shoreham-by-Sea, England).
Pyroban – a Great British global export
Pyroban exports products all over the world every single day and our processes are designed to adapt to the requirements, legislation, and standards of any country or union. BREXIT is no different.
For Pyroban engineers supporting our products globally, there will be small changes to travel processes, but we do not foresee any difficulties.
If you’d like more information on how BREXIT concerns your Pyroban order, contact our team on +44(0)1273 456800 and we can talk you through the correct route to market.