Thread by @pmdfoster

🚨🤷‍♂️ ⏰🔌🎛 🚨NEW/EXC Manufacturers now screaming for clarity from Government about how the UK’s new “UKCA” standard (replacing CE Mark) will work after #brexit - this one is a real head-scratcher. 🤷‍♂️ Stay with me. 1/thread.
on.ft.com/32C70Lr

It starts with the 'CE' mark - the EU-wide quality assurance standard 'mark' that's needed for pretty much all industrial goods from car brakes and airbags to industrial pressure valves and electromagnetic engine safety tests.

But with #Brexit the UK is dropping out. So what?/2

Well the EU-wide scheme, which amalgamated a host of national standards marks into a single regime ("business heaven" as one SME described it)...will be replaced in the UK by a new "UK Conformity Assessed - or UKCA" standard.

Naturally, industry wants to know what that is.../3

But thus far - to the rising frustration of @honda and the members of the UK manufacturing lobby group @MakeUK_ the government won't say what the UKCA standards are...OR what will happen in Jan 1 in terms of enforcement. Despite industry saying it needs to know./4

@Honda @MakeUK_ Back in 2019 as 'no deal' loomed the then govt said that the UK would carry on accepting the 'CE' mark for a "limited time" after #brexit, but that was cancelled in Jan 30 because there was now a 'transition' period...but no news since /5

gov.uk/guidance/prepa…

@Honda @MakeUK_ As things stand, products that currently use the CE marking to demonstrate compliance with EU requirements will have to comply with these - as yet unspecified - new national UK requirements.

With less than six months to go there clearly isn't time to do this.../6

@Honda @MakeUK_ So manufactures like Honda (and other @MakeUK_ members are begging for mercy! Telling govt to reinstate the 'grace period' so that they at least have time to adjust to the new regime... or they won't be able to place goods on the market. Which would be bonkers./7

@Honda @MakeUK_ Which is why everyone assumes, in the end, the Govt will have to face facts (like it did on its phased in border arrangements) and agree to this...but for now ministers sit on their hands because negotiations are ongoing in Brussels and they don't want to give away 'leverage'/8

@Honda @MakeUK_ The UK is seeking a 'Mutual Recognition Agreement' that would enable testing bodies on both sides of the Channel to issue certificates for each others regimes - but you'll still need BOTH. A UKCA mark for the UK, a CE mark for the EU.

So second Q: what's the point of that?/9

@Honda @MakeUK_ That's a mighty good question, because as SME owner Andrew Varga tells me, there really are only two 'global' standards regimes for his pressure valve business - the EU's CE mark, and the US's ASME mark. China is trying, but basically US and EU are the hegemons. /10

So what is worth of having *another* standard? The govt says UKCA will be a mark of UK's "highest standards in the world"...but business says it's just hassle, confusion and unnecessary complication for absolutely no obvious gain whatsoever. Because.../11

As Mr Varga says:

- if UKCA is weaker it will damage the UK’s reputation;

- if it’s tougher, that’s pointless since CE is the global gold standard and..

- if it’s the same, but with a UK badge on it, then it’s a nugatory effort /12

The presumption in Whitehall is that the UK standards will essentially be a carbon copy of EU CE mark standards...but you still need 'notified bodies' to certify them in both jurisdictions and industry fears that as everyone rushes to do this, these will be overwhelmed. /13

It is always worth remember that this approach - on CE marks, on waiving safety and security decs, on associate membership of EASA and EU REACH - are all *active choices* that this government is making, largely meaningful consultation with industry and the public /14

Being a professional Brexit bore I often find myself trying to explain this stuff, to ask people if, for example, they'd be happy to lose their job or face higher prices in order to have a UKCA mark over a CE mark? I've yet to find anyone who wants to die in a ditch on this. /15

In fact - bitter irony of ironies - one of the most common things you hear is that people wanted to leave to "escape Brussels red tape" - and yet, as is becoming apparent with the publication of the Border Operating Model, #brexit is taking us back in bureaucratic time /16

It will be interesting to see whether this stuff 'cuts through' - one argument for the govt doing a deal is to make sure that it doesn't. The economy will, in aggregate be smaller than it otherwise would have been (already is)...but we don't live the counterfactual. /17

So Mr Varga tells me he's lost 15% of his EU business already because customers in EU won't use his parts in products with long life-cycles because they fear they won't be able to count them as 'local' content for export purposes - the dreaded rules of origin. BUT.../18

His business has still grown over the last two years, finding more customers in the UK and rest of world. It's still smaller than it might have been, and in aggregate that hurts UK consumers, workers, but the sky doesn't fall. But I digress...for now he wants details on UKCA/19

Those I cannot help him with. That said, the *good news* is that someone has found time to design a natty logo for the UKCA mark!

Coming to an industrial product near you soon...or soonish. Or sooner rather than later. If that helps with planning?

ENDS

PS...on further thought. UK has guaranteed 'unfettered' access for Northern Ireland to UK Internal Market. So presumably CE marked goods coming via Republic of Ireland will travel freely into UK? So they'll be floating around anyway?