If the UK leaves the EU in March 2019 without a deal, find out how this would affect your business using a ‘nominated person’ to carry out certain tasks on your behalf.
If the UK leaves the EU without a deal on 29 March 2019, the requirements for placing certain products on the UK and EU markets, including the arrangements for nominated persons, will change.
This notice explains the future arrangements for nominated persons (‘authorised representatives’ and ‘responsible persons’) in relation to manufactured goods in a ‘no deal’ scenario.
This notice does not cover the of Qualified Persons and Qualified Persons Responsible for Pharmacovigilance (QPs and QPPVs) for pharmaceuticals, the role of the Only Representative for chemicals, or Authorised Representatives for medical devices.
Actions for businesses and other stakeholders
Manufacturers placing products on the UK market on or after 29 March 2019 should note:
- Existing authorised representatives based in an EU country will continue to be recognised in the UK for a time-limited period.
- Businesses wishing post exit to appoint a new authorised representative to carry out tasks on their behalf in the UK will need to appoint a representative located in the UK.
- For cosmetics, responsible persons based in an EU country will no longer be recognised by the UK after March 2019
- Businesses placing cosmetic products on the UK market will need a responsible person located in the UK.
Manufacturers placing products on or after 29 March 2019 the EU market should note:
- UK-based nominated or responsible person will no longer be recognised under EU law. This means they will not be recognised as able to carry out tasks on the manufacturer’s behalf.
- Businesses with an authorised representative based in the UK will need to establish a new authorised representative in an EU country if they want an authorised representative to carry out tasks on their behalf within the EU.
- Businesses placing cosmetic products on the EU market will need a responsible person located in an EU country.