New guidance has been published for UK Conformity Assessment Bodies (CABs) who are intending to subcontract tasks such as testing, certification or inspection. This process will limit the the need to test new products in the UK and Europe separately for the purpose of conformity marking (UKCA and CE Marking).
Overview of Guidance
Subcontracting is the act of contracting another body to do a task, which you have been appointed to perform, as part of the conformity assessment process. This is also commonly referred to as ‘outsourcing’. UK CABs can subcontract most tasks within the UKCA conformity assessment process, such as testing, certification or inspections. However, the decision on conformity itself must be made by a UK CAB.
If a CAB has an overseas subsidiary, the subsidiary to carry out the conformity assessment activities subject to the same conditions as using sub-contractors.
Subcontracting does not include when individuals are contracted-in as employees of a UK CAB (regardless of where they are employed). These individuals fall under the quality management system of that body.
There may be different conditions for products approved under the terms of a mutual recognition agreement (MRA) with the UK. The requirements for CABs are detailed within these agreements.
Note EU does not afford a reciprocal privilege to Notified Bodies for CE marking and this process will not impact legacy testing, where the lack of mutual recognition in the Exit Agreement prevents recognition of historic testing or Engineering Assessment Documents for some CE Market products (those covered by ACVP 3).