The impact of Brexit on standards and regulations
October 2016

For my short address at the recent CAB Members’ Meeting, held at Mercedes Benz World on 12 October 2016, I attempted to provide some clarity around the possible impact of Brexit on standards and regulations. At this point in time nothing has changed in this regard and it is very much business as usual. This should come as no surprise as, in case you had not noticed, we have actually not left the European Union yet…

It is also worth pointing out that standards-making in particular is led by private organisations. The national standards bodies such as BSI in the UK and DIN in Germany are private organisations; the European Committee for Standardisation (CEN) is an international non-profit association that is independent from any individual stakeholder, although of course it operates within the framework of EU Regulation. This highlights an important issue for the UK post-Brexit: where should we be positioned with respect to EU Regulations? Perhaps this is a: “What has the EU ever done for us?” moment (and no, we do not want answers on a postcard).

Returning to standards-making, BSI has made it clear that it continues to be a member of CEN and that in the longer term, it is BSI’s ambition for the UK to continue to participate in the European standards system as a full member of CEN post-Brexit. This is on the basis that shared standards facilitate market access with European countries and the maintenance of a unified domestic market structure across the UK facilitates trade and reduces complexity for SMEs and consumers. For CAB, this means we will continue to be active in developing, commenting and voting on European standards as well as national (BS) and international (ISO) standards. We will continue to work with our European partners and under the auspices of FAECF, the European Federation of metal window and façade trade associations, to promote and defend the interests of aluminium in building.

There is, however, more uncertainty when it comes to EU Regulations. In the short term, it is also very much business as usual, as we grapple with untangling 40 years of integration with the EU. While on behalf of industry we need to reduce where possible the amount of red tape that you have to cut through, we do need to balance the needs of industry and society in a responsible way.

Consider two pieces of EU legislation that arguably have the biggest impact on our sector: one is an EU directive and one is an EU regulation.

The Energy Performance of Buildings Directive or EBPD has driven the development of the requirements for the thermal performance of buildings across Europe, so Part L in England and Section 6 in Scotland, for example. Hence it is very important. When you look at the EU building stock, it is responsible for more than one third of CO2 emissions; three quarters of the buildings are deemed to be inefficient and four fifths of the buildings in place now will still be in use in 2050. It is clear to many that we urgently need to reduce emissions from the built environment. Some are saying we need all buildings to be Nearly Zero Energy Buildings by 2050 in order to meet the commitments made in the recent Paris Agreement (note: which is a United Nations framework, so not affected by Brexit).

What is the position of CAB? In principle we support the goal of Nearly Zero Energy Buildings (NZEB) and the fabric first approach – meaning we should get the building right before adding in any renewable energy generation systems such as photovoltaics. However, the devil is in the detail, and we need to highlight to regulators that the role of glazing is not just about insulation – it is about the energy balance, taking into account solar gains and air tightness, and it is about occupant comfort and daylighting, taking into account solar shading and natural ventilation. It is also about recognising that the size and orientation of products has a massive impact on the energy balance, as well as the local climate. It is also important that regulators set out their vision to inform new product development, although we are already seeing a regionalisation of approaches.

A difficult question to answer is how do we increase renovation rates as we must to move towards all buildings being NZEB? How can we best encourage people, particularly home owners, to replace their windows, and more importantly, replace them with aluminium systems? We need to ensure that the benefits of aluminium systems are considered in the round, from the “hard facts” such as their excellent energy balance performance, daylighting potential and durability to the “soft facts” of enhanced aesthetics, amenity and overall value.

Turning to EU Regulation, consider the Construction Products Regulation or CPR. It is the CPR that regulates CE marking across Europe and the CPR is currently a legal requirement in the UK. Love it or loathe it, the CPR has facilitated the business to business communication of product performance in a standardised way.

Against this backdrop, there is a transition underway in our sector that I believe will drive the need for standardised product data: Building Information Modelling or BIM. For BIM, product data will be driven by the performance characteristics listed in harmonised European product standards that are the basis for CE marking. The UK approach to Product Data Definition and the new LEXiCON tool for structuring product data are being used to help develop a consistent approach to BIM across Europe.

Hence in my view it is very much business as usual for standards both in the short term and most likely longer term and post-Brexit. Harmonised product standards used for CE marking will have an important role to play in BIM, for example. In the longer term, there is an opportunity to shape UK regulations and energy efficiency of the built environment remains high on the agenda. So while there is some uncertainty longer term, technically speaking “Keep calm and carry on”, as it is business as usual in the short term. CAB will continue to promote and defend the interests of our members and aluminium in building when it comes to standards and regulations.