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The UK and Switzerland have negotiated a second Mutal Recognition Agreement (MRA), which was signed on 17th November 2022 in London. Further information can be found here.

Under the MRA, UK Conformity Assessment Bodies will be able to apply for recognition in Switzerland and will be able to carry out conformity assessment of certain products against the technical requirements of Switzerland and vice versa.

Previous UK-Swiss Arrangements

Following EU-Exit, UK-Switzerland trade was no longer covered by the EU-Switzerland MRA of 2002. Some of the sectors covered by the EU-Swiss MRA were included in MRA provisions in the 2019 UK-Switzerland trade agreement. UK exports to Switzerland in many of the remaining sectors (13 in total) previously covered by the EU-Swiss MRA continued to be covered via temporary unilateral measures granted by Switzerland. These temporary measures will cease on 31st December 2022, as outlined on the relevant Swiss government website.

With this planned expiry in mind, officials recently concluded technical discussions with Switzerland to bring as many of these sectors as possible into a new MRA.

New UK-Switzerland MRA

This new UK-Switzerland MRA will cover the following sectors:

• Electrical Equipment and Electromagnetic Compatibility
• Measuring instruments and pre-packages
• Radio equipment
• Transportable pressure equipment
• Noise emitting equipment for use outdoors

Subject to Parliamentary approval, the agreement will be applied provisionally from 1st January 2023.

Any products in the sectors listed above which require third-party conformity assessment and which have previously been approved for sale on the Swiss market can still be sold. No action is needed in this case. If new product lines are introduced by businesses operating in these five sectors after 1st January 2023, businesses will be able to use either a UK CAB which has been designated by Switzerland to carry out third-party conformity assessment, or an EU recognised notified body.

This MRA therefore allows manufacturers in these sectors to continue to save time and effort when required to undergo conformity assessment for the importing country. It also builds the foundation for including more sectors in the future, subject to mutual agreement.

CABs based in the UK which are operating in these sectors will be able to begin seeking designation from Switzerland in 2023.

Eight sectors subjected to expiring Swiss temporary measures will remain outside the scope of the MRA. These sectors are:

• Machinery
• Toys
• Personal Protective Equipment
• Gas appliances and boilers
• Equipment and protective systems intended for use in potentially explosive atmospheres (ATEX)
• Agricultural and forestry tractors
• Lifts
• Cableway installations

These sectors are not included in the MRA because Switzerland does not have an independent Swiss conformity assessment mark, and uses the CE mark - or the type approval “e” mark in the case of Agricultural and Forestry Tractors. For this reason, it was not possible to include them in the MRA. After 31st December 2022, goods in these sectors will no longer be covered. 

However, businesses operating in these sectors are unlikely to be affected if the goods which they intend to place on the market in Switzerland: 

• Do not require third party conformity assessment in order to be placed on the market under the rules in the EU and

• Have been conformity assessed by a notified body recognised by the EU. This notified body may be based in the EU,
  Switzerland or in another country with which the EU or Switzerland has an MRA. 

Further information on placing goods on the market in the EU and EFTA countries can be found here

Businesses can access guidance on exporting to Europe, Eastern Europe, and Central Asia from the Export Support Service.

Following the conclusion of the MRA, the UK is now looking to begin negotiating a new enhanced FTA with Switzerland. DIT will provide further detail in due course.

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