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Uncertainty still remains concerning the final outcome of the negotiations between the EU and the UK.  All Irish businesses are being advised to complete all required administrative actions, before the day the UK officially ceases being a Member State of the EU.

It is likely that the EU single market and customs union checks post-Brexit could include:

  • customs declarations
  • declarations of origin
  • sanitary and phytosanitary checks
  • checks on product compliance

It is feasible that impacts will be felt in the following areas:

Regulations and Standards

If your organisation relies on certificates, licenses or authorisations issued by UK authorities or by bodies based in the UK – or held by someone established in the UK – these may no longer be valid in the EU post-Brexit. You may need to transfer or seek new ones issued by an EU27-based body or authority.

This will apply to certificates, licenses and authorisations issued for good and services.  Sectors include the construction, automotive and the medical devices sector.  It is advised that you take all the necessary steps to transfer or obtain new certificates, licences or authorisations issued in the UK to a Notified Body in the EU27.

To protect health and safety and the environment, EU rules restrict the import/export of certain goods to and from third countries – for example, live animals, products of animal origin, and some plants and plant products, such as wood packaging. Imports/exports of certain commodities are subject to specific permits or notifications. Post-Brexit, goods destined to or coming from the UK will be subject to these EU rules. You should take the necessary steps to ensure compliance with the EU’s import/export prohibitions and restrictions.

Supply Chain and Logistics

EU law stipulates that businesses have specific responsibilities in accordance to where they are situated in the supply chain (e.g. manufacturer, importer, wholesale distributor, etc.).

Customs, VAT and Tariffs

With the UK becoming a third country, trade will become more complicated for customs and VAT procedures. If you trade with companies in the UK, you should get acquainted with the EU procedures and rules that will apply post-Brexit.

For tariffs, when exporting products to third countries with which the EU has a Free Trade Agreement, exporters may enjoy a preferential tariff rate if the products have enough according to rules of origin. Post-Brexit, you can no longer count on UK input to the finished product being considered as EU content. You should therefore examine your supply chains and start treating any UK input as “non-originating”, in order to ensure EU preferential origin for your goods.

Mutual Recognition Agreements

Mutual Recognition is the principle that a product lawfully marketed in one Member State and not subject to Community harmonization should be allowed to be marketed in any other Member State.

Mutual Recognition Agreements (MRAs) are bilateral agreements that establish conditions whereby a non-EU Member State and the EU accept each other’s conformity assessment results (e.g. testing or certification) that demonstrate compliance with the established requirements.

The main objective of MRAs is to promote trade in goods between the European Union and third countries and facilitate market access.

The EU has Mutual Recognition Agreements (MRAs) with several third countries who are recognised as key trading partners to the EU.

  • Australia
  • Canada
  • Israel
  • Japan
  • New Zealand
  • Switzerland
  • USA

European companies that wish to export to Australia, Canada, Japan, New Zealand, the USA, Israel or Switzerland need to know about MRAs and the designated Conformity Assessment Bodies (CABs).