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Leaving the EU: implications and opportunities for science and research Contents

Annex: Issues raised in written and oral evidence

We received over 270 written submissions to our inquiry, providing a wealth of information on the many issues of interest to the science and research community in the context of leaving the European Union. An illustrative selection of these issues are reproduced here, although it is not intended to be a comprehensive summary of the many issues raised. As the Government turns its attention to addressing the overarching issues highlighted in this report it should draw on these and other submissions to understand the community’s concerns.

Table 1: Funding

Issue

Description and written evidence references

Notes

Concerns that the UK might not be able to access EU funding, including Framework Programmes (Horizon 2020) and structural funds, after the UK leaves the EU—depending on which future UK-EU model is chosen.

The University of Southampton quoted data from the Swiss Secretariat for Education, Research and Innovation (SERI), showing the effect of Switzerland’s move to a partial association model, and described this as a “substantial decline in Swiss involvement and income during this period of uncertainty”.1 The SERI report goes on to state that “If Switzerland were to be fully downgraded to third-country status from 2017 onwards, its opportunities for participation and influence would be extremely limited. We would also expect to see an even sharper decrease in the financial and quantitative shares of Swiss participation in the [Framework Programmes]. A further concern would be the potential isolation of Swiss-based researchers. The fear is that over the long term, third country status could lead to a loss of expertise and could reduce Switzerland’s influence in research circles, both in Europe and indeed globally”.

HEFCE described the benefits of funds beyond Horizon 2020, particularly in supporting innovation: “EU public and private funds have played a significant role in supporting innovation in the UK. UK universities have received around £100M p/a from ERDF and ESF funding streams over the last three years to support a range of economic regeneration activities. Structural Funds have helped to improve regional competitiveness and absorptive capacity. Competitiveness and capacity are also supported by domestic businesses’ ability to access a range of EU funds including H2020. The European investment fund has provided important SME financing which in turn has leveraged venture capital and private equity funds. Each finance stream invests in private sector capacity to engage in research and development and this then helps university enterprise activity and innovation partnerships to be successful. In addition, universities have benefitted from working with EU businesses with good levels of research and development capacity and a high tech focus”.2

A description of the existing models for non EU-member involvement in Horizon 2020 is provided in the House of Lords Science and Technology report. This includes a description of the “Swiss model”.

Ability to lead projects and influence the EU Framework Programmes post-Brexit

The University of Oxford told us that: “For the UK (and in particular UK universities), whilst participation in projects is, of course, desirable, future success and the UK’s competitive edge is also dependent on the ability to influence the content of future research programmes, the areas for large-scale investment in research as well as the content of EU directives that affect research in the UK (eg animal testing, open access & data mining). It is vital that the UK is driving the research agenda rather than following the agenda of other member states.3

The House of Lords Science and Technology Committee noted that: “The UK currently has significant influence on the development of EU policy for science. It is not entirely clear how this would be affected in the event of termination of membership and adoption of Associated Country status”.4

The need for appropriate levels of funding to be delivered through appropriate new schemes, if access to Horizon 2020 and other funding streams cannot be negotiated

The Royal Academy of Engineering wrote that: “If the UK was unable to secure continued access to EU research and innovation programmes, it would be essential for the UK government to create suitable replacement research and innovation programmes using national funds. Any such replacement programmes should replicate the successful and unique aspects of EU programmes, including support targeted at collaboration and partnership at many different levels, including researchers, universities, large corporates and SMEs, plus long term visibility of themes and subject areas”.5

Loughborough University wrote that: “Participation in EU research projects is about much more than access to another research funding stream. Advances in research and consequent benefits to society and economy could not be realised by simply placing the same level of funding through a UK funding body”.6

The Wellcome Trust Sanger Institute described these features in more detail: “European funding structures have a number of significant differences from UK sources, but in conversations with Institute faculty the themes of investigator-led funding calls, mobility and career development came up repeatedly. Many faculty felt that the strategic direction of EU funding was more driven by investigators themselves than in the UK and this often led to the EU funding more ambitious projects than UK research councils were willing to. The EU also supports individuals through their career stages more than is currently the case in the UK. EU funding for career development fellowships is more generous and does not require a sponsor to top up the award, unlike most UK funders”.7

The University of Edinburgh added that “even if all displaced H2020 funding is fully replaced and ring fenced, it is possible that UK researchers will be still be disadvantaged if industry partners perceive that their contributions are better leveraged through Horizon 2020, with a consequent net drain of industrial sponsorship from UK universities in favour of their European rivals.”8

