As Architectural Technology professionals, we are constantly using and referring to standards which, for the past 40+ years have been harmonised with European Standards. One of the consequences of Brexit is that consideration needs to be given to all of our regulations (Building Regulations etc.) which make reference to standards.
An example would be within English Building Regulations, Approved Document B, where fire classification is defined by European Standards. The reason for standardisation is self-explanatory but with the coming changes, the UK will soon have to operate under its own standards' framework. This does not mean that European Standards are lower or higher, it just means that the testing and certification for products for use within the UK will no longer be able to carry the CE mark. Products will have to be tested and approved by a UK testing authority. It is hoped that any potential duplication or confusion will be minimal with cooperation between the relevant bodies.
The critical issue for Architectural Technology professionals is the matter of legislation and specification. We and our clients have become used to specifying standards and writing specifications making reference to British and European standards without thinking twice. Our standards, contracts, specifications and regulations all have European standards hard wired into them and we will have to start referring to new UK standards, although EN standards will always be there.
It is hoped that legislation will provide 'grandfather' rights/transitional timeframe to all designs and specifications that were created prior to 31 December 2020, that have not yet been contracted or started on site; as it appears that without an agreement that once we leave the EU, we may not be able to make reference to a European Standard.
As part of CLC Standards and Regulatory Alignment Group, there have been a number of meetings to discuss the effects of movement and transportation of goods and materials in and out of the UK after 31 December 2020. CIAT is represented on this Group, but there is currently no certainty on the concerns that we have.
Products | Use of CE marking
From 31 December 2020, the UK manufacturing sector will no longer be a member of the CE conformity marking scheme and will not be able to use the CE mark for sale of goods within the UK. There will be a UK notified body that will be responsible for all relevant conformity marking. There are to be other arrangements for Northern Ireland which will (currently) be covered by CE marking.
All testing that is certified in the UK by UKAS (ukas.com) will no longer be part of the CE scheme. Any testing that is based in the UK will only be able to certify products for sale in the UK and any products for export to the EU will have to be tested on 'European' soil.
Transitional arrangements are that from 31 December 2020 until 31 December 2021, materials and manufactured items which already have CE marking will continue to be able to be distributed without having to be re-branded with a UK conformity mark. As it currently stands, no agreement has been reached on new products that will be manufactured in the UK for domestic or EU export after 31 December 2020 and will require a conformity mark.
Regulatory Alignments | Movement of goods and materials
Another issue which will affect the way in which we work is the movement of materials and goods.
COVID-19 has had a far-reaching effect on the UK's stock levels of construction goods and building materials. This time of year would normally give merchants an opportunity to restock materials but a combination of factors are restricting this. Manufacturers have been slow to react to the reinvigoration of the construction sector and keep up with demand, whilst other goods are being sold elsewhere across the world at higher prices.
Brexit will no doubt create a 'different' strain on the procurement of goods and materials with new tariffs being introduced that were not present before. This will directly affect prices for import and export. Items, including any component parts, that you currently specify from abroad may be cost prohibitive come 1 January 2021.
What do we need to do as Architectural Technology professionals?
Definitely be aware of transitional arrangement coming into force on 1 January 2021. Many projects will only be entering the design stage in 2021 with construction programmed for 2022. We need to keep an eye on the proposals for conformity marks and UK standards for the following year.
With the looming tariffs and logistics for movement of goods from the EU to the UK and stock levels, we may need to start looking closer to home for the specification of materials and products coming from local manufacturers.
All CLC Brexit groups meet regularly and CIAT will keep you posted on developments across all groups into Brexit and 2021.