Trade agreement in force since 1 January 2021. Negotiations on a modern and comprehensive free trade agreement (FTA) were concluded in substance on 13 July 2026; the agreement is not yet in force.
The United Kingdom is an important economic partner for Switzerland. Until 1 January 2021, relations between the two countries were largely governed by Switzerland's bilateral agreements with the European Union (EU).
Following the UK's withdrawal from the EU (Brexit), Switzerland took a number of steps to preserve mutual rights and obligations as far as possible and lay the groundwork for a deeper bilateral relationship. These included a trade agreement with the United Kingdom, which entered into force on 1 January 2021.
Information on trade in goods, services and public procurement, as well as answers to frequently asked questions, can be found under the relevant headings below.
Switzerland and the United Kingdom concluded negotiations to upgrade the 2019 Trade Agreement on 13 July 2026.
The two countries are deepening their strategic partnership and reaffirming their commitment to open markets, reliable rules and close economic cooperation at a time of increasing fragmentation and trade policy uncertainty. In doing so, the agreement also contributes to the diversification and resilience of economic relations.
The previous “Mind the Gap” approach ensured the continuity of trade relations following the United Kingdom's withdrawal from the European Union. The new agreement goes well beyond preserving the status quo, placing bilateral economic relations on a comprehensive and modern footing.
The new agreement broadens and modernises the bilateral legal framework, in particular for trade in services, investment, the mobility of service suppliers and digital trade. It also contains provisions on financial services, telecommunications, government procurement, intellectual property, trade and sustainable development, and small and medium-sized enterprises. The agreement thus strengthens legal certainty and predictability for businesses in both countries. On trade in goods, already largely covered under the existing Trade Agreement between Switzerland and the UK, the new agreement safeguards existing preferences and provides for targeted additional improvements.
Switzerland and the United Kingdom launched negotiations to upgrade their trade agreement in May 2023. Following the legal review, the agreement is expected to be signed before the end of 2026. The respective domestic approval procedures will then follow.
The trade agreement that entered into force on 1 January 2021 replicates the majority of trade-related rights and obligations from the bilateral agreements between Switzerland and the EU. These include the Free Trade Agreement, the Agreement on Public Procurement, the Agreement on Combating Fraud, the Mutual Recognition Agreement (MRA) on conformity assessment, the Agricultural Agreement, and the Agreement on Customs Facilitation and Security. Several of these rest on regulatory harmonisation or mutual recognition of equivalence between Switzerland and the EU – namely the Agreement on Customs Facilitation and Security, certain sectors of the Agriculture Agreement (including the Veterinary Agreement annex), and certain sectors of the MRA. As the United Kingdom has not harmonised its regulations with those of the EU, these agreements could not be fully replicated.
Decision No 2/2021 of the Switzerland–UK Trade Joint Committee Amending the Appendix to Annex 1 of the Trade Agreement between the Swiss Confederation and the United Kingdom of Great Britain and Northern Ireland, done at Bern on 11 February 2019
Decision No 2/2021 del comitato misto commerciale Svizzera‒Regno Unito che modifica l’appendice dell’allegato 1 dell’Accordo commerciale tra la Confederazione Svizzera e il Regno Unito di Gran Bretagna e Irlanda del Nord, fatto a Berna l’11 febbraio 2019
In addition to the trade agreement, Switzerland has concluded sectoral agreements with the United Kingdom covering air transport, road transport, insurance, mutual recognition of professional qualifications, recognition of supervisory arrangements for financial services, social security, and a temporary agreement on the mobility of service providers.
Swiss–UK relations post Brexit As of 1 January 2021, Switzerland's relations with the United Kingdom (UK) are governed by new bilateral agreements.
Mobility of service providers
The Services Mobility Agreement (SMA) between Switzerland and the United Kingdom facilitates access for service providers following the end of free movement of persons under the Agreement on the Free Movement of Persons (AFMP) for Switzerland–UK relations as of 1 January 2021.
