Brexit - Regulations & Standards

Transition Period

During the transition period (also known as the implementation period), employers would expect to face ‘business as usual’ arrangements with respect to UK and EU regulations. All existing structures will continue to apply, including jurisdiction of the European Court of Justice.

With respect to product testing, there will be a continued transfer of information between UK and EU bodies. If a manufacturer applies for a new certificate in the EU, having already obtained a certificate in the UK, the information will be transferred to the EU testing body before the end of the transition period.

On standards, the withdrawal agreement includes ‘non-regression clauses’ to prevent the UK from bringing in lower standards on environmental, labour, and social regulations. EU state aid rules will also continue to apply


If the ‘backstop arrangement’ comes into force, Northern Ireland will remain aligned to a number of EU rules that are required to avoid a hard border and there are a number of changes expected for businesses.

Products originating in Northern Ireland that are sold in to Great Britain will need a UK origin label. However, products originating in Northern Ireland that are sold into the EU will need a different label: “UK(NI)”. No EU approval process will be needed to place NI goods onto the UK market and both EU and UK approvals will be recognised for goods sold throughout the UK. State aid rules will continue to apply.

Post Transition / Backstop

Post-transition or backstop arrangement, the political declaration between the UK and EU expects the creation of a free trade area with deep regulatory alignment. Alignment on standardisation, accreditation, labelling, intellectual property, and conformity assessment is expected to go beyond WTO agreements. The UK and EU will explore the possibility of UK cooperation within a range of EU regulatory agencies. However, beyond these commitments, the political declaration does not contain detail on the specifics of future regulatory or standards cooperation.

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