Page 20 - Industrial Technology magazine February 2021 issue

MACHINE BUILDING

Implications of the UK-EU trade

deal for UK machine builders

IMPORT AND EXPORT

DEREK COULSON OF HOLD TECH
FILES DETAILS THE KEY CHANGES
FOR MACHINE BUILDERS IN THE
UK-EU TRADE DEAL

ollowing long-running negotiations and a deadline
that was repeatedly postponed, the UK and EU
finally agreed a new trading relationship on
FChristmas Eve. For the last few years, until the
end of the transition period on 31 December, it had been
‘business as usual’ for machine builders – yet they had
been left to speculate what would happen if the UK left
the EU with or without a trade deal. And if there was a
deal, what would it look like?
Now we know: tariff-free, quota-free trade with,
according to Prime Minister Boris Johnson, no non-tariff
barriers. However, that last point seems to be more a
matter of opinion than fact. If UK machine builders wish
to continue exporting to the EU 27 member states, then
they need to do certain things differently, plus there are
new requirements relating to customs declarations. Many
commentators say these look distinctly like non-tariff
barriers to trade.
Furthermore, machine builders in the UK will also
have to make some changes to continue serving
customers in the home market; let’s take a closer look at
that first. We will discuss Northern Ireland later but,
suffice to say, the Northern Ireland Protocol means that and the product itself. At the time of writing, we are not Approved Bodies but machine builders should check this
selling machines in Northern Ireland is now different from aware of anything in the trade agreement that would with their Notified/Approved Body and make sure the
selling in England, Scotland and Wales, collectively countermand this advice. documentation is updated accordingly.
referred to as Great Britain. Changes to the documentation should not be too
GB machine builders are already familiar with the CE onerous. As we have already said, the documentation now UK machine builders and Northern Ireland
marking process (or they certainly should be). CE marking needs to show the machine as being UKCA marked The Northern Ireland Protocol has been in place since
continues for exports to EU 27 countries and later in this instead of CE marked. In addition, where a Declaration of 1 January 2021. This permits free trade between
article we will discuss the small yet vital actions that need Conformity (DoC) or Declaration of Incorporation (DoI) Northern Ireland and the Republic of Ireland for most
to be taken. Now the UK has left the EU, however, previously referred to harmonised standards with EN manufactured products. It also ensures unfettered access
machines for the home market can no longer CE marked prefixes, they now need to refer to designated standards to Great Britain for manufacturers in Northern Ireland.
because CE marking is being replaced by UKCA (UK and all standard numbers should be prefixed with BS to Because of the need for free trade across the Irish border,
Conformity Assessed) marking. The process is all but indicate they are British Standards. Northern Ireland is largely aligning with European rules
identical so long as the UK’s Supply of Machinery (Safety) When preparing a DoC or DoI under the CE marking rather than GB regulations when it comes to placing
Regulations remain aligned with the European Machinery regime, the declaration requires a person established in manufactured goods on the market.
Directive. Nevertheless, there are some changes to the EEA (European Economic Area) to be named as Machine builders in Northern Ireland can therefore
documentation and machine marking that need to be authorised to compile the technical file. For UKCA marking continue to CE mark machines and sell them in Northern
implemented. there is no such requirement and it would appear that the Ireland, the EU 27 member states and, thanks to
The most obvious change is that machines need to authorised person can be anywhere in the world. For GB unfettered access, Great Britain. Machines manufactured
have a UKCA mark applied instead of a CE mark. Both the machine builders supplying the home market, this in GB for sale in Northern Ireland must be CE marked (see
HSE (Health and Safety Executive) and BEIS (Department difference will probably be immaterial. Similarly, the the section on exporting to Europe). Note that UKCA
for Business, Energy and Industrial Strategy) advised last requirement for the technical file to be in English will not marking is not accepted in Northern Ireland.
year that, for the time being, CE labelling will continue to bother machine builders in Great Britain. If Annex IV machines are conformity assessed by a UK
be accepted for products that have already been assessed For Annex IV machinery, where CE marking requires a Approved Body, then the machine must display both the
and CE marked prior to 31st December 2020. The UKCA Notified Body to undertake the conformity assessment, CE and UKNI mark; they cannot use the UKNI mark on its
mark can be applied to accompanying documentation only the relevant bodies in the UK are now termed UK Market own. UK Approved Bodies can continue to act as Notified
until 1 January 2023 if preferred but, after that date, the Conformity Assessment Bodies (UKMCABs). Most UK Bodies for products being CE/UKNI marked for Northern
UKCA mark must be displayed on both the documentation Notified Bodies are being converted automatically to Ireland.

20 INDUSTRIAL TECHNOLOGY • January/February 2021