March 2021

26 n MACHINE-BUILDING March 2021 www.drivesncontrols.com What the UK-EU deal means for British machine-builders F ollowing long-running negotiations and a deadline that was repeatedly postponed, the UK and EU finally agreed a new trading relationship on Christmas Eve, 2020. Until the end of the transition period on 31 December, it had been business as usual for the UK’s machine- builders. 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 their 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 selling machines in Northern Ireland is now different from selling in England, Scotland and Wales, collectively referred to as Great Britain. British machine-builders are already familiar with the CE marking process (or they certainly should be). CE marking continues for exports to EU 27 countries. Later in this article I will discuss the small, yet vital, actions that need to be taken. Now that the UK has left the EU, however, machines for the home market can no longer CE-marked because CE marking is being replaced by UKCA (UK Conformity Assessed) marking. This process is all but identical as long as the UK’s Supply of Machinery (Safety) Regulations remain aligned with the European Machinery Directive. Nevertheless, there are some changes to documentation and machine marking that need to be implemented. The most obvious change is that machines need to have a UKCA mark applied instead of a CE mark. Both the HSE (Health and Safety Executive) and BEIS (Department for Business, Energy and Industrial Strategy) advised last year that, for the time being, CE labelling will continue to be accepted for products that have already The new trading relationship between the UK and the EU has major implications for UK machine-builders that sell into Europe. Derek Coulson, a machine safety specialist with more than 25 years’ experience and a director of Hold Tech Files, examines some of the repercussions. UK machine-builders that export equipment to the EU have been affected by the ending of the Brexit transition period

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