GEN – 1097.00. The guidance notes from the EU are still those published in 2019. Meanwhile, the negotiations between the United Kingdom and the EU started in February. The United Kingdom has meanwhile withdrawn some of its guidance notes and replaced these with updates referring the documents released by the EU.

UK guidance documents withdrawn

The UK guidance on trading goods regulated under the new approach if there is no Brexit deal has been withdrawn on 13 March 2020. The UK guidance on placing manufactured goods on the UK market after Brexit was withdrawn on 30 January 2020.

The UK now refers on its website to its guidance on CE marking from October 2012 and the EU guidance of the UK withdrawal of 24 January 2020.

EU guidance notes

These guidance notes remain as before.

Transition

The UK government website now contains three documents referring to the transition:

• Future Relationship with the European Union (22 February)
• Confirmation plans to introduce import controls (10 February)
• The initial statement regarding the UK approach to the negotiations with the EU (2 February)

The 2 and 22 February documents provides the general UK outline towards a Comprehensive Free Trade Agreement (CFTA). The UK proposes to reach with similar provisions as in the EU-Canada Comprehensive Economic and Trade Agreement (CETA) or the EU-Japan partnership agreement. These documents remain general (and thus vague).

The statement on import controls mentions that business can prepare for border controls by making sure they have an Economic Operator Registration and Identification (EORI) number and how business would wish to make the customs declarations; The EORI-website has recently been updated with a guidance and electronic application form.

As a separate note, the UK will introduce legislation that will continue with the phase-down for F-Gases. UK draft legislation was published at the end of January was updated in October.

Outlook

It is not possible to forecast how the negotiations will evolve. The UK Prime Minister had indicated he might terminate the negotiations at the end of June, if insufficient progress is made. In that case the ‘no deal’ scenario would apply.

Recommended Actions

Companies manufacturing in the UK or trading with the UK are advised to check if they would already have registered as an economic operator.

Related documents and links

All related documents and articles can be found in the respective sections in the right sidebar.

• EORI: https://www.gov.uk/eori
• Placing goods on UK market: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-uk-market-if-theres-no-brexit-deal#new-approach-goods
• Placing UK goods on EU market: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-internal-market-if-theres-no-deal#new-approach-goods
• Transition: https://www.gov.uk/transition
• Draft UK F-Gas legislation: http://www.legislation.gov.uk/ukdsi/2019/9780111180433/contents
• EU guidance and notes on Brexit (latest 22 November): https://ec.europa.eu/taxation_customs/uk_withdrawal_en
• EU Brexit preparedness: https://ec.europa.eu/info/brexit/brexit-preparedness_en
• GEN – 1077.00 – Previous update on Brexit