The United Kingdom Accreditation Service (UKAS) and Sweden’s accreditation authority Swedac have agreed a framework for UK-based conformity assessment bodies to undergo accreditation assessments locally while retaining access to selected EU regulatory schemes. The agreement was unveiled at the Global ACI Annual Meetings in Panama on 26 October 2026. It initially covers the EU’s Carbon Border Adjustment Mechanism (CBAM) and Renewable Energy Directive III (RED III).
Under the arrangement, UKAS will carry out accreditation assessments of verification and certification bodies based in the United Kingdom on behalf of Swedac. Swedac will remain the EU-based authority responsible for granting accreditation. The framework is intended to provide a route for UK conformity assessment bodies to meet relevant EU requirements without additional costs and delays associated with bringing assessment teams from abroad.
EU accreditation requirements and separation of assessment roles
Regulation (EC) No 765/2008 requires conformity assessment bodies participating in certain verification and certification programmes to be accredited by an EU-based accreditation body. The UKAS-Swedac framework addresses this requirement by separating the conduct of assessments from the authority that grants accreditation. The organisations said they intend to maintain the rigour of accreditation assessments while improving accessibility for UK-based conformity assessment bodies.
The approach combines assessments conducted locally by UKAS with recognition through Swedac. This structure is designed to enable eligible bodies to participate in the EU schemes covered by the agreement. Both frameworks depend on reliable, verifiable information, with requirements specifying the use of accredited certifiers and verifiers.
CBAM scope and RED III requirements
The agreement’s initial scope includes CBAM, which is designed to address carbon leakage by placing a comparable carbon cost on imports. Carbon leakage occurs when carbon-intensive production shifts to countries with less stringent carbon constraints, potentially undermining domestic decarbonisation efforts. The scheme’s operation relies on submitted data being supported by accredited verification.
The second covered scheme is RED III, which sets EU sustainability and greenhouse-gas requirements for renewable energy, including crops used in biofuel production. The directive also seeks to reduce greenhouse-gas emissions and accelerate the transition to clean energy through targets for the share of energy derived from renewable sources by 2030. Accredited certifiers and verifiers are specified as part of ensuring confidence in regulatory compliance.
Statements from UKAS and Swedac on market access
Matt Gantley, UKAS chief executive, said the agreement strengthened cooperation between the two accreditation organisations. He described it as demonstrating commitment to practical solutions for market access. Gantley said the framework would reduce unnecessary duplication by combining local assessment convenience with EU-wide recognition.
Gantley also said the approach would not weaken the robustness of accreditation procedures. He highlighted accredited services as a way to maintain confidence in quality and integrity while lowering barriers to trade. Alexandra Wilton Wahren, Swedac director general, said cooperation was intended to translate mutual trust into practical arrangements supporting trade.
Wahren said enabling UK conformity assessment bodies to obtain accreditation against EU requirements for CBAM and RED III would benefit businesses on both sides. She added that it would strengthen confidence in movement of goods between the United Kingdom, Sweden and the wider EU market. The agreement is intended to facilitate access for UK-based conformity assessment bodies while maintaining confidence among businesses, regulators and the public.
Additional schemes planned for future expansion
The UKAS-Swedac agreement currently covers assessments relating to CBAM and RED III. Both organisations are working towards expanding its scope to include additional schemes that require accreditation by an EU-based body. The expansion is intended to allow conformity assessment bodies established outside the EU and European Economic Area (EEA) to be recognised.
Any expansion would build on the initial framework for UK-based verification and certification bodies seeking to meet accreditation requirements associated with the covered European regulatory schemes.