UK - marine equipment certification (MER)

As a result of the UK leaving the European Union (EU), the United Kingdom Maritime & Coastguard Agency (MCA) has implemented the UK Conformity Assessment Scheme for certification of marine equipment.

Background:

  • Before the UK withdrew from the EU, its regulatory regime relied on the implementation of the EU’s marine equipment directive (2014/90/EU).
  • The UK left the EU on 31 January 2020 with an agreement which included a transition period. During this transition period, the Marine Equipment Directive (MED) and other EU legislation have continued to apply to the UK. However, the MED will no longer apply after the transition period has ended.
  • The MCA has implemented its own regulations to establish UK conformity assessment procedures for certification of marine equipment.

UK Maritime and Coastguard Agency (MCA) has fully appointed DNV UK Ltd. (0097) as a UK Approved Body for the approval of marine equipment according to the Merchant Shipping (Marine Equipment) Regulations (MER) 2016 as amended.

As result the DNV can provide UK marine equipment conformity assessment procedures for all modules covering the full scope of product categories:

  • Lifesaving Appliances 
  • Marine Pollution Prevention Equipment 
  • Fire Protection Equipment 
  • Navigation Equipment 
  • Radiocommunications Equipment 
  • Navigation Lights 
  • Self-contained compressed-air operated breathing apparatus for entry and work in gas-filled space 
  • Water level detectors

Equipment manufactured after 31 December 2022 that shall be placed onboard ships with UK flag need to bear the Red Ensign Mark indicating compliance with the MER. This compliance includes approval of the equipment in question by an UK Approved Body.

DNV is aware about the MER certification requirement are mandatory since 1 January 2023. 

Any applications of:

  1. equipment already MED certified by DNV
  2. equipment MED certified by other EU notified body
  3. equipment currently neither certified by DNV nor any other UK or EU approved body are welcome.

For products mentioned in (1.) DNV may provide a streamlined certification process. For products in (2.) and (3.) the default certification process needs to be applied. Our experts and support staff in central units and the field organization are doing their utmost to satisfy the needs of the industry. 

References to UK regulations:

  • Merchant Shipping (Marine Equipment) Regulations 2016 SI 2016/1025
    This regulation implements Directive 2014/90/EU on marine equipment, which provides for the uniform application of international standards for equipment placed on ships registered in the European Union and the enforcement of those standards. This is achieved in the UK by requiring equipment placed on board UK ships to comply with international design, construction and performance standards.
  • As amended by the Merchant Shipping Regulations 2019 SI 2019/470
    The purpose of these regulations is to ensure the UK can continue to comply with its international obligations by applying international standards to marine equipment placed on UK ships and enforcing those standards.
  • Merchant Shipping (Marine Equipment) (Amendment) (UK and US Mutual Recognition Agreement) (EU Exit) Regulations 2019 SI 2019/1304
    The agreement between the UK, encompassing Great Britain and Northern Ireland, and the USA on the Mutual Recognition of Certificates of Conformity for Marine Equipment.
  • MIN 590 Amendment 5 (M+F) – UK conformity assessment procedures for marine equipment
    This notice updates key information regarding the UK’s marine equipment conformity assessment regime, including in relation to the end of the ‘standstill’ period on 31 December 2022, after which date EU approved marine equipment will no longer be able to be placed on board UK vessels (with the exception of ‘spares’, and equipment manufactured before 1 January 2023). This notice provides important updates and outlines key exceptions to that. It also provides additional guidance to industry in preparation for that 1 January 2023 date.
  • Merchant Shipping Notice MSN 1874 (M+F) Amendment 8
    This notice gives technical information and guidance on the procedures for obtaining type approval in conformity with the regulations. It also gives information regarding the UK’s policy for enforcing these requirements, and other standards to be applied to equipment on board UK ships.

Annex I set out in full the design, construction and performance requirements and testing standards for marine equipment to which approval by an approved body is required in accordance with regulation 5.

FAQs:

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The UK has implemented its own conformity assessment procedure for marine equipment with a separate set of certificates. Therefore, manufacturers will receive, after successful UK marine equipment certification, separate certificates.
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Until there are no differences to the valid MED implementing regulation, the test reporting/ documentation from existing MED certification can be used to fulfil the UK conformity assessment requirements too. The relevant test requirements for UK marine equipment are described in MSN 1874 Amendment 8, Annex 1. 
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DNV plans not to change the established marine equipment certification process in general, which is well known by DNV customers. The certification depends on the product, possible re-use of the MED assessment and the UK conformity assessment. 
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All products within the scope of the UK marine equipment certification are described in MSN 1874 Amendment 8, Annex 1. DNV can cover the full scope of UK conformity assessments products. 
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DNV will provide an offer for the UK marine equipment service to interested customers in good time. Please contact your local DNV office.
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No, the deadline has not been changed and was 1 January 2023.
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Yes, but please consider:

Article 19 of the Mutual Recognition Agreement between UK and US stipulates that: ‘1. This Agreement applies, on the one hand, to conformity assessment procedures performed on products in the territory of the United Kingdom, and, on the other hand, to conformity assessment procedures performed on products in the territory of the United States.’

Therefore, when conducting any aspect of the conformity assessment procedure on equipment that is to be US Coastguard (“USCG”) marked (including testing) under the MRA, please ensure that this is done within the territory of the United Kingdom.
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For marine equipment, the UK flag will have to be fixed instead of or added to the wheel mark. Information regarding Mark of conformity can be found in MSN 1874 (M+F) Amendment 8, Annex 5.

The zip-file containing the high-resolution logos for the ‘UK Mark of Conformity – the Red Ensign’ in different file formats. It can only be used on marine equipment that complies with the Merchant Shipping (Marine Equipment) Regulations 2016 as amended. 
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No, there is no Mutual Recognition Agreement between the UK and the EU.
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No, the affixing of the UK mark is only allowed after a successful conformity assessment by a UK conformity assessment body. Manufacturers will receive, after positive UK marine equipment certification, separate certificates as evidence.
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According to point 2.5 in MSN 1874 Amendment 8: Equipment that is defined as a ‘spare’ part can continue to be placed on board a United Kingdom ship, this includes after 1 January 2023. A ‘spare’ is defined as: ‘Spares are replacements of Wheel marked or Red Ensign marked products which ensure continued functionality (i.e., via maintenance or repair) of a wider product or system on board a United Kingdom ship.’
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According to point 2.6 in MSN 1874 Amendment 8:” EU-approved marine equipment that has been manufactured before 1 January 2023 can continue to be placed on board United Kingdom ships as if it was a United Kingdom approved piece of marine equipment, subject to the timeframes around placing on board outlined elsewhere in this notice. If such equipment has been manufactured after 1 January 2023, then it must be UK approved.”

Last placing on board dates are provided in MSN 1874 Amendment 8, Annex 1, Column 6.

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