So with the UK - EU Free Trade Agreement, what should we be aware of it a post brexit world.
To provide goods to both the UK and the EU markets you must meet both sets of standards and regulations.
As of 1st January 2021, the EU and UK will be two separate regulatory and legal regimes.
This means that all products exported from the EU to the UK will have to comply with UK technical regulations and will be subject to any applicable regulatory compliance checks and controls.
Similarly, all products imported from the UK to the EU will need to comply with EU technical regulations and will be subject to all applicable regulatory compliance obligations, checks and controls.
Nonetheless, the TCA contains several provisions aimed at preventing and addressing unnecessary TBTs. The UK and EU have agreed a definition of international standards that identifies relevant international standard setting bodies.
This will help ensure that both sides’ domestic product standards and technical regulations are based on the same international references to the extent possible, thereby reducing the burden on manufacturers to produce to differing UK and EU standards
In the field of conformity assessment, the parties have agreed to maintain simplified access to each other’s markets through the continued use of self-certification of conformity by the manufacturer where this is currently applied in both the EU and the UK. This covers a very large share of bilateral EU-UK trade
Product conformity assessments: there is no cross-recognition of conformity standards; accordingly, with a few exceptions, products will have to undergo two separate conformity assessment processes in order that they can be validly placed on both the EU and UK markets (although there are simplified arrangements for some sectors – e.g., wine, chemicals, motor vehicles and parts, medicinal products, and organic products).
§ Annex on medicinal products – This provides for mutual recognition of Good Manufacturing Practice (GMP) inspections and certificates, meaning that manufacturing facilities do not need to undergo separate UK and EU inspections.
§ Annex on motor vehicles and equipment and parts thereof – This confirms that the UK and EU will mutually recognise approvals based on UN regulations; establishes dedicated cooperation mechanisms to address regulatory barriers; and provides for information exchange to support activities including market surveillance.
§ Annex on organic products – This provides for an equivalence agreement between the UK and EU which means that products that are certified as organic in one market will be recognised as organic in the other. In addition, there are provisions for effective regulatory cooperation to combat fraud, upholding the integrity of organic food production and control systems, and provision for the collaboration on the future development of organic standards.
§ Annex on trade in wine – This sets out simplified certification, documentation, labelling and packaging requirements for the imports of wine produced by the other party, which will reduce costs for exporters and consumers. There are also provisions to share information and to jointly review the TCA in future with a view to further facilitating trade in wine.
§ Annex on chemicals – This aims to facilitate trade in chemicals, whilst ensuring high levels of environmental and health protection. It provides for cooperation between authorities and includes joint commitments to the comprehensive implementation of international classification and labelling rules, as well as commitments to ongoing cooperation and information exchange.
There will be ‘grace periods’ for goods placed on the UK market, until the 1st January 2022.
Ø e.g., CE marking and for food labelling.
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