Brexit and its consequences for the lift sector

Great Britain has not been part of the EU single market and customs union since 1 January 2021. The article by Jan König treats the consequences for the lift sector.

However, anyone in the lift industry who thought that everything would be settled with the departure of the United Kingdom and approval of the EU parliament of the Trade and Cooperation Agreement is in for a disappointment. Things could in particular prove difficult for exporters of safety components to Great Britain.

First, a distinction must be drawn between Great Britain and the United Kingdom, which also includes Northern Ireland. The northern part of Ireland continues to be part of the EU single market; consequently, all relevant EU regulations for the distribution of products apply there.

The situation is more complicated for Great Britain. First, some good news: the British implementation of the Lift Directive, the UK Lift Regulations of 2016, are almost identical with 2014/33/EU. This means there are no significant changes to the fundamental health protection and safety requirements or conformity procedure requirements.

Moreover, the British Standard Institution has signed an agreement with the Comité Européen de Normalisation (CEN) to remain a CEN partner: all EN 81 standards are preserved. By the way: technical documentation and existing market approvals should no longer include any national designations, such as DIN EN 81, since only the European designation EN 81 is accepted.

Problems with safety components

Now we come to the approved bodies and as a result to the problems with safety components. They may still be placed on the British market up to the end of the year if they have been passed by an approved body in the EU and bear the CE mark. From the coming year, this will no longer be possible. Use of the UKCA mark will then become mandatory; an approved body in Great Britain will be necessary from 2022 for conformity assessments.

Photo: © Habib Ayoade / unsplash

This means that suppliers/assembly companies for lifts and manufacturers of safety components now have less than seven months’ time to transfer their certification to a UK approved body.

The European Lift Association ELA assumes that the problem will be greatest with safety components, since there is a large number of them - approximately at least 1000 different types. The problem is that there are currently only five bodies that can completely approve lifts and only a single UK approved body that can certify safety components - BSI Assurance UK.

Approval: an extensive process

The expectation had in fact been that transferring certificates valid in the EU would be uncomplicated. But reliable information is now available that approval of safety components in Great Britain is a process that is as comprehensive as new approval in the EU – all documents have to be examined in full and the tests conducted anew.

Approved bodies in the EU have admittedly now also applied for approval in Great Britain, but this process appears to be taking between eight and twelve months. Consequently, every company supplying the British market should contact its previous approved body and ask what the position there is.

The VFA has drawn up a comprehensive letter about Brexit for its members and also provided information at the last meeting of the VFA Standards Working Group. Moreover, there is an EU website that provides information on this topic and an EU-wide telephone number in every EU language (00 800 678 910 11). Guidelines on the distribution of industrial goods are also available on a British government website.

By Jan König
The author is a technical consultant of the VFA-Interlift.

More information (1): EU website: https://europa.eu/european-union/contact_de
British government website: www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain
Exports from the EU to GB: www.gov.uk/import-goods-into-uk
Imports from GB to the EU: https://www.gov.uk/export-goods

More information (2): From 1 January 2022, manufacturers of safety components must draw up a GB conformity declaration on distribution according to the above-described approval in Great Britain and supply English operating instructions with the product.

It is already necessary to either state the name and address of a legal person with registered office in the United Kingdom on the product or an accompanying document, which the market supervisory authorities can contact.

More information (3): Around 100 days after Brexit, most companies are experiencing Brexit effects that are more negative than they expected at the beginning of the year. This is evident from a recent survey conducted by KPMG and the British Chamber of Commerce in Germany (BCCG) among 93 member firms of the BCCG.

80 percent of these companies are based in Germany, the rest in the UK. As a result, companies are drawing the first conclusions. For example, one in six of the companies surveyed has decided to cease exports to the UK altogether.