Thursday, April 15, 2021
Remember Brexit?
Hoist magazine’s new editor, Jennifer Eagle, certainly does, hence her recent tweet:
‘…we are currently looking at EU regulations post-Brexit and how that will affect the hoist industry…’
We were happy to submit some comments for a timely article about a subject that was once so regularly in the headlines that it took a global pandemic to move it down the page. The problem is, as Jennifer suggests, Brexit hasn’t gone away and as businesses we’ve got to make sure that we conform to new legislation, while navigating ourselves away from Covid.
As we told Hoist magazine, there are two main post-Brexit issues that we have prioritised for attention:
- Customs
- UKCA marking
Customs
This is arguably the more problematic of the two because we’re like many companies in not feeling that we have total control over the situation. Importing core product from Europe, such as wire rope that we use to manufacture slings, is taking twice as long as it once did, largely due to the customs declaration, the official document that gives details of the goods that are being imported. A lot more data must be provided than was previously required.
Exporting our wares is more complicated too. It’s common knowledge that you need an Economic Operators Registration and Identification number (EORI number) if you move goods:
– between Great Britain (England, Scotland and Wales) or the Isle of Man and any other country (including the EU)
– between Great Britain and Northern Ireland
– between Great Britain and the Channel Islands
– between Northern Ireland and countries outside the EU
However, the type of EORI number you need and where you get it from depends on where you’re moving goods to and from. You may even need more than one. If you do not have the right EORI number, you may have further delays at customs and increased costs. Items may even be placed into storage.
But this is just the start of the post-Brexit customs legislation companies must adhere to. It’s prudent to do your research.
UKCA marking
This is arguably causing fewer problems but businesses must still be aware of it.
The UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking. The UKCA marking came into effect on 1 January 2021 but to allow businesses time to adjust, you will still be able to use the CE marking until 1 January 2022 in nearly every instance.
In most cases, you must apply the UKCA marking to the product itself or to the packaging. Sometimes, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.
Remember, the UKCA marking is not recognised on the EU market so products need a CE marking for sale in the EU, further complicating matters related to these dealings.
(Without wishing to overburden readers with legislative jargon, I also recommend you look up UK Declaration of Conformity and how it applies to your business.)
Friends in high places
I’ve blogged before about making sure that CEO doesn’t stand for Chief of Everything Officer. In other words, you’ve got to delegate assignments and rely on supporting organisations, especially as a company grows. Covid and Brexit have only reiterated the importance of being able to give other people ownership of tasks.
Where legislation is concerned, it’s wise to have an expert within the business and then look to outside sources of information, such as trade organisations (the Lifting Equipment Engineers Association or LEEA, for example).
Alan Varney, our operations director, plays a Number 10 role in relation to sales; hire; inspection; manufacturing; customer issues; conformance; operations; health and safety; legislation; and internal / external audits. He also oversees the company’s training content, both in terms of delivery to staff and outside candidates. Alan looks to the Institution of Occupational Safety and Health (IOSH) for education on areas relevant to the growth of the operation and boasts a deep knowledge of the health, safety, environmental and quality procedures that we must adhere to from the top down. All good companies (teams) have a solid Number 10.
Beyond IOSH, LEEA is a go-to resource for anyone in the lifting industry. LEEA pointed us to the Department for Business, Energy and Industrial Strategy (BEIS) published guidance on UKCA marking, for example. BEIS reiterated that if you placed goods on the UK market (or in an EU or EEA state) before 1 January 2021, you do not need to do anything for these individual goods. It added that they can continue to circulate on either market until they reach their end user and do not need to comply with the changes that took effect from 1 January 2021. It was helpful to know that the guidance applies to goods placed on the GB market after 1 January 2021.
LEEA issued its own statements as well…
Lifting equipment is considered to be ‘placed on the market’ when it is made available in Great Britain, Northern Ireland, or the EU for the first time. Placing on the market refers to each individual item of lifting equipment and partly completed lifting equipment and not to a model or type. In order to place products onto the market in Great Britain and Northern Ireland the manufacturer or his authorised representative must fulfil all of the relevant requirements of the Supply of Machinery (Safety) Regulations 2008[1] – Part 3 General prohibitions and obligations.
…which is worth digesting in its entirety.
It’s certainly an interesting time for many lifting and rigging gear companies as Q2 2021 gathers pace because there is so much turbulence in the world (most paths lead back to Covid and Brexit) yet our services remain in demand and important manufacturing, construction and infrastructure projects have only gathered pace since the turn of the year.
There are an abundance of opportunities out there, so it’s important not to get derailed by taking your eye off legislation and conformity.
Au revoir.
Steve Hutin
Managing Director
Rope and Sling Specialists Ltd