The Institute of Chartered Foresters queried which bodies would be distributing any replacement funding and to whom: “Whilst it would be good to ensure the UK continues to spend on research what it repatriates, it must ensure that whatever it does spend is available, on a level playing field, for all research bodies that can currently apply for EU funding namely, Universities, Public Sector Research Organisations, SMEs etc. Any funds repatriated should not be given solely to Research Councils to administer as they are not all-inclusive”.9

The University of Cambridge highlighted a need to ensure any domestic funding routes are synchronised with those in other countries: “The Government’s Balance of Competences Review (2014) found that international collaborations with non-EU members are made more difficult by the reliance of researchers in different countries on different funding cycles. Potential UK participants could run into problems in ‘synchronising’ research projects and funding with EU partners, in the event of the UK no longer being a full participant in Horizon 2020”.10

Key features of EU funding that should be preserved or imitated

The University of the Arts London (UAL) described EU funding as an “an approach that in many ways is more attractive than Research Council schemes to an institution like UAL”. UAL pointed to:

–Greater notice of funding calls, which gives HEIs time to assemble consortia. (A complaint about major Research Council directed calls is that the public notice period is so short that only those with informal prior knowledge have a serious chance of assembling a fully resolved response.)

–Wider and more inclusive support for academic and industrial partnerships. The structure of EU funding means that commercialisation is more integrated into the project lifecycle. This approach is especially attractive to the design discipline with its close links to professional practice.

–Greater opportunities for UK companies to be involved in publicly funded research. UK companies are keen to be involved in EU funding but SMEs in particular are wary of their complexity. UK universities provide a vehicle for British companies to engage with funding streams and expertise to which they would never normally have access.

–More opportunities to learn about funder priorities and expectations. Feedback on applications is more extensive and detailed than that from the Research Councils. Applicants can learn how to improve the quality of their bids, and so increase their chances of being funded in later calls.

Criticisms of EU funding routes that should not be replicated

The Chartered Institute of Foresters hoped that any future system would be as simple and free from “red tape” as possible, noting that “the Horizon 2020 programme has made substantial advances in reducing complexity and bureaucracy but many other EU funding mechanisms (LIFE+, Interreg and others) remain labyrinthine and non-uniform in their approach to eligible costs”.11

A group of researchers at Swansea University observed that “Rules and regulations around EU funding applications and grants are designed to fit a wide variety of funding calls over multiple programmes and research areas. As such, the known issue of overextended time-to-grant and intrinsic complexity of European funding create a high threshold of administrative knowledge and resources necessary to navigate these funds”. They suggested that “By returning the key sources of funding to the nation state level, Brexit may offer an opportunity to streamline research guidelines, thus reducing the resource burden of both applying for and undertaking large research grants. Some researchers indicate that many UK funding bodies, including RCUK bodies, Innovate UK and the Wellcome Trust, are all already simpler and more user-friendly than EU funding”.12

Ian Byrne, the Deputy CEO of a small charity undertaking research and development in the area of sustainable energy, told us that “In recent years, the EU has consolidated many of its funding strands into just two: those around the European Social Funds and, for science-based activities, Horizon 2020. This has had the effect of reducing the number of projects being funded, while maintaining the total level of expenditure. While this may be beneficial for fundamental research in “big science” it has not helped smaller organisations such as ours, working in fields where much of the research is incremental. In particular, in the area of energy efficiency we have seen a trend towards funding a few disconnected projects each year, which often appear to suffer from bloated administration yet modest achievements”.13

The effect of reliance on EU funding on smaller HEIs

We were told that “Smaller organisations such as Goldsmiths have relied heavily on access to the ERC and EU income to ensure their research income remains stable. Reduced access to EU funding sources would negatively affect this stability”.14

The effect of reliance on EU funding on smaller subjects

Representatives of some smaller research subjects in the UK were concerned about the level of their current reliance on EU funding. For instance, the Institute of Acoustics told us that 47% of funding for acoustics-related research in the UK is received through EU routes,15 and the Institute of Conservation highlighted Heritage Science as an area with a similar level of dependence on EU funding.16

Some information on the current level of reliance on EU funding by discipline was provided by RCUK.17 Over the three-year period from 2012/13 to 2014/15, EU Government Bodies provided 13% of all research grants and contracts income to UK universities. The variability is not restricted to ‘small’ subjects; Chemistry and “IT, system sciences, and computer software engineering” both appear in RCUK’s top ten subject centres by proportion of income from EU bodies (at 21.5% and 30.9% respectively), and also in the top ten by total level of EU income (at £155m and £142m)

Need to map EU funding mechanisms

Scientists for EU told us that “There is probably not, at this stage, enough appreciation of the myriad EU-based mechanisms that bring funds into innovative players in both the public and private sector at the moment. These must be mapped urgently. Horizon 2020 and the ”EU Structural Funds” (Regional Development Fund and the European Social Fund–jointly €10.8billion allocated to the UK from 2014–2020) are not the only investments”.

