Switzerland has concluded two MRAs with the United Kingdom of Great Britain and Northern Ireland (UK). One based on harmonised legislation and one that takes into account the regulations of the contracting partner.
MRA for 3 sectors - integrated in the trade agreement
The MRA between Switzerland and the United Kingdom, which is based on harmonised legislation, is an integral part of the "Trade Agreement between Switzerland and the United Kingdom of Great Britain and Northern Ireland" (CH-UK Trade Agreement) (Art. 1 let. d in conjunction with Art. 2 let. b and Annex 3).
It covers three product areas: Motor Vehicles, Good Laboratory Practice (GLP) and Good Manufacturing Practice (GMP) Inspection for Medicinal Products and Batch Certification. These three product areas covered by the MRA Switzerland-EU were incorporated into the trade agreement with the United Kingdom, as the standards underlying the technical regulations were developed within the framework of international organisations of which both Switzerland and the United Kingdom are members. These international organisations are: the UN Economic Commission for Europe for motor vehicles, the OECD Principles for Good Laboratory Practices for good laboratory practice and the Pharmaceutical Inspection Cooperation Scheme (PIC/S) for good manufacturing practice (GMP) inspection. In these three product areas, the agreement replicates the rights and obligations under the Switzerland-EU MRA; these product areas function in the same way in relation to the UK as they do in relation to the EU.
Ambitious traditional MRA for 5 more sectors
The second MRA between Switzerland and the UK is a stand-alone agreement, also called atMRA. This atMRA covers the five product sectors in which a Swiss conformity mark exists: Pressure Equipment, Telecommunications Equipment, Electromagnetic Compatibility (EMC), Measuring Instruments and Noise Emissions from Equipment Used Outdoors.
This atMRA is a traditional MRA. Unlike the MRA mentioned above, it is not based on equivalent legislation: According to the atMRA, Swiss conformity assessment bodies (CABs) test products intended for the UK market according to UK regulations. Conversely, UK CABs test products intended for the Swiss market according to Swiss legislation. At the same time, it is also more ambitious than a traditional MRA. In particular, the provisions on cooperation among the competent authorities go further than in other traditional MRAs, both in the regulatory area and in the area of market surveillance. This was only possible because Switzerland and the UK still have de facto equivalent legislation. This also leads to manufacturing processes with lower costs and facilitates conformity assessment, since the knowledge of the applicable regulations is already available and does not have to be acquired at great expense, as is usually the case.
In order to continue to guarantee this knowledge advantage, the competent authorities will jointly identify and make available to the public any differences in the regulations in the event of future legal changes. If you would like to consult this list of differences, please feel free to ask for it at the e-mail address firstname.lastname@example.org.