The policy paper released last Friday on the NI protocol reveals, among other things, the problem the government has got itself into by insisting on having some sort of independent UK standards. As we know goods made to a European harmonised standard are CE marked but we know the plan is to have a UK standard where good are marked UKCA. The NI paper confirms that goods made in Northern Ireland will have their own UK(NI) mark.
The key part concerns goods that require certification by an authorised body. The key bit is this (my emphasis in bold):
If you choose to use a UK-recognised body, you will apply only the relevant EU conformity mark, usually the CE mark, plus an additional UK(NI) mark. Check the UK(NI) mark rules which will be published shortly to find out what you need to do. Your good will be valid for the UK market, but cannot be placed on the EU market. This is because the results of mandatory conformity assessments carried out by UK-recognised conformity assessment bodies will not be recognised in the EU.
The question for most manufacturers in NI is why should I add a UK(NI) mark on anything I produce since this simply renders it unsaleable in the Republic of Ireland or the rest of the EU. There is no 'benefit' and only a serious and substantial downside. Why would the government even suggest it?
It repeats the rule and adds a bit of extra 'clarity' with this:
Products carrying both the relevant EU conformity mark, for example the CE mark, and the UK(NI) mark cannot be placed on the EU market. Harmonised goods carrying only the UKCA mark will not be valid for the Northern Ireland market.
You begin to see (a) what a unique place Northern Ireland will become next year and (b) what a problem the government is going to have with the whole idea of UK standards and certification. The EU are not going to accept UKCA or UK(NI) stamped goods. This will never happen. So, why would a manufacturer use them at all - when a CE mark will still (presumably) be acceptable in the UK?
Unlike the EU, the UK government cannot ban the use of the CE mark since millions (possibly even billions) of items are already being used every day across the UK and for many manufacturers, the EU market will remain a significant one. They will still need to comply with EU standards.
Moreover, anyone fitting a part with a UKCA mark to a larger system would be unable to export it. The EU have regulations on electric motors and variable speed drives for example and although I don't think the UK has a big electric motor industry (my own field of packaging used mainly SEW, a German company or Bonfiglioli from Italy) anyone fitting a UKCA motor would cut themselves off from the EU market.
Guidance on UKCA marking was published in February 2019 but withdrawn at the end of January 2020. This said:
Selling goods in the UK
In the majority of cases you will still be able to use the CE marking if you are selling goods on the UK market after the UK leaves the EU. The CE marking will only be accepted in the UK for a limited time after Brexit. The government will consult and give businesses notice before this period ends. Find out about the future use of markings in the UK.
In some cases you will need to apply the new UKCA marking to goods being sold in the UK immediately after Brexit.
The link above then takes you to this:
Future use of markings in the UK
After a time-limited period, only the UKCA marking will be recognised for the UK market. We will consult and give businesses notice before ceasing to recognise the CE marking. However, a product bearing the CE marking would still be valid for sale in the UK so long as it was also UKCA marked and complied with the relevant UK rules.
It is well known that business does not want to have two sets of standards so the result of the consultation will be fascinating. I expect the whole idea of having unique national UK standards will have to be dropped or heavily modified since there is zero logic to it, only jingoism.
How the CE mark can cease to be recognised is beyond me, especially when it is known the world over as being the gold standard and everything made to our own (EU) standards up to that point will carry that mark. Johnson, Gove and Cummings seem to believe that these standards are shackling British industry when the are the lubricant to international trade.
Imagine you are a manufacturer making goods which need an authorised body to certify compliance with both standards. Firstly, it adds needless expense but more than that, if you affix a plate to every item before shipment, you and will need to separate stocks and probably carry more stocks since you cannot be sure where demand might come from.
Also, a UK customer sourcing a specialised part might find it in Europe but the maker may not have submitted it for UKCA certification and therefore cannot ship into the UK. It is nationalistic insanity that hugely over estimates our influence. But then this is Brexit isn't it?