They highlighted the European Fund for Strategic Investment (EFSI) as one such route:”[EFSI], also known as the “Juncker Plan” is a recent initiative (launched jointly by the European Investment Bank, European Investment Fund and European Commission) aimed at using public funds strategically to dramatically leverage private investment into innovation. “The EFSI aims to overcome current market failures by addressing market gaps and mobilising private investment. It will support strategic investments in key areas such as infrastructure, education, research and innovation, as well as risk finance for small businesses.”18

1 University of Southampton (LEA 97) para 25

2 HEFCE (LEA 230) para A

3 University of Oxford (LEA 184) para 1

4 House of Lords, EU membership and UK science, Second report of the Science and Technology Committee, Session 2015–16, HL Paper 127, para 228

5 Royal Academy of Engineering (LEA 279) para 2.5

6 Loughborough University (LEA 109)

7 Wellcome Trust Sanger Institute (LEA 133) para 26

8 University of Edinburgh (LEA 159) para 13

9 Institute of Chartered Foresters (LEA 156) para 6

10 University of Cambridge (LEA 42)

11 Chartered Institute of Foresters (LEA 156) para 2

12 IMPACKT, Swansea University (LEA 138) para 7

13 Ian Byrne (LEA 134)

14 Goldsmiths, University of London (LEA 252) para 17

15 Institute of Acoustics (LEA 73) para 3

16 Institute of Conservation (LEA 86) para 1.1.1

17 Research Councils UK (LEA 235) annex 1

18 Scientists for EU (LEA 261) 2.3

Table 2: People

Issue

Description and written evidence references

Notes

Costs from visa requirements

Dr Julian Downward warned that the Crick Institute’s annual expenditure on processing visa and work permit applications could rise “from about £70,000 to some £250,000, if rules introduced to regulate entry of EU nationals are similar to those currently applied to non-EU nationals”.19 Similarly, the University of Oxford estimated that there could be “anything up to a tripling of work load” in order to process additional visa applications.20

The Society for the Environment noted the possibility of a “research passport” model as a solution, based on the National Health Service (NHS) research passport, “which grants honorary research contracts or letters of access to those who need to undertake research within the NHS”.21 However, the Society noted that “whilst a similar system would be a good compromise for those who conduct research, it may not be a suitable model for industries employing scientists who work in the field but do not conduct research as part of their activities”.

Movement of researchers potentially constrained by caps on overall immigration levels

The University of Cambridge explained that the current limits on Tier 2 visas meant that this route “would be unlikely to have the capacity to absorb the numbers of EU nationals which the sector would require”.22

The UK currently controls immigration from countries outside the EU through a system of visa ‘tiers’, which includes a mix of ‘points-based’ and ‘employer-led selection’ components. This includes tier-1 visas (‘exceptional talent’ /entrepreneurs), tier-2 visas (‘skilled workers’), tier-4 visas (students) and tier-5 visas (which includes approved ‘research placement’ schemes). Tier-1 and tier-2 visas have quotas—the 1,000 a year cap on tier-1 visas include an allocation of 250 places to be endorsed by the Royal Society, 150 by the Royal Academy of Engineering and 150 by the British Academy.

In March 2016, before the EU Referendum, the Government announced reforms to the skilled worker visa (Tier-2), following a review of the route by the Migration Advisory Committee, including an increase in the minimum salary threshold for experienced workers using Tier 2, from £20,800 to £25,000 in Autumn 2016 and £30,000 in April 2017 (For new entrants to the workforce, including those under 25, the minimum will be £23,000), and the introduction of an ‘immigration skills charge’ for each non-EEA worker an employer wants to bring to the UK (larger sponsors of Tier 2 migrants would be charged £1,000 per migrant a year, £364 for small businesses and charities). There would be an exemption for migrants undertaking PhD level roles

Reassurance for EU researchers currently in the UK is needed to avoid ‘brain drain’

The University of Leicester suggested that “There should be a fast-track way of enabling non-UK EU academics and researchers (including after any envisaged transition date) to obtain the right to remain in the UK when employed by the universities”.

