By Paul Sheerin
The first days of July have understandably seen several reviews of the first six months of Brexit, trying to take an objective view on the impacts and challenges that have been clarified in this time. An interesting perspective on that comes from our colleagues in Northern Ireland who have really been at the sharp end of those changes, with wider stability at stake for them in addition to the economic concerns that industry strives to avoid.
In that respect they would remind us that Brexit hasn’t fully happened yet on the island of Great Britain, pointing to their reality of the difficulties associated in carrying out the required import checks, a can which has been kicked down road for the rest of the UK until the beginning of 2022 at the earliest.
The experience that businesses in Northern Ireland have endured in that respect is a cautionary tale. In May this year, industry body Manufacturing NI stated that a fifth of their businesses reported that suppliers from Great Britain were unwilling to engage with the new requirements, ultimately meaning that some of those businesses are no longer serving the Northern Ireland market.
Here at home, the current headache for most Scottish manufacturers is availability – and pricing – of raw materials and components sourced from their global supply chains, including of course Europe. Put bluntly, if one in five suppliers in Great Britain see the additional barriers of the import checks required by Brexit as too great a burden to overcome for their UK partners in Northern Ireland, what do we think the ratio will be for our European suppliers? As ever, the tone of the conversation with Europe from our UK Government can help here, a move away from the ‘dead in a ditch’ rhetoric essential to steering a path through Brexit which is far from “done”.
Let’s take another example of a Brexit uncertainty not yet clear, and, although unlikely to be in view of the general public, it’s of significant and material importance to our manufacturers. On January 1, 2022, the UKCA mark indicating product conformity is currently planned to come into force, replacing the CE mark for goods placed on the UK market, meaning that a UK manufacturer who sells goods in Great Britain must ensure they certify and carry a UKCA mark, regardless of whether the product carries a CE mark. UKCA marking under Construction Product Regulations specifically highlights a problem around an inconsistency in approach, with UK Conformity Assessment Bodies (CABs) able to use European Union test results for some but not other products. But many CABs still want to test when they don’t need to and charge handsomely to issue certificates even when using the test results of others, and where retesting of products is required the bill for a small or medium-sized enterprise can be approaching six figures.
The next problem – and this is definitely a problem rather an opportunity – is that, unsurprisingly, before Brexit the option of access to accredited test bodies across the EU brought capacity to ensure that testing kept pace with the need to have products ready to sell. Last month engineering services body Actuate UK estimated that for certain product categories, industry is estimating that 64 years’ worth of retesting will be required, at that time with only seven months to go.
Scottish Engineering and other engineering representative bodies across the UK have raised this issue repeatedly with the UK Government, urging it to allow the CE mark to be recognised beyond the current deadline to allow more testing capacity and CABs to come on stream, avoiding damage to industry. Like others, the response received has been that we have left the EU, that the planned date must be adhered to because recognition of the CE marking and EU conformity assessment in effect would mean ongoing recognition of EU regulations. For me that reads that getting Brexit “done” is more important than saving unnecessary costs, upheaval and loss of business to sector companies who have been diligent and forward-thinking in their planning for the next impact of Brexit. The breadth of conformity assessment detail and the testing associated could send the most committed of insomniacs to sleep, and we know from previous deadlines that not all of our sector is as prepared as they might be. What else sits below the visible part of this particular iceberg?
You could argue that the UK Government has time on this to hold off and at the eleventh hour announce a delay to avoid the impact, but companies in this dilemma need to press the button on retesting now, incurring those expensive bills as they try to bet on which way this will steer. Without that clarity, if they don’t start that testing now this situation still holds the potential that, next year, we could be reading about UK manufacturers who can’t sell their product in the UK, because of Brexit.
Paul Sheerin is chief executive of Scottish Engineering
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