UK White Paper on Brexit: shallow and glib at best

Whether you want the UK to remain in the EU, step back into a looser relationship, or sever its ties altogether, the UK government’s White Paper is a document of huge importance. It explains current government thinking and plans. If it’s wrong or flawed, then the decision and negotiations will be made on false premises, and could lead to great damage to the UK and the EU.

Having worked for many years in standards, at a national, European, and international level, I was particularly interested to read its proposals concerning the UK’s future involvement in the making of standards at those levels. I was also frankly horrified at what the White Paper says, both in terms of its accuracy – it is wrong at best – and its understanding of the issues – which is dangerously superficial.

Standards are covered in a boxout which almost fills page 40, in the section on trade. Its first sentence is so wrong as to be dangerous:
Standards are voluntary technical agreements about the best way to do something, such as how to manufacture a certain product.

The errors in this sentence include:

  • In many sectors of industry, standards are now not in the least bit voluntary, but mandatory requirements which are enforced by law and/or by the expectations of customers and others.
  • Product standards have very little to do with ways of doing anything. They prescribe testable properties of a product.
  • Standards are never about the best way to do anything. They specify minimum acceptable properties.
  • Standards seldom specify manufacturing methods, but product performance.

Of these, the first is by far the most important error, as it affects the government’s approach to standards, which are a vital determinant of the UK’s ability to trade with the rest of the world in the future.

For a large number of products, ranging from toys to lifejackets, EU law requires all those products which are offered for sale within the EU to comply with product standards, and to be marked with the CE mark to attest to that.

Many of the product standards developed by CEN and CENELEC, the main European standards bodies (which are not even named here in the White Paper), are de facto implementations of EU requirements. Compliance with the relevant CEN/CENELEC standard(s) therefore allows a manufacturer or importer to use the CE mark, and for their product to go on sale to the public throughout the EU.

Pop into your local yacht chandlers, for example, and you will see that every single lifejacket or buoyancy aid on sale there has the CE mark, and details of the CEN standard with which it complies. The same is true for toys, electrical and electronic appliances, and a very wide range of other products. Many of those are products which the UK successfully exports to the rest of the EU. If those exporters were to stop CE marking, their products could not be exported to any EU country, as they could not be sold legally.

Many more products are required to conform to standards for non-legislative reasons. Most substantial companies are expected to operate within quality management systems, by their customers, investors, and their insurers. Key issues in quality management are the quality assurance of all components used to manufacture more complex products, and the overall product performance and safety at the end. A fundamental quality benchmark at both ends of manufacturing is compliance with relevant product standards.

For example, electrical and electronic systems often use capacitors (‘caps’). These must be manufactured to an acceptable standard, or they will fail prematurely, causing failure of the whole product, and sometimes hazards such as fire. The only practical way for a manufacturer to set the standard of the capacitors which they purchase is using accepted European or international standards. Ensuring that those components comply with those standards is part of quality management, as is ensuring that the end product complies with its appropriate standards too.

So if you go out into industry in the real world, you will find very few industries for which standards are not mandatory – either because they are required by law, or because they are an expectation by customers and everyone else.

If anyone in government really does think that “standards are voluntary technical agreements”, they don’t understand how modern industry and trade work. By prefacing the section on standards with that incorrect assertion, the White Paper misleads its readers into thinking that standards are not important, and we could perhaps make our own once we’re not in the EU. Nothing could be further from the truth.

Skipping to the final paragraph of that boxout, the UK government therefore concludes:
We are working with BSI to ensure that our future relationship with the European Standards Organisations continues to support a productive, open and competitive business environment in the UK.

In other words, the UK government hasn’t a clue what it intends to do.

The UK has, with Germany, been the main driver and workhorse of standardisation activity within CEN and CENELEC. It is only by being fully engaged throughout standardisation work that the interests of UK industry – and those of UK consumers – are adequately served. If you don’t make the standards, then you will find the standards of others being imposed on you. And sadly you will then discover that your competitors are not magnanimous and inclusive when they write their standards with which you have to comply.

Restrictive standards are a long-established and perfectly legal way for one country, or group of countries, to lock out competition from imports.

Ask anyone who knows anything about standards: continued UK membership of, and strong and active involvement in, CEN and CENELEC is absolutely vital. Relying on our membership of ISO is not adequate, and will very quickly leave our industry at a major competitive disadvantage. There would be little point in negotiating beneficial trade and customs arrangements with the rest of the EU if UK industry was unable to deliver competitive products which meet European standards.

That anyone should have to point this out now confirms that the authors of the White Paper either have not a clue what they are writing about, or they are deliberately trying to tell us alternative truths. Neither bodes well for the UK just before the start of negotiations.