The Babraham Institute wrote that “Action is needed immediately, EU-nationals need to be reassured that their status is protected now and in the future, or we risk losing the ‘best brains’ before negotiations even begin”.23

Student access to loans

UUK called on the Government to “Provide immediate reassurances to EU students starting in academic year 2016/17 regarding their unchanged tuition fee status and for 2017/18 entrants on their ability to access student loans, recognising that the UCAS cycle opens on 6 September 2016”.24 The Russell Group went further: “Our experience suggests that future cohorts of students will also be making decisions about where to study even though they may not be expecting to start until 2018/19 or 2019/20. This is expected to be a crucial time when negotiations between the UK and the EU may conclude and early clarification from the Government on the expected status of these students would be very welcome”.25

The Government announced on 11 October that “EU students applying for a place at an English university or further education institution in the 2017 to 2018 academic year will continue to be eligible for student loans and grants—and will be for the duration of their course”.26

Financial consequences of changes in EU student fees

The University of Oxford explained that “At the moment, students from the EU pay the same fees as ‘home’ students. It has been suggested that a positive outcome of a UK withdrawal from the EU will be the charging of international student fees to EU students, thus giving UK Universities a huge boost in fee income. In theory, this sounds like an excellent proposition. However, those who deal with student recruitment believe that, in reality, there will be a huge drop in numbers from the EU as students chose to study at one of the many excellent universities in mainland Europe. The result would actually be a huge drop in fee income (as well as the loss of some excellent students). There is strong feeling that if EU fees are raised to the level of overseas students there will be a knock-on effect on the make-up of the students we see applying, as UK courses become exponentially more unaffordable (especially compared to other EU providers)”.27

The University of Liverpool provided some figures on the possible financial consequences: “Projections based on no new EU students coming to Liverpool show the loss in fee income in 2016/17 would be around £2.5M, rising to £6.2M in 2018/19. If only 50% of students currently forecast came there would be a potential loss of over £3M”.28

Universities UK called for the Government to produce “an international student strategy, backed by investment to support international marketing, mobility and partnerships in both Europe and across the world including a quantitative target to increase international student recruitment”.29

Access to ERASMUS exchange programmes

Loughborough University wrote that “Studying abroad and ERASMUS exchanges are life-shaping events for young people, preparing them for careers working across nations and cultures. Their careers will deliver economic prosperity to the UK. Exclusion from programmes would be hugely to our detriment and will not be replaced on anything like the same scale by piecemeal opportunities around the world”.30

Loughborough University went on to provide figures: “Student mobility is clearly a very significant EU achievement. At Loughborough some 600 students are EU (non-UK) nationals. Their fee income amounts to £5M and they spend similar sums in the local economy. They enrich our community immeasurably, as do our exchange students. 170 students/year come to Loughborough on ERASMUS exchange and we send the same number out, 2/3 to study and 1/3 to work. As an indication of the success of ERASMUS, we can compare with exchanges with the rest of the world which serve as an indicator of likely levels of activity in a UK outside the EU. Despite the attractions of major English-speaking nations, the absence of formal programmes results in a much smaller activity, about 20 students in and 20 out. Exchanges are life-shaping events for these young people, preparing them for careers working across nations and cultures that will deliver economic prosperity to the UK. Exclusion from programmes would be hugely to our detriment and would not be replaced on anything like the same scale by piecemeal opportunities around the world”.31

The Russell Group said that “The Erasmus programme has also benefited UK and EU students and universities for many years. Over 15,000 students from UK universities took part in the Erasmus+ programme in 2013/14, nearly half of whom were from Russell Group universities. The programme provides an experience that is valuable to those individuals and to employers who want graduates with experience of other cultures and language skills. The Government has confirmed the referendum result does not affect beneficiaries of Erasmus+ or those considering applying in 2017 but there is currently no clarity beyond that. We hope the Government will negotiate for the UK to have continued access to the Erasmus+ programme beyond 2017”.32

The Education Committee is holding its own inquiry into the implications of Brexit for Higher Education, which will include the UK’s participation in the ERASMUS scheme.33

Visas for short visits

The MRC Laboratory of Molecular Biology in Cambridge told us that “short-term working visits and internships are the lifeblood of scientific collaboration and information transfer”, but that current immigration rules make it “extremely difficult” to host such visits from non-EU citizens. The laboratory was concerned that similar restrictions could apply to visits from EU citizens after Brexit, noting that such visits “do not lead to immigration nor compete for jobs, so their restriction serves little obvious purpose”.34

