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.
Trade in goods
Will trade in goods between Switzerland and the United Kingdom (UK) continue to be duty-free?
What tariffs apply to the import of products originating in the UK to Switzerland?
What tariffs apply to the import of products originating in Switzerland to the UK?
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.
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.
See also: Swiss Federal Customs Administration circular on Brexit (in German)
Please direct any further questions regarding customs and import formalities to the UK customs authorities’ enquiry team.
Rules of origin / cumulation
What types of cumulation are provided for under the Switzerland-UK trade agreement?
Is diagonal cumulation EU-Switzerland-UK still possible?
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?
Does a product retain its preferential origin for export from Switzerland into the UK if cumulation with Turkish input material was applied?
Can a company still produce goods in Western Balkan countries and export them duty-free to the UK using cumulation?
Does a product retain its preferential origin when imported from Switzerland into the EU if cumulation with UK input material was applied?
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 from the Federal Customs Administration and the factsheet on Brexit - cumulation (in German).
Information on the UK’s free trade agreements with the parties to the PEM Convention can be found here.
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).
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.
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).
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.
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.
Customs procedure
What is the point of contact for customs clearance procedures in the UK?
What is the situation with mutual recognition of the Authorized Economic Operator (AEO) between Switzerland and the UK?
How do I submit an import declaration in the UK?
Is an Entry Summary Declaration required when importing goods from the UK into Switzerland?
Is an Entry Summary Declaration required when importing goods from Switzerland into the UK?
Will the current active EORI (Economic Operator Registration and Identification) number in the UK still be valid?
The contact details of the UK customs authorities’ enquiry team can be found here.
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.
Information on the UK’s import customs procedure can be found here.
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.
Please contact the UK customs authorities’ enquiries team. Information on the Entry Summary Declaration can be found here.
Information on EORI numbers can be found in the Border Operating Model (section 3.1.5).
Manufactured goods – regulatory requirements
What measures has the UK announced to simplify trade?
What measures has Switzerland adopted to facilitate the import of industrial products into Switzerland?
How can I check whether a given product falls within a product domain of the Switzerland-UK Mutual Recognition Agreement?
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)?
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.
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 2025. The 9 product sectors are no. 1-3, 5, 6 (partial) 8, 13, 17, 19 in the Switzerland-EU Mutual Recognition Agreement (MRA). Further information on the unilateral measure can be found under this link. A further extension is examined annually.
Yes. UK rules apply from 1 January 2021.
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.
Products of animal and plant origin
What is the process for exporting goods of animal origin from Switzerland to the UK?
What is the process to get a CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) licence?
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: https://www.gov.uk/guidance/importing-animals-animal-products-and-high-risk-food-and-feed-not-of-animal-origin-after-eu-exit#new-notification-process.
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 https://www.blv.admin.ch/blv/en/home/import-und-export/import/importe-artengeschuetzte-tiere-pflanzen.html.
The UK authorities have issued guidance on trading and moving endangered species protected by CITES. See: https://www.gov.uk/guidance/trading-and-moving-endangered-species-protected-by-cites-if-theres-no-withdrawal-deal.
Services and mobility
What do I need to do to provide services in the UK? Do I need a visa?
Can a UK service provider provide services for us? What are the requirements?
- For a limited number of activities such as visits to clients, machinery installation or certain scientific activities, you can come to the UK as a visitor (check eligible activities).
- In order to provide services in one of the sectors covered by the Services Mobility Agreement (SMA, see also factsheet), Swiss residents who are self-employed persons or employees of a Swiss company established in Switzerland, having concluded a contract for the provision of services with a British consumer, benefit from the SMA for the period necessary for such contracts (presence on British soil up to one year). You must:
- obtain a temporary work – international agreeement visa, which serves as a work permit (apply at least three weeks in advance).
- hold a university degree or equivalent qualification, and the qualifications required for the job in question.
- for employees: be employed for at least one year and have three years' experience.
- for self-employed persons: have six years' experience.
For further information please refer to UK visa regulations or contact the UK authorities (British Home Office or British Embassy in Bern).
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:
Notification procedure for short-term work in Switzerland (admin.ch)
Intellectual property
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?
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?
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.
For more information on SPCs and intellectual property in general, see: Intellectual property after 1 January
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.
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.
Last modification 21.03.2024
