Will BREXIT require a re-think for products in relation to CE Marking and EN standards? Will there be change? Or is the best policy, perhaps, to keep calm and carry on? What does No Deal mean?
Few in the current fevered political environment have in mind what happens in a post-Brexit UK to the suite of glass and glazing standards originating under the CPR. The glass and glazing standards have been very well established for around 20 years, after what was a long gestation period of diligent standardisation work in which the UK industry took such a prominent leading role. Will Brexit bring problems? Or can we just follow on, still dancing to the EN tune?
One sure aspect of BREXIT is that very little is actually nailed down. Nothing is certain relating to possible consequences and outcomes. Politicians have wandered into a political morass and are now going about in increasingly smaller circles trying to find a way out to firmer ground. We won’t know in many areas what the implications are until events start to unfold after the UK leaves.
Even when leaving is finally settled, we still cannot be entirely confident what will emerge as a result. Uncertainty rules, OK? There is a hope that the implications will not mean a re-working of all the product standards that now provide such a firm basis for glass and glazing products in the UK.
It is useful to recall the origin for those glass and glazing standards – the background history is important
The standards come from the Single Market, determined by processes under the Construction Products regulation (the CPR) subject to the original EU Treaties, originating way back from the Single European Act, in Margaret Thatcher’s day, to establish the single market by 1992. The Act came into force in 1987, under the Delors Commission. Before the stimulation provided by the European single market process there were no BS glass and glazing product standards in the UK.
A fundamental requirement by treaty is the free movement of goods without technical barriers to trade within the EU. That requires what is described as a common technical language, captured by harmonised European Norms (hEN’s) that allow the definition of product types and classification according to key properties and characteristics.
First came the Construction Products Directive in 1988, finally leading to a new regulation of the European Parliament 305/2011 known as the CPR (The Construction Products Regulation). The CPR made CE marking obligatory for qualifying products available for sale and placed on the EU market (i.e. those which are covered by an appropriate product harmonised standard, hEN).
On that count there is perhaps not cause to worry unduly. It seems BSI will remain part of the European standards club – at least as far as we can see, at the moment, until things settle down further.
BSI has announced that they have been accepted to continue as a full member of CEN in transition to BREXIT until the end of 2020. How membership continues beyond the interim period is not yet clear: CEN membership rules require the national bodies to come from countries that are either EU or EFTA members. The UK looks likely to be in neither camp.
As a member of the standards club, the UK represented by BSI will be able to continue using the BS EN standards that have already been developed. The consequences of not being able to continue with those standards is horrific to contemplate. They have all been developed over many years, involving a very high level of work in various European and UK standards forums, for many industry people. It would take years to go over that work again, to replace the BS EN’s with original new BS’s. It is fundamentally important to keep the British Standards for products, testing and performance classification that are available from adopted EN standards.
When standards have to be updated, or new standards developed, the future ability to be as fully engaged in the standardisation process is less clear and somewhat hazy.
Hopefully the deadlock intransigence to agree will not spill over into standardisation, where there has been harmony. But the UK may find itself not as welcome in European Forums as it has been in the past. Voting rights might not be the same. And it would be an unwelcome outcome if UK industry should not be as influential as it has been in the past.
Conformity with the EN standards is shown by the CE Mark, the only mark acceptable for compliance with the CPR Single Market process. If the UK is no longer part of the EU Single Community Market – by definition, beyond the CPR – then it’s obvious that the CE Mark can no longer hold sway in the UK. Government has suggested an answer. There are optimistic noises and the mood at least in this respect, can be said to be somewhat upbeat.
If the UK crashes out on a No Deal basis then the Government has said that goods already on the market that meet EU CE mark requirements can still legitimately be placed on the UK market in the same way. Current arrangements are expected to have force through a new UK mark, the CA Mark (i.e. Conformity Assessed). The stated policy intention is that new UK rules will mirror the EU rulebook. That at least is the anticipated position when the starter gun goes off.
But this is to be time-limited. Products tested by a UK-notified body under CPR procedures will no longer be able to be placed on the EU market without re-testing and re-marking by a EU-recognised conformity assessment body. A UK-based organisation cannot be a new EU notified body. UK bodies notified under the CPR will be granted new UK Government approved body status, Government has said. And those organisations will be able to assess products for the UK market against UK essential requirements (which are naturally expected most likely to mirror EU essential requirements).
All this scenario comes under the heading “We hope; and expect.” But there are many BIG influential issues to be resolved yet. The best policy in the absence of anything more definite does seem to be to keep calm and carry on. But don’t be surprised if there should be unforeseen consequences and disruptive unwelcome outcomes.
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