19 Dr Julian Downward (LEA 187)

20 University of Oxford (LEA 184)

21 The Society for the Environment (LEA 192) para 2.2

22 University of Cambridge (LEA 42)

23 Babraham Institute (LEA 124) para 2.2

24 Universities UK (LEA 275)

25 Russell Group (LEA 180) para 3.3

26 “Funding support for EU students”, Department for Education press release, 11 October 2016

27 University of Oxford (LEA 184)

28 University of Liverpool (LEA 222) para 6

29 Universities UK (LEA 275) para 18

30 Loughborough University (LEA 109) p1

31 Loughborough University (LEA 109) para 2.4

32 Russell Group (LEA 180) para 3.6

33 “The impact of exiting the European Union on higher education”, Education Committee, accessed 4 November 2016

34 MRC Laboratory of Molecular Biology, Cambridge (LEA 74) para 4

Table 3: Collaboration

Issue

Description and written evidence reference

Notes

Collaboration requires dedicated funding

The Royal Society observed that collaboration was dependent on funding, and that: “Leaving the EU will not create spare capacity for collaboration elsewhere unless supporting funds are identified, ring-fenced and made available. If the UK wishes to increase global collaboration then it must increase the funding and support to make it possible, ideally encouraging collaborations both in Europe and further afield.35

Some research is only possible through collaboration

International collaboration is important for conducting studies that require large populations, such as clinical trials of medicines for rare diseases.36 The Royal Society of Biology told us that: “Research on cancer, mental health, imaging, neurodegenerative disease, tissue engineering, bioinformatics, and conservation among others will be heavily and negatively affected if the UK is unable to maintain involvement in centralized EU-wide initiatives. By their nature these research efforts require, for example, large patient pools, or distributed ecosystems, or infrastructure that is beyond the scope of any individual country. Many specialisms, for example endocrinology, cover rare diseases requiring a large population from which to draw viable study cohorts. Similarly, capacity to conduct studies on trans-national boundary infectious diseases (clinical and veterinary) is essential for research as well as disease control and public health. International collaboration and outlook is key.37

Loughborough University emphasised the need for recognition that “participation in EU research projects is about much more than access to another research funding stream”.38 The university provided case studies of projects that could not be delivered by UK partners alone, even with equivalent levels of funding, and explained that: “The collaborations across EU states enable projects to happen where teams with the required skills cannot be assembled within single nations, as well as where climatic, cultural and behavioural differences are fundamental to the motivation for, delivery of and ultimately the success of the project.39

Similarly, the Marine Biological Association explained that “Sophisticated Research Vessels, such as the new RRS Sir David Attenborough, can still only operate in one location at any given time so that no one nation can afford to conduct research across the global oceans on their own. With the threats to the seas, through climate warming, acidification and pollution, international collaboration in marine science is essential”.40

There are many EU structures for promoting collaboration

RCUK explained that: “JPIs, ERA-Nets and CSAs foster and support international collaboration at a strategic and research level, reducing fragmentation and adding value to national investment:

–Joint Programming Initiatives (JPIs) pool and align national research efforts to more effectively tackle common European challenges, many of which have a wider global impact. There are ten JPIs in key areas such as neurodegenerative disease, cultural heritage, antimicrobial resistance and climate change.

–European Research Area Networks (ERA-NETs) strengthen co-ordination of national and regional research programmes by providing a framework to develop joint activities and support joint calls for transnational proposals. The Research Councils support UK involvement in around twenty such platforms, aligning with areas of key national interest such as diet and health, synthetic biology and urban futures and often receiving additional EU funding for particular activities.

–Coordination and Support Actions (CSAs) support coordination and networking–including workshops, development of collaborative activities and knowledge exchange -particularly where relationships are new and emerging”.41

A new research funding stream for collaboration is needed

Researchers at Swansea University suggested that “The UK should provide some funding, with a low administrative hurdle, to researchers with proven and pre-existing European networks who are already or about to start developing collaborative bids. This would dissuade other EU partners from dropping UK universities from projects and provide a strong signal that UK research will continue to be outward looking”.42

35 Royal Society of Biology (LEA 225) para 3

36 Academy of Medical Sciences (LEA 265)

37 Royal Society of Biology (LEA 225) para 2

38 Loughborough University (LEA 109) para 2.8

39 Loughborough University (LEA 109) para 2.8 ff

40 Marine Biological Association (LEA 278) para 5

41 Research Councils UK (LEA 235)

42 IMPACKT, Swansea University (LEA 138) para 12

Table 4: Regulation

Issue

Description and written evidence references

Notes

Regulations relevant to science and research requiring review, and the process for this

