Are obligations for legacy stock assessed using its actual date of supply rather than a general Brexit statement?

Are obligations for legacy stock assessed using its actual date of supply rather than a general Brexit statement?

For electrical equipment, regulation 62A(2) of the Electrical Equipment (Safety) Regulations 2016, SI 2016/1101, provides, subject to paragraph (3), that “where a product was made available on the market during the pre-exit period”, an obligation under those Regulations as they had effect immediately before IP completion day “continues to have effect as it did immediately before IP completion day, in relation to that product.”

The company does not say how that provision applies to any stock. The company sets out its position under two bodies of law only, and neither of them is the law there.

Under United States law, NF Technical Products Inc. classifies the NanoFlashing™ Air Filter as a device under Section 2(h) of the Federal Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. § 136(h), and 40 C.F.R. § 152.500(a). Under Regulation (EU) No 528/2012, C-POLAR Technologies, Inc. classifies the same filter as neither a biocidal product nor a treated article. Each statement records that it addresses that one question only. No authority has approved, registered, endorsed or cleared the filter; the company classifies its own article.

What an authority requires of a product placed on its market is decided under its own rules, by the party that places it there. Every commercial NanoFlashing™ product is made by a manufacturing partner, in their facility, in their format.

Source: Statement of Classification for the NanoFlashing™ Air Filter, sections 1.3 and 3.7, issued by NF Technical Products Inc.; Statement of Regulatory Status for the NanoFlashing™ Air Filter, sections 1.3 and 3.7, C-POLAR Technologies, Inc., 11 September 2026; C-POLAR — Terms of Use, section 6, https://cpolar.tech/terms/; Electrical Equipment (Safety) Regulations 2016, SI 2016/1101, regulation 62A, read 20 September 2026, https://www.legislation.gov.uk/uksi/2016/1101/regulation/62A.

Reviewed on 21 September 2026.