In general, we view an exit from the EU as unlikely to have a significant short-term impact on how LR provides services to clients. However, given the extent of the uncertainty about how the process will unfold, we will continue to follow events and keep our clients updated on our view and plans.
LR’s Brexit Committee, formed soon after the EU referendum last year, continues to closely monitor the UK’s exit negotiations and focus on the plans and actions we have put in place to ensure any impacts on our clients are minimized and managed.
We want to reassure our clients that, whatever the outcome of the Brexit negotiations, LR is a robust and resilient business that benefits from a global footprint, and is, therefore, in a good position to deal with the results and emerge strongly.
Possible impact on LR’s status
It is important to note that, until the UK government formally exits the EU (some two years from the date that Article 50 was triggered) our business will carry on as normal.
After this period, we have examined the possible impact of the UK’s exit from the EU on LR’s status in three areas:
1) As an EU Notified Body; this is particularly relevant to LR’s assurance and inspection work performed under various EU Directives and Regulations and to our services to the marine and offshore sector performed under the Marine Equipment Directive (see table below);
2) As an accredited certification organization; this is particularly relevant to management systems assurance and inspection work performed under UKAS accreditation; and
3) As a Recognized Organization; this is particularly relevant to the marine and offshore services we deliver.
Our businesses currently have plans in place and are taking action to mitigate the risks and deal with all possible outcomes in these areas.
LR views continuity of service to its clients as imperative. Although it is not clear whether the UK will continue to operate its own EU notified bodies post-Brexit, LR is taking contingency actions to obtain accreditation through other major EU27 countries. We are confident these steps will prevent disruption to our services.
LR already holds Notified Body status in several major EU27 countries. We are actively expanding these approvals to replicate the appointments LR holds in the UK. We have submitted several applications and the first of these additional Notified Body appointments (for the Lift Directive) was granted by France in November 2017.
We envision making the majority of our additional applications in the Netherlands. This includes submissions already made in respect of the Medical Devices Directive, the In Vitro Diagnostic Devices Directive and the Noise Emission by Outdoor Equipment Directive.
Management systems assessment and certification
Although much of our global activity in this field is carried out via accreditations held in the UK with the United Kingdom Accreditation Service (UKAS), we do not expect the validity or recognition of those accreditations to be affected by the outcome of Brexit. However, LR will continue to monitor this situation closely.
Marine and offshore sector
In the marine sector, as LR is an EU Recognized Organization we are required to be sponsored, (for the purposes of ensuring compliance with Regulation (EC) No 391/2009, Article 8, paragraph 1) by an EU Flag. With effect from 1 May 2017 LR’s sponsorship has moved from the UK to the Danish Maritime Authority, assuring our ability to continue to act as an EU Recognized Organization post Brexit.
Our global accreditation by the United Kingdom Accreditation Service (UKAS) allows us to deliver services for the assessment of monitoring plans and verification of emissions reports for maritime transport subject to Regulation (EU) 2015/757, monitoring, reporting and verification of carbon dioxide (CO2) emissions from shipping activities, also known as MRV Regulation. At this stage we do not expect this area to be impacted by the UK’s exit from the EU, but we continue to monitor this situation closely.
LR’s preferred outcomes
While the shape and nature of the exit continues to evolve, we will contribute to the voice of UK business to represent LR’s desired outcome. In general, LR is supportive of positions taken by the Confederation of British Industry (CBI), the UK employers’ group, which has identified five broad outcomes that UK Business requires from Britain’s negotiations with the EU.
- Tariff and barrier-free access to the single market
- Access to skills and people
- Regulatory equivalence
- Strategy for agreeing trade deals with other parts of the world
- Protection for benefits derived from EU-funded projects
LR continues to monitor developments closely and will update clients as and when the need arises. Regardless of the negotiation outcome, we are confident that LR will continue to provide global services to our clients in the same manner and to the same high standard as we have done throughout our long history.
If you would like to discuss a particular aspect of our service or our position, please get in touch with your client manager or Tom Boardley, Executive VP and Global Head of Corporate and External Affairs (firstname.lastname@example.org).
LR’s Notified Body appointments in the UK, with respect to the following EC/EU Directives:
|Pressure Equipment Directive (PED)
|Transportable Pressure Equipment Directive (TPED)
|Simple Pressure Vessel Directive (SPVD)
|Equipment and protective systems intended for use in potentially explosive atmospheres (ATEX)
|Noise Emission in the environment by equipment for use outdoor (NED)
|Construction Products Regulation (CPR) - Construction Products Directive
||Reg (EU) 305/2011
|Marine Equipment Directive (MED)
|Common Safety Method (CSM)
||EU Reg. 2004/49/EC
|Rail Interoperability Directive
|Machinery Directive (MD)
|Medical Devices Directive
|In Vitro Diagnostic Medical Devices Directive
|Personal Protective Equipment Directive
|Lifts and Safety Components For Lifts Directive