UK Government Report

Electronics and Machinery Sector Report

This report covers both the Parts and Machinery sector and the Electronics and Electrical Sector. As defined these sectors combined contribute c. £28bn to UK GVA

Parts and machinery

‘Parts and Machinery’ is used to describe a discrete subset of UK manufacturing (the manufacture, installation and repair of machinery and equipment). This collective does not operate as a single sector and Government has not traditionally engaged with the entirety of this defined group.

The current EU regulatory regime

The majority of products in these sectors are covered by harmonisation legislation that set out the ‘essential safety requirements’ for the product. The legislation also sets out the conformity assessment process (pre-market testing requirements) and various administrative obligations, including documentation, labelling and use of the ‘CE mark’ required to be undertaken to demonstrate compliance with the legislation. Conformity assessment ranges from declaration by the manufacturer or importer supported by documentary evidence, through to mandatory use of test laboratories appointed by an EU Member State.

For products (or aspects of products) not covered by harmonisation legislation, Member States may maintain their own domestic technical regulations (a small group for these sectors). There is also the principle of mutual recognition, which states that (subject to various caveats) a product which is legally marketed in one Member State is entitled to free circulation throughout the rest of the EU.

Safety-related legislation

All machinery, electronic and electrical products are regulated for safety under EU law to ensure a common requirement across the internal market. Examples of legislation in this area include:

he Machinery Directive: Manufacturers of new machinery38 (and other products in scope) to be placed onto the European Economic Area (EEA40) market must design, construct and supply products that comply with the Machinery Directive. In particular, they must be designed and built to meet the relevant essential health and safety requirements. These requirements have been implemented in the UK by the Supply of Machinery (Safety) Regulations 2008, as amended by the Supply ofMachinery (Safety) (Amendment) Regulations.42

Radio Equipment Directive: Some electronics products will be subject to the Radio Equipment Directive, which requires that radio equipment products placed on the market are safe (in terms of the health and safety of persons and domestic animalsand the protection of property) and do not interfere with the radio spectrum. It also requires an adequate level of electromagnetic compatibility and efficient use of the
radio spectrum.

The Low Voltage Directive : This directive ensures that electrical equipment within certain voltage limits provides a high level of protection for European citizens, and benefits fully from the Single Market. Electrical equipment under this directive covers a wide range of consumer and professional products e.g. household appliances, cables, power supply units, laser equipment and some components such as fuses.

Product safety legislation is enforced by national Market Surveillance Authorities (MSAs). For the UK, safety legislation is usually enforced by Trading Standards or HSE although some measures are enforced by other agencies (e.g. Environment Agency, BEIS RDD, and Ofcom). The procedures followed by MSAs are designed to ensure that only compliant products are allowed access to the Single Market, and unsafe or non-compliant products are identified and removed from the market.

Environmental-related legislation

Machinery, electronic and electrical products are also subject to a number of environmental regulations. Examples of legislation in this area include:
41. Waste Electrical and Electronic Equipment Directive (WEEE): This covers the appropriate disposal of these items to avoid significant environmental and health impacts and to encourage resource efficiency, given that the production of electronics and electrical machinery relies on the use of scarce resources (e.g. rare earths). This includes collection schemes which place burdens on the manufacturersand retailers of electronic goods.

Restrictions on Hazardous Substances Directive (RoHS): This restricts the use of hazardous substances in electrical and electronic equipment. The legislation requires heavy metals (e.g. lead, mercury, cadmium), and other materials such as flame retardants, to be substituted for safer alternatives.

Registration, Evaluation, Authorisation of Chemicals (REACH) Regulation: Chemicals produced in or imported by the EU are subject to the EU REACH44regime.
Chemicals are a prime input material for many electronic component manufacturers.

Ecodesign Directive:: This establishes a framework to set requirements for energyusing and energy-related products sold in the EU. Many electronic devices aretherefore in scope. The Directive itself only sets the framework – the minimum ecological requirements are adopted through specific implementing measures for each group of products, so its effective scope will increase over time.

Standards

EU regulations on machinery and electronics are supported by voluntary European standards which provide a technical route to compliance. These standards are developed by European Standards Organisations 45 following a direct request from the European Commission. Though not mandatory, compliance with these standards offers a simple way to demonstrate compliance with the essential requirements of applicable EU legislation.

In the majority of cases these European Standards are drawn from international standards, developed through the International Electrotechnical Commission (IEC) and the International Organization for Standardization (ISO). Industry stakeholders look to a common global approach where possible and therefore work through national standards bodies, such as the British Standards Institution (BSI) in the UK, to minimise any deviation between the international standard and ‘regional’ (e.g. European or Australian) standards.

Intellectual property

Intellectual Property frameworks are highly relevant to the electronics sector. Sampled information from the Intellectual Property Office suggests that, in 2014, around 11% of companies in this sector had trademarks in force, with around 11% of companies classed within ‘manufacture of computer, electronic and optical products’ and 2% of companies classed within ‘manufacture of electrical equipment’ had patents in force. This is in comparison to the 0.3% of the IPO’s total sample of over 2.5m companies that had patents in force in the same year.

Alternatives

Alternative Post-Brexit Business Frameworks (UK Government Report)

Best of Both Worlds

Manufacturing in Ireland

Distribution from Ireland

Trade in Goods

Product Standards

Irish Standards

CE Marking

EU Accreditation

EU Product Surveillance

Product Responsibility

Product Liability for Importers