Share This Story

Transition – Licences & Certification

Status Changes

At the end of transition the UK stops being a member of EU so the EU and UK become different territories, with different rules and agreements.  Also, EU agreements with other countries cease to apply to UK.

UK government has already introduced mutual recognition agreements with many states, to replace some EU agreements e.g. Australia & USA, and is working on more.

Some old agreements still stand from before the UK joined the EU and may come back into force e.g. double taxation agreements

Special agreements have been put in place for Northern Ireland (NI) – the Northern Ireland Protocol

For current status see


As a member of the EU, the UK was recognised and had to recognise other EU qualification, certifications etc.

What qualifications do you and your staff hold?  Are they now valid where they/you are or are working?

The UK government has put in place rules to continue to recognise EU qualifications, for people already in the UK, but what about secondments?

Mutual recognition of qualