The UK’s withdrawal from the EU (Brexit)

The United Kingdom is an important economic partner for Switzerland. At present, relations between Switzerland and the United Kingdom are predominantly governed by the bilateral agreements with the European Union (EU). Under the withdrawal agreement concluded between the UK and the EU, there is a transition period lasting from the withdrawal date until at least 31 December 2020. During this transition phase, the UK will remain part of the European single market and customs union. The terms of the bilateral agreements between Switzerland and the EU will still apply to relations between Switzerland and the UK.

In order to ensure that the existing mutual rights and obligations in Switzerland’s relationship with the United Kingdom continue to apply as far as possible beyond this transition period, and to create a basis for expanding relations in future, Switzerland has concluded agreements with the United Kingdom in certain areas, including trade. The trade agreement will become applicable as soon as the bilateral agreements between Switzerland and the EU are no longer effective to the relation between Switzerland and the UK.

The trade agreement replicates the vast majority of the trade-related rights and obligations that apply under the bilateral agreements between Switzerland and the EU. These include the Free Trade Agreement, the Agreement on Public Procurement, the Agreement on the Fight against Fraud, the Agreement on Mutual Recognition in relation to Conformity Assessment, the Agricultural Agreement and the Agreement on Customs Facilitation and Security. Some of these agreements between Switzerland and the EU focus (to varying extents) on the harmonisation or recognition of equivalence of rules between Switzerland and the EU (Agreement on Customs Facilitation and Security, certain sections of the Agricultural Agreement including the ‘Veterinary Agreement’ Annex, and certain sections of the Agreement on Mutual Recognition in relation to Conformity Assessment) and cannot be fully replicated at this stage.

Besides the trade agreement, Switzerland has concluded, in the context of its ‘mind the gap’ strategy, agreements with the UK on air traffic, insurance, transport and citizens’ rights, coordination of social security schemes. There is also a temporary agreement between the two countries to safeguard access to their respective labour markets. More information can be found here:

Switzerland–UK relations post Brexit.

Texts of the agreements signed between Switzerland and the United Kingdom on 11 February 2019

Dispatch on the agreements signed between Switzerland and the United Kingdom on 11 February 2019

Text of the Memorandum of Understanding signed between the SECO and the Department for International Trade

Last modification 31.01.2020

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