The Babraham Institute told us that: “A substantial amount of work will be needed to review science and technology-related legislation, regulations and projects. Areas to be covered will include: health & safety, employment laws, IP, commercialisation and technology transfer practices, and animal research regulations.43

Universities UK provided a substantial list of regulations relevant to science and research that will need to be reviewed,44 and the Institute of Physics and Engineering in Medicine highlighted others specific to medical physics and clinical engineering.45 The Institution for Environmental Sciences listed several regulations relevant to environmental research.46

Jo Johnson told us that:

“We need to look at what kind of relationship we are going to have to the rest of the European Union before we can give a clear picture about the regulatory systems we will continue and those that we might be able to change and adapt. They will all form part of a very detailed piece of work, which will be undertaken within the Department and across Government over the weeks and months to come”.

Specific regulations: Clinical trials

Many organisations highlighted the Clinical trials directive as relevant to science and research. The British Pharmaceutical Society explained that “New EU Clinical Trials Regulations are set to come into force by the end of 2018. These regulations are meant to harmonise procedures for assessing clinical trials applications, as well as enhancing collaboration between ethics committees, streamlining safety-reporting procedures and increasing transparency surrounding the outcome of clinical trials. These regulations will create a centralised gateway for clinical trial applications. However, Brexit means that UK patients will be left out of this new system, leaving EU patients ahead in accessing the latest innovative clinical research. The likely impact on the UK of not being involved in these new regulations is thought to be major and needs to be carefully assessed”.47

UCL wrote that “If the UK leaves the EU, there will be significant implications for medical research involving clinical trials or use of human samples which have obtained ethical and patient consents. This will affect both ongoing research projects, where consent was given under a previous regulatory regime, and future research projects, which will have to comply with multiple sets of regulation. This poses a currently overlooked but highly significant risk to the undertaking of medical research and could affect the UK’s pre-eminence in this field. Pharmaceutical research will also be affected both in terms of prospects for investment (the UK alone is less attractive than the UK as gateway to the EU market) and because of the consequences of regulatory divergence for drug development (the UK becomes a less attractive place to develop drugs for the EU market) […] It is likely that ongoing clinical projects will either have to re-seek consent or abandon some or all of their previous work. UK researchers will find it increasingly difficult to collaborate with EU partners in future if their involvement necessitates compliance with two different regulatory regimes.48

Specific regulations: Data protection

The Wellcome Trust Sanger Institute told us that “The UK was recently instrumental in the negotiation of the new Data Protection Regulation, with UK science being strongly represented. The question has now arisen of whether the UK will adopt this legislation and the government can and should make a decision on this as soon as possible. The ability of UK science to generate, collect, process and share data is vital especially given the national drive towards “big data science” and establishing legislation compatible with EU legislation is vital”.49

Open Data Institute also raised data regulation issues: “The EU is implementing the General Data Protection Regulation, which requires personal data be managed in countries with similar standards of privacy rules. The EU is also developing the Free Flow of Data initiative to regulate flows of data within the EU. The UK may leave the EU without an agreement for data flows and personal data management. [A consequence could be that] UK researchers may lose access to data about EU citizens, due to incompatible data regulations. Certain types of research may be hampered (longitudinal studies into health, for example)”.50

Specific regulations: Toxicology

The British Toxicology Society wrote that “An example of an EU regulation that has wide-ranging implications for the UK following withdrawal from the EU is REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). UK exporters to the EU of products ranging from bulk chemicals and cars to cleaning products, will still need to abide by REACH. Under REACH, an Only Representative (OR) is a legal entity responsible for the chemicals to be registered or pre-registered. All non-EU importers must appoint an OR. Currently an OR needs to be in the European Economic Area (EEA) in order to make a REACH registration. Without a negotiated change to the current regulation, following the UK withdrawal from the EU many small companies will no longer be able to be responsible for their own REACH registrations for exports to the EU and consultants who provide this function as a service will no longer be able to do so directly from a UK based company. In the absence of a negotiated arrangement, companies wishing to provide an OR service would need to collaborate with a business within the EEA—an additional overhead”.51

Specific regulations: GM

In our report on EU regulation of the life sciences we concluded that “too often, the precautionary principle has been wilfully misused in the formulation of EU life science policy-making, including and notably for Genetically Modified Organisms”.52 In our current inquiry, the NFU told us that: “Leaving the EU could provide Britain with the opportunity to develop and harness certain technologies, such as biotechnology, that have been hindered by over politicised and unscientific decision-making. […] Being outside of the EU could enable the UK to authorise new crops and traits more quickly, for use in feed, food and for cultivation.53