The SMA governs the entry and temporary residence of service providers in both countries. Switzerland applies the notification procedure for service providers from the United Kingdom for stays of up to 90 days per year. The United Kingdom opens its market to Swiss service providers through sector-specific market access commitments covering posted workers from Swiss companies and self-employed service providers (see sector list below, Annex 2, points 9 and 12). Swiss nationals and permanent residents benefit from additional preferential conditions. Swiss service providers are not subject to an economic needs test in the sectors covered, nor are they required to demonstrate English language proficiency. Service providers from Switzerland may access the UK market for up to 12 months.
A statement from the UK authorities sets out the conditions for market access for service providers from Switzerland.
The SMA preserves Swiss service providers' extensive market access in the United Kingdom for contract-based services provided by natural persons and allows Swiss businesses to continue drawing on short-term services from UK companies at short notice.
Access to the UK market under the SMA is limited to individuals with university‑level or equivalent qualifications, including holders of certain Swiss qualifications (degrees from professional education institutions and advanced federal professional diplomas).
The trade agreement between Switzerland and the United Kingdom carries forward the mutual rights and obligations set out in the bilateral Switzerland–EU agreement on certain aspects of public procurement. The provisions of that agreement, together with those of the WTO Agreement on Government Procurement, have been incorporated into a bilateral agreement between Switzerland and the United Kingdom.
FAQ
Can goods continue to be traded duty‑free between Switzerland and the United Kingdom? What tariff rates apply to imports of goods of UK origin into Switzerland? What tariff rates apply to imports of goods of Swiss origin into the United Kingdom?
The market access provisions of the Switzerland-European Union (EU) free trade agreement and the Switzerland-EU Agreement on Agriculture have been adopted in the Switzerland-UK bilateral trade agreement. This means that existing preferential customs treatment continues to apply in the Switzerland-UK relationship. This includes exemption from duty for manufactured products (originating products listed in HS chapters 25–97, with the exception of individual products listed in customs tariff chapters 35 and 38) and preferential treatment for processed and unprocessed agricultural products.
What tariffs apply to the import of products originating in the UK to Switzerland?
Products originating in the UK according to the terms of the Switzerland-UK trade agreement continue to be given preferential treatment when imported into Switzerland. The tariffs applicable to the import of products originating in the UK are published in the digital customs tariff Tares.
What tariffs apply to the import of products originating in Switzerland to the UK?
Products originating in Switzerland according to the terms of the Switzerland-UK trade agreement continue to be given preferential treatment when imported into the UK. Information on the applicable UK tariffs can be viewed here.
enquiry team Please direct any further questions regarding customs and import formalities to the UK customs authorities
What types of cumulation are provided for under the Switzerland-UK trade agreement?
Protocol No 3 of the trade agreement provides for bilateral Switzerland-UK cumulation. Under certain circumstances, diagonal cumulation is possible with input materials from the EU and other parties to the Regional Convention on Pan-Euro-Mediterranean Preferential Rules of Origin (PEM Convention, SR 0.946.31). For detailed information, please see this circular (PDF in German) from the Federal Customs Administration and the factsheet on Brexit - cumulation (available in German only).
Information on the UK’s free trade agreements with the parties to the PEM Convention can be found here.
Is diagonal cumulation EU-Switzerland-UK still possible?
Swiss exporters can cumulate with input materials from the EU provided these qualify as originating goods within the meaning of the PEM Convention or the transitional rules (revised rules of origin of the PEM Convention) (permeability).
In the case of EU-Switzerland-UK cumulation, is it possible for a Swiss company to send a preferentially traded product from the EU via Switzerland to the UK duty free, or must the product have undergone more than minimum processing in Switzerland?
It is not possible to export to or import from the UK imported goods originating in the EU unchanged with proof of origin. It makes no difference whether these goods are assessed in Switzerland or the UK, or are exported from a customs warehouse. No proof of origin can be issued in Switzerland or the UK in such a case. Input materials from the EU must undergo more than minimal treatment (Article 6 of Protocol 3) in Switzerland or the UK. If goods from the EU are exported from a customs warehouse, the proof of origin must be issued by the original EU exporter.
Does a product retain its preferential origin for export from Switzerland into the UK if cumulation with Turkish input material was applied?
