Brexit means that Britain is leaving the EU’s internal market and the harmonised product legislation. Britain will become a so-called third country in relation to the EU, and economic actors trading with the country will thus take on new roles. Distributors in the internal market will be considered importers or manufacturers, and will have new requirements to meet. If they also act under the authority of UK assessment bodies, they will need to rely on bodies from an EU country to continue with their sales in the internal market.
For both British and European industry, the current system of free movement in the internal market is the most efficient. All deviations from this will result in a deterioration of the process. A preference from industry is to attempt to keep the British regulatory framework as similar as possible to the EU regulatory framework in the future, so that industry will not need to manufacture one variant of a product for the EU, and another for Britain. Britain will adopt major parts of EU legislation as national law, which could technically facilitate a continued free movement of goods. However, there are some issues to resolve before a future trade agreement can be possible.
Swedac has also investigated the significance of the fact that Britain, after withdrawal from the EU, continues to be a member of international organisations for accreditation and standardisation. The assessment is that continued membership of these organisations does not in itself mean that the technical product requirements will be maintained. What is of significance is the legislation that will apply in the country after the withdrawal. There is also uncertainty about the possibility of continued membership based on other aspects.
All in all, Swedac concludes that Brexit means major changes for trade. The report highlights the issues that need to be resolved in a withdrawal agreement in order to mitigate the negative consequences of Brexit.