The Royal Society of Biology wrote that “An important consideration following the UK exit from the EU would be the regulations concerning the use of GMOs in agriculture and the status of genome editing. The current EU approval process is viewed by many scientists as burdensome and dissuading innovation. The UK might have an opportunity to develop its own regulations in this area. However, this would not necessarily lead to adoption or commercial growing of approved GMOs in the UK, because public, political and economic considerations must combine in this decision-making”.54

Similarly, the Agricultural Biotechnology Council (ABC) wrote that “Given the strength of the UK science base, there is now an opportunity to boost this base through the implementation of better regulation. ABC is primarily focused with agricultural biotechnology, and as such is particularly concerned with the regulation of GM crops. As such, ABC believes that the future regulation of GM crops in the UK should be led by scientific evidence and safety assessments should be ‘risk-based’. There is also the prospect of the UK becoming a leader in new technologies, such as Novel Breeding Techniques (NBTs), which can help to overcome some limitations of traditional breeding and enlarge the portfolio of products developed in the UK. Although relatively new, NBTs hold the potential to speed up the conventional breeding process and have the potential to increase the competitiveness of agriculture in the UK. The EU is yet to agree regulations for these technologies, however if the UK were to adopt a science-led approach to regulation, there is an opportunity for the UK to be a leading light in seed research and development (R&D), and for UK farmers to reap the benefits of early access to new tools before their European counterparts”.55

The future of the European Medicines Agency in London and licensing of new treatments

A particular concern raised in written evidence was the feasibility of the UK being able to retain the headquarters of the European Medicines Agency (EMA), and the benefits this brings to UK bioscience and pharmaceutical businesses in dealing with EU regulation and approvals. In our report on the EU regulation of the life-sciences, we highlighted the importance of the close relationship between the EMA and the UK Medicines and Healthcare Products Regulatory Agency (MHRA).56 If the UK, after Brexit, is not a member of the EEA, pharmaceutical companies would need to apply for marketing authorisations separately to the Medicines and Healthcare Products Regulatory Agency (MHRA) for a medicine they wished to supply in the UK.

This issue was the subject of a Westminster Hall debate on 12 October.57

Robin Walker MP (a DExEU Minister) told us that “The implications to medicines licensed through the EMA after the UK’s departure from the EU are being considered as part of the wider assessment of the UK’s regulatory regime. It is too early to speculate at this stage on the future location of the EMA.”58

43 Babraham Institute (LEA 124)

44 Universities UK (LEA 275) annex 2

45 Institute of Physics (LEA 135) para 3.1

46 Institution of Environmental Sciences (LEA 256) para 7.1

47 British Pharmaceutical Society (LEA 272) para 3. See also Cancer Research UK (LEA 224) and others.

48 UCL (LEA 258) paras 24–25

49 Wellcome Trust Sanger Institute (LEA 133) para 19

50 Open Data Institute (LEA 118)

51 British Toxicology Society (LEA 255) para 12

52 Science and Technology Committee, First Report of Session 2016–17, EU regulation of the life sciences, HC 158, para 65

53 National Farmers’ Union (LEA 116)

54 Royal Society of Biology (LEA 225) para 17

55 Agricultural Biotechnology Council (LEA 191)

56 Science and Technology Committee, First Report of Session 2016–17, EU regulation of the life sciences, HC 158, para 28 ff

57 HC Deb, 12 October 2016, cols 116–137WH

58 Q210

Table 5: Innovation, facilities and infrastructure

Issue

Description and references

Notes

The contribution that science and research can make to the industrial strategy

The Campaign for Science and Engineering wrote that “the Industrial Strategy could provide a long-term, ambitious framework and programmes to support collaboration, knowledge exchange and build on the UK’s competitive strength of its science and innovation base”.59

The Royal Academy of Engineering wrote that “Long-term commitment to an Industrial Strategy is one of the most effective ways of encouraging private sector investment in priority sector and technology areas, thus the Prime Minister’s commitment to Industrial Strategy was welcomed by the engineering community. An Industrial Strategy, if deployed successfully, will help the UK to exploit the opportunities and mitigate many of the risks that face the country as a consequence of exiting the EU. The Academy wants to ensure that engineering businesses, large and small, feature strongly in the industrial strategy and can access the talented workforce they need. […] Furthermore, the creation of UK Research and Innovation (UKRI) offers the opportunity for an agile research and innovation system that invests strategically in areas of future growth and brings greater coherence to research and innovation funding.

