About TCA
The Canada-United Kingdom Trade Continuity Agreement is a free trade agreement between Canada and the UK that was created following BREXIT and based on the Comprehensive Economic and Trade Agreement (CETA) between Canada and The European Union EU. Its purpose is to facilitate trade between Canada and the UK and support better access and opportunities for Canadian businesses to be more competitive in the UK market.
The agreement was signed in 2020 and entered into force in 2021.
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Canada-UK TCA preserves the main benefits of CETA and Canada’s competitive advantage in the UK market.
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Protocol on the mutual acceptance of the results of conformity assessment
The Canada-UK TCA includes the protocol on mutual acceptance of conformity assessment results (the protocol). SCC is implementing the protocol on behalf of the government of Canada.
About the protocol
The protocol specifies product categories that can be implemented which are identified in Annex I and Annex II of the Conformity Assessment Protocol. It allows for Canadian products to be certified for UK markets by Canadian conformity assessment bodies.
UK products destined for Canadian markets can now be certified by UK conformity assessment bodies that have been accredited by the United Kingdom Accreditation Services (UKAS) after a product category is mobilized and activated.
Product categories
The protocol specifies product categories which can be implemented. It allows for Canadian products to be certified for EU markets by Canadian conformity assessment bodies.
EU products destined for Canadian markets can now be certified by EU conformity assessment bodies.
Bilateral cooperation
The protocol is implemented through a bilateral cooperation agreement between SCC and the United Kingdom Accreditation Services working on behalf of the United Kingdom. The agreement defines the scope and method of cooperation between the two organizations and is renewable every three years.
Recognition of SCC in the United Kingdom
The Canada-UK TCA came into force in 2021 and SCC and UKAS are working together to implement the first product group category (ATEX – Equipment for potentially explosive atmospheres). Learn more about the joint SCC-UKAS communication on ATEX and expected completion.
Our role as a designating authority in Canada
The UK’s regulatory framework, which is currently largely based on the EU’s framework, requires that the conformity assessment bodies considered competent to certify products against UK regulations, which are based on EU directives and/or regulations, be approved to the United Kingdom for Great Britain only (GB). This means they must be recognized as approved bodies. Northern Ireland still requires conformity assessment work to be undertaken in accordance with EU requirements and requires notified bodies. Please refer to our Canada – European Union Comprehensive Economic and Trade Agreement (CETA) for more information on becoming a Notified Body for the European Union.
SCC has been appointed as the authority to approve bodies based on mobilized product categories listed in the protocol. One exception is electromagnetic compatibility and radio equipment as it is fulfilled by Innovation, Science and Economic Development Canada.
UKAS provides accreditation for appointment under United Kingdom Regulations and EC Directives
Accreditation and designation
Canadian conformity assessment bodies
SCC-accredited conformity assessment bodies can have their scopes of accreditation extended to certify products against UK requirements for Great Britain (GB) related to product categories included in the protocol.
If they have a legal presence in Canada, they are eligible for designation as approved bodies in the UK for Great Britain. Northern Ireland still requires Conformity Assessment Bodies to be Notified Bodies to the EU and provide conformity assessment services against EU regulations and requirements with the use of the CE mark. For more information on becoming a notified body for the EU, please refer to our Canada – EU Comprehensive Economic and Trade Agreement (CETA).
Contact your SCC account manager at TCAinfo@scc-ccn.ca if you are:
• An SCC-accredited conformity assessment body and interested in extending your scope of accreditation to include UK requirements (based on EU Directive(s) and Regulation(s))
• already accredited by SCC to UK requirements and would like to become an approved body
UKAS and certification bodies in Canada
When recognized in Canada, UKAS can accredit UK conformity assessment bodies as competent to certify products to Canadian technical regulations.
Canadian manufacturers
Do you wish to certify your products for the UK (Great Britain) market? Contact SCC at TCAinfo@scc-ccn.ca.
Canadian regulators
For UKAS to be recognized in Canada, they need to ensure that their accredited conformity assessment bodies establish relationships with Canadian authorities having jurisdiction and/or with the appropriate regulatory authority advisory bodies, in the same manner as SCC-accredited conformity assessment bodies in Canada. The protocol does not require any changes to Canadian and UK regulatory requirements. UK products will be certified by UK conformity assessment bodies for the Canadian market so that they meet all applicable federal, provincial, and territorial regulations.
Questions?
Contact SCC at TCAinfo@scc-ccn.ca