Swiss exporters can cumulate with input materials from Turkey provided these qualify as originating goods within the meaning of the PEM Convention or the transitional rules (revised rules of origin of the PEM Convention) (permeability).
Can a company still produce goods in Western Balkan countries and export them duty-free to the UK using cumulation?
For products originating in the Western Balkan countries to be exported unchanged to the UK, a free trade agreement must first be concluded between the UK and the Western Balkans with identical rules of origin as those in the Switzerland-UK trade agreement. More information can be found in the factsheet on Brexit - cumulation (available in German only).
Does a product retain its preferential origin when imported from Switzerland into the EU if cumulation with UK input material was applied?
No, the UK is considered as a third country for the purposes of the Switzerland-EU free trade agreement and of FTAs with other parties to the PEM Convention. If input material of UK origin is used in production, the list rules of the PEM Convention laid down in the given FTA must be adhered to. Cumulation is not possible.
What is the point of contact for customs clearance procedures in the UK?
The contact details of the UK customs authorities’ enquiry team can be found here.
What is the situation with mutual recognition of the Authorized Economic Operator (AEO) between Switzerland and the UK?
Until the UK and the EU conclude an agreement similar to the Switzerland-EU agreement on customs facilitation and security, the UK leaves the joint security area covering Switzerland, Norway and the EU and has third-country status. Reciprocal recognition of AEO status by Switzerland and the UK is no longer possible for the time being. However, Switzerland and the UK are currently negotiating a bilateral agreement on mutual recognition of AEO status.
Is an Entry Summary Declaration required when importing goods from the UK into Switzerland?
For consignments via land from the UK to Switzerland, like those from other third countries, the EU requires a pre-entry declaration and carries out any security checks required. Since the goods are then already in the joint security area, no further customs security measures are necessary on entry into Switzerland.
For consignments transported by air from the UK to Switzerland, like those from other third countries, a pre-entry declaration will need to be made in advance to the Federal Customs Administration in line with the provisions of the Switzerland-EU agreement on customs facilitation and security. Any security checks required will take place after the arrival of the goods in Switzerland. However, there will be no further security checks if these goods are then sent on from an airport in Switzerland to the EU.
Is an Entry Summary Declaration required when importing goods from Switzerland into the UK?
Please contact the UK customs authorities’ enquiries team. Information on the Entry Summary Declaration can be found here.
Will the current active EORI (Economic Operator Registration and Identification) number in the UK still be valid?
What measures has the UK announced to simplify trade?
Manufactured goods placed on the UK market after 1 January 2021 must meet the requirements of UK legislation. However, in 21 product sectors, the UK continues to recognise the current EU requirements and conformity assessment procedures, including CE marking and the inverted epsilon. The 21 product sectors are listed on the UK government website.
What measures has Switzerland adopted to facilitate the import of industrial products into Switzerland?
In order to protect the trade and supply chains between the UK and Switzerland on the import side and to create a certain degree of continuity, Switzerland has unilaterally enacted the following measure:
Recognition of test reports and conformity assessments: Switzerland recognises test reports and conformity assessments from conformity assessment bodies based in the UK in 9 product sectors until the end of March 2026. The 9 product sectors are no. 1-3, 5, 6 (partial) 8, 13, 17, 19 in the Switzerland-EU Mutual Recognition Agreement (MRA). A further extension is examined annually.
How can I check whether a given product falls within a product domain of the Switzerland-UK Mutual Recognition Agreement?
Switzerland has concluded two MRAs with the UK. You can find more information on these agreements and in particular the product sectors covered under this MRA Switzerland - UK.
For further information on the products covered by the Switzerland-EU Mutual Recognition Agreement, please see MRA Switzerland - EU.
Do Swiss companies need to designate a responsible person for the UK in order to register new products/chemicals?
What are the changes to REACH registration (chemical products)?
The UK Government has published guidance on complying with REACH chemical regulations, which will help to answer any questions businesses and interested parties may have. Further questions regarding the UK legislation should be addressed to the British Embassy in Switzerland or the competent authorities in the UK.
