Thread by @pmdfoster

It's OUT!! My weekly #Brexit Briefing for @ft
This week: the transition from "CE" safety marks (u see them on everything) to "UKCA" marks - the UK's post-Brexit copycat version - which is creating pointless headaches for business...stay with me /1

on.ft.com/36lvXeS

@FT So what's this about? Well, as an expression of UK sovereignty after #Brexit the UK decided that it wanted its own equivalent of a CE mark -- even tho it remained part of European Standards Organisation which co-ordinates standards -- so UKCA was born /2

captec-group.com/the-new-ukca-m…

@FT Since standards are the same, and most businesses (in non risky sectors) can "self-certify", you might think this is just what @SamuelMarcLowe calls "performative divergence" -- just for #brexit show and a bit of harmless form-filling. Alas not. /3

@FT @SamuelMarcLowe For three reasons, this is a headache for business even before we've diverged (or the EU diverges) and we end up with dual or competing standards regimes... and it's headache that's gonna grow. /4

@FT @SamuelMarcLowe 1) for 'risky' products (cars, lifts, some construction materials etc) you can't self certify -- you have to use a "notified body" (a professional assessor) and there aren't enough of them! So per @NickJMellor for Lifts there is 1 body, but 1,000s of items to certify /2

@FT @SamuelMarcLowe @NickJMellor 1b) This creates a backlog of CE-marked products that need a UKCA mark by Jan 1 2022....and then raises Qs: what about old CE-marked lifts being repaired in UK -- a Siemens lift in Brighton say -- does the spare need a UKCA mark? No-one seems to know! /6

@FT @SamuelMarcLowe @NickJMellor It's worth remember at this point that none of this benefits anyone -- its still same EU standards, so it's not making things safer or better. Just cost to rebadge and re-label. Oh, and products from NI that can be CE marked can circulate in GB anyways! /7

@FT @SamuelMarcLowe @NickJMellor 2) This doesn't just impact UK businesses. If you have an EU supplier then they also need to get UKCA marks for all their products to be legal in the UK from Jan 1 2022. For some that'll be worth it, for some not. That's risk to UK supply chains tho - even before divergence /8

@FT @SamuelMarcLowe @NickJMellor 3) Then there is legal liability. To put a CE-marked product (some with UKCA mark) on market in GB, you must accept legal liability. (And vice-versa in EU). So companies are having to draw up legal agreements to cover liabilities if a court case happens. Yup, more cost! /9

@FT @SamuelMarcLowe @NickJMellor So this is why groups like Construction Products Association @CPA_Tweets and environmental services groups like @Actuate_UK are all howling for extension to Jan 1 2022 deadline -- an extension already granted to some, like Medical Devices, marine equipment /10

@FT @SamuelMarcLowe @NickJMellor @CPA_Tweets @Actuate_UK As Russell Beattie of the chief executive of the Federation of Environmental Trade Associations @FetaNews tells me, this isn't about refighting old battles: "We’re not remoaners. We need some sensible discussion about the consequences." /11

@FT @SamuelMarcLowe @NickJMellor @CPA_Tweets @Actuate_UK @FetaNews As @TimFigures, a former Biz sec adviser during the Theresa May era , observes, diverging from the EU regulatory framework brings “little or no benefit” in safety-critical industries like autos/aerospace -- even if it has some potential in 'future industries' like AI, tech etc/12

@FT @SamuelMarcLowe @NickJMellor @CPA_Tweets @Actuate_UK @FetaNews @TimFigures But the future doesn't help business fighting this senseless bureaucracy now -- all cost, no benefit. AND as standards evolve via ESO the UK will find itself an effective rule-taker (which it wasn't as an EU member) since standards link back to EU directives. /13

@FT @SamuelMarcLowe @NickJMellor @CPA_Tweets @Actuate_UK @FetaNews @TimFigures The politics of all this is pretty baffling. Was anyone sat in the 'Red Wall' or the Tory shires looking at the CE-marks on their TVs and kettles and yelling 'Oi! no, I want a Britshe CE mark!" Did they even notice them? Would anyone notice now? Can't believe they would /14

@FT @SamuelMarcLowe @NickJMellor @CPA_Tweets @Actuate_UK @FetaNews @TimFigures But on we trudge. @SamuelMarcLowe is betting that the UK gov will extend deadlines and keep aligned to EU standards for a good while yet -- but given lead times for cars etc, that (obvious) decision needs to come soon. Less that 6 months to go. Tick tock. ENDS