The Business, Energy and Industrial Strategy Committee is currently holding an inquiry into the Government’s forthcoming industrial strategy.60

Access to EU facilities

Research often needs specialised infrastructure, including equipment and buildings, or less tangible infrastructure such as databases, archives, collections and computing systems. Since such facilities can be expensive, investment in construction and running costs may be provided by multiple countries. Thus, while the ‘headquarters’ of a facility will be in one country, other investor countries in the infrastructure can also gain access. For example, the European Synchrotron Radiation Facility (one of the most powerful x-ray sources in the world) is located in Grenoble, France. It is funded, however, by 21 partner nations, including the UK via the Science and Technology Facilities Council (STFC), who can use the facility. Professor Leyser, representing the Royal Society, also emphasised that UK scientists would “want to continue to make use of the facilities that are outside the UK because that is how science works and that is the most efficient way to do science. We do not want a situation where we are duplicating facilities because we no longer have access to existing facilities”.61

Gareth Davies from BEIS emphasised the complexity of the nature of the scientific community’s relationship with Europe:

“Some of the relationships are obviously formal and through the European Union. Others are multilateral and predate our relationship with Europe. As you work through the individual research institutions, it is very important to discriminate between those different types. There is CERN on the one hand, and JET and ITER, on nuclear fusion. There is work on European spallation centres and SKA in Manchester. They all have different legal bases and different ways of participation. A very complex and variable geometry sits behind these relationships”.62

Participation in space projects

Several organisations highlighted the UK’s ability to participate in space and satellite projects that will provide national infrastructure. The Satellite Applications Catapult told us that “the EU has more recently been increasing the role it plays in European space programmes, especially those which have an application focus, and hence are important to the UK. This includes taking leadership of programmes like Galileo [satellite navigation programme] and Copernicus [earth monitoring programme], in both of which the UK has strong industrial interest […] The UK satellite applications sector needs to retain access to Copernicus and Galileo to drive economic growth through the exploitation of these and other data sources. The current EU data and information policy means that users have free, full and open access to the data from these programmes. It is important that this continues. Defra, as the UK lead for the Copernicus programme, should work to ensure its future access and ideally influence in this programme. There are a number of operational contracts that are being, or are due to be, tendered for these programmes, the UK Government should ensure that UK companies have fair access to these contracts during the exit negotiations, to ensure the benefits of past investments”.63

Hosting EU facilities in the UK

The House of Lords Science and Technology Committee highlighted in its report that the UK hosts the headquarters of five pan-European research facilities: the European Life-science Infrastructure for Biological Information (ELIXIR) in Cambridgeshire, the Integrated Structural Biology Infrastructure (INSTRUCT) in Oxford, the Infrastructure for Systems Biology-Europe (ISBE) in London, the Square Kilometre Array at Jodrell Bank, and the European Social Survey (ESS ERIC) in London.64

Professor Philip Nelson of Research Councils UK highlighted their importance: “They are important activities. Several of them are around biology. We have the European Social Survey, for example, at City University in London. That is a very important enterprise, which has over 90,000 registered users worldwide using social survey data. It is critically important that we stay involved in that. There will be an awful lot of technical detail to be worked through and unravelled in the negotiation process, and in the way these things are structured—again emphasising the complexity—it will be important that we have a strong voice at the table to try to ensure that we can stay very much part of these things”.65

We received written evidence from the European Social Survey (a European Infrastructure Consortium, (ERIC)),66 ELIXIR,67 and others, highlighting the specifics of their circumstances. For instance, the ESS notes that “Arrangements have been made for Norway to host an ERIC, suggesting that Associated Members status would allow the UK to continue hosting the ESS ERIC. However arrangements which lead to the legal exclusion of the UK from the European Research Area—and in particular from access to future framework programme funding—would have far reaching ramifications for the ability of the UK to act as a host country for any ERIC including the ESS”.

59 Campaign for Science and Engineering (LEA 267)

60 “Industrial strategy inquiry”, Business, Energy and Industrial Strategy Committee, accessed 10 November 2016

61 Q76

62 Q206

63 Satellite Applications Catapult (LEA 93). Space programmes such as Galileo and Copernicus were also highlighted by the European Space Agency (LEA 105), ADS Group (LEA 221), Airbus (LEA 168),

64 House of Lords, EU membership and UK science, Second report of the Science and Technology Committee, Session 2015–16, HL Paper 127, para 180

65 Q112

66 European Social Survey (LEA 5)

67 ELIXIR (LEA 231)



17 November 2016