BREXIT – what does it mean for UK Wood Product Standards & Canadian Exporters?

By: Lance Tao

Export Development Program, Canada Wood Group

Now that the UK is no longer a member of the European Union what does this mean for wood product exporters to Great Britain and EU?  This article provides some answers.

Unified rules for the EU single market began with the Construction Products Directive (CPD).  The system enables placement of building products on the market in all EU Member States (MS) based on a common technical language comprising harmonized technical specifications, supporting product standards (European Norms – EN), European Assessment Documents (EAD) for the technical approval of innovative products/systems plus the oversight of a single Notified Body (NB) located in any EU member state when third-party accreditation is required.  Just one set of integrated documentation enables your product to be placed on the market in all 28 member states.  Very useful indeed!

Unfortunately, Brexit is likely to ‘throw a spanner in the works’ for Canadian lumber and panel exporters to the UK.

One consequence of the UK having been involved for over forty years in the EU was that many conflicting British Standards (BS) were replaced by ENs, as BS ENs, which, of necessity, must now be retained.  And similarly, it has been necessary to retain, with appropriate amendments, the Construction Products Regulation (CPR).  (The CPD preceded the CPR.) In 2019, the UK government adopted and wrote into law the original EU CPR. All existing European harmonized standards will become UK ‘designated standards.’ This will mean that immediately following the UK’s exit from the EU, the European harmonized standards and UK designated standards will be identical.

Following the conclusion of the Brexit ‘deal’ in December 2020, UK government issued further amendments with which little changed other than an indication that Northern Ireland would no longer be covered by the 2019 UK CPR which became the CPR for Great Britain (“England and Wales, and Scotland”).  Northern Ireland will retain the EU CPR.

CE marking remained mandatory in the UK during the Brexit transition period and will remain acceptable for “a time-limited period” thereafter, which we now know is until the end of 2021. At that point, CE marking will cease to be acceptable in Great Britain, to be replaced by UKCA marking.  The two will not be mutually acceptable.  And, NOTE, January 1st, 2022 is the enforcement date when product arrives in the UK market with no leeway given! 

CE marking of construction products will continue to be accepted in Northern Ireland however CE marked wood where third-party accreditation is carried out by a UK approved body must also have affixed an accompanying UK(NI) indicator.   

British government communications advise: “Businesses must prepare for the end of recognition of the CE mark in GB and affix the UK marking using a UK-recognised ‘approved body’ for products which will be placed on the UK market from 1 January 2022.”  A significant question for Canadian lumber producers who are presently audited by an EU-based Notified Body (NB): will it be possible for an EU NB to also become a UK Approved Body?

For exporters wishing to continue placing products on both EU and GB markets it will be necessary to involve both an EU NB and a UK approved body, maintain two separate sets of technical documentation, audit records, product documentation and, of course, affix both CE marking and UKCA marking, which it is currently assumed will be acceptable, side-by-side, on marked products.  Clearly a case of redundant expense and paperwork.

There are several EU standards where the UK has not agreed with published versions, divergences being identified in UK national forewords and annexes.  How these will be resolved is not yet clear.

It is early days and there will be no change for Canadian wood product manufacturers over the course of 2021 until they must adopt UKCA marking in the fall to meet the January 1st UK port deadline.  What might happen beyond 1 January 2022 is, presently, anyone’s guess.