The United Kingdom is an important economic partner for Switzerland. Until 1 January 2021, relations between Switzerland and the United Kingdom were predominantly governed by the bilateral agreements with the European Union (EU).
In order to ensure that the mutual rights and obligations in Switzerland’s relationship with the United Kingdom continue to apply as far as possible beyond the UK's withdrawal from the EU (Brexit), 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 came into force on 1 January 2021.
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). As there is no harmonisation between the UK and the EU, these agreements could not be fully replicated.
