Where does BREXIT leave the product standards and CE marking for glass?
One sure bet about BREXIT is that it will cause doubts and conflicts, polarised opinions and somewhat heated debate. It is doubtful if anybody can really be confident about what is likely to follow. We know that the UK is set to leave on 29 March 2019. But even when the terms are settled, we still cannot be sure what will develop. There are likely to be demons hiding in the details, which will only turn up as BREXIT plays out.
For the glass and glazing industry, a key consideration must be what happens to the suite of glass product standards that have been established now for 15 to 20 years after a long gestation period of diligent standardisation work that the UK industry took such a prominent role in bringing to a conclusion.
It is useful to recall the basis for these standards.
They come from the Single Market. Before the stimulation provided by the European process there were no BS glass 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.
Conformity with the standards is shown by the CE Mark, the only mark for compliance.
First came the Construction Products Directive in 1988. Then a new regulation of the European Parliament 305/2011 (The Construction Products Regulation, CPR), with reference back to the core agreements of the European Union, that made CE marking obligatory for qualifying products available for sale and placed on the EU market.
The CPR states that Construction works as a whole and in their separate parts must be fit for the intended use. Manufacturers and other suppliers responsible for placing products on the market need to declare where their products meet basic public health and safety requirements. Those requirements are expressed as a defined set of essential characteristics - fire safety, safety in use, protection against noise, thermal insulation, mechanical stability, and impact on the environment – all of which apply to glass products.
It is assumed that BSI as the UK’s national standards body will remain as a member of the European standards body (CEN). But that may not be straightforward. BSI has announced that they have been accepted to continue as a full member, in transition to BREXIT, until the end of 2020. How membership continues beyond the interim period is not yet clear, as 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 organisation.
Most importantly, what will happen to the CE Mark post-BREXIT? It’s a mark for the Single Market. And the UK will no longer be a member.
There are some optimistic noises. The mood is upbeat, as Government should be. The vision, and hope, following on from the Chequers conference is for the EU and UK to trade without tariffs, in what is described as a level playing field. It has been said where goods are concerned that the UK will follow a common rulebook. Or at least as common as can be achieved, politically. It is implied that what continues as CE marking within the Single Market will be mirrored by ongoing equivalent marking in the UK, on the basis that the closer the UK aligns itself with EU rules then the less friction is likely to occur at the new UK-EU border.
If the UK crashes out without a deal then the Government has said that goods already on the market that meet EU CE mark requirements can still be offered in the UK.
But this is intended 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. But UK notified bodies 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).
Those arrangements are expected to have force through a new UK conformity mark.
Whether that will correspond with existing UK third-party certification schemes is yet to be established. But established third-party certification clearly offers an obvious way forward, by adapting those processes to the new UK Mark for a friction-free and seamless way forward. What industry and the market certainly does not need are additional costs for no additional benefit. Those aspects are still to be considered.
NB # Glass was one of the first construction products to go through the whole EN process of standardisation and CE marking. Pilkington Pyrostop and Pilkington Pyrodur were both at the forefront of fire-resistant glass products in attaining the CE Mark. They are fully compliant, and Declaration of Performances can be provided by Pilkington UK. #
T A Anders Limited is a longstanding Licensed Supplier of the well tried and tested Pilkington Pyrostop and Pilkington Pyrodur fire-resistant glass and glazed framed systems. We stock the entire range at our modern factory in Trafford Park, Manchester, and can process, distribute, install in proprietary frames and provide fire safety and product guidance if required. For further information, please contact T A Anders Limited on 0161 736 2487 or email@example.com or visit www.andersglass.co.uk for product specification advice, information and test evidence.
These opinions are offered in good faith but it is the responsibility of the reader to satisfy themselves as to their veracity and form their conclusions