REACH is not covered by Switzerland’s bilateral agreements with the EU, including the Mutual Recognition Agreement.
What is the process for exporting goods of animal origin from Switzerland to the UK?
The UK authorities are responsible for laying down the rules, regulations and import conditions to the UK for animals and products of animal origin from all countries including Switzerland. Exporters should therefore refer to the UK guidance on importing animals, animal products and high-risk food and feed not of animal origin available at:
What is the process to get a CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) licence?
The import into Switzerland of protected species of animals and plants remains unchanged after Brexit. Interested parties can find the relevant information on import procedures on the website of the Federal Food Safety and Veterinary Office:
What do I need to do to provide services in the UK? Do I need a visa?
For a limited number of activities (customer visits, machine installation, certain research activities), entry into the United Kingdom as a visitor is permitted (see the list of permitted activities, available in English only). Persons resident in Switzerland who are self-employed or who, as employees of a Swiss company based in Switzerland, have a service contract with end consumers in the United Kingdom in a sector covered by the Services Mobility Agreement (SMA; Agreement on the Mobility of Service Providers; see download) may provide services in the United Kingdom for the period necessary to fulfil the contract (up to a maximum of one year), provided the following conditions are met: - Visa: A Temporary Work – International Agreement Visa (Temporary Work – International Agreement Visa; serves as a work visa) must have been granted; the application must be submitted at least three weeks in advance. - Education: A higher education qualification (university or university of applied sciences) or equivalent, as well as the necessary professional qualifications. Work experience for employees: at least one year’s employment and three years’ professional experience. Work experience for self-employed persons: six years.
Can a UK service provider provide services for us? What are the requirements?
Yes, under the temporary Services Mobility Agreement (SMA) between Switzerland and the UK, you simply have to notify the authorities when services are provided for up to 90 days per year. Information can be found here:
Patents are granted based on the European Patent Convention (EPC), i.e. independently of EU law. However, EU legislation is the basis for the Supplementary Protection Certificate (SPC), clinical data protection, orphan drugs market exclusivity and the extension of the SPC to paediatric medicinal products. Have these regulations been incorporated into UK legislation?
Since the European Patent Office is not an EU institution, the UK’s exit from the EU has no impact on the current European patent system. Nor are existing European patents covering the UK affected. The UK has stated that relevant EU legislation on SPCs (or its domestic implementation) will be retained in UK law under the EU Withdrawal Act 2018; they will continue to apply after 1 January 2021, as the UK legislation (Patents (Amendment) (EU Exit) Regulations 2019) reflects to a large extent the existing EU SPC Regulation and provides for the same term of protection.
In its guidance Changes to SPC and patent law from 1 January 2021 the UK government states that, in order to obtain an SPC for Great Britain, authorisation for the British market is also required. Patent holders must check whether their marketing authorisation is valid for the whole of the UK or only for Northern Ireland or for Great Britain.
Since 1 January 2019, an SPC waiver for exports has applied in the EU. The UK government intends to maintain this waiver, but with some important changes.
For paediatric renewals, the requirements remain broadly the same. The main difference is that it is no longer necessary to prove that a product has marketing authorisation in all EEA member states; it is sufficient to demonstrate that there is marketing authorisation for the UK. The UK maintains a special regulatory regime for orphan drugs (drugs to treat rare diseases). This regime largely reflects the existing EU system.
UK clinical trials are already managed nationally and UK clinical trial applications will continue to be authorised by the Medicines and Healthcare products Regulatory Agency (MHRA). The UK is not making any changes to the term of data and market exclusivity.
Also excluded from the European Patent Convention (EPC) are trade marks and design rights. Are EUTM & RCD (European trademarks and registered Community designs) still valid in the UK and can they be registered at national level?
The UK government has said that it will ensure that property rights to all existing registered EU trade marks and registered Community designs will continue to be protected and to be enforceable in the UK by providing an equivalent trade mark or design registered in the UK. Rights holders with an existing EU trade mark or registered Community design will automatically acquire a new UK equivalent right. See Guidance: Changes to EU and international designs and trade mark protection from 1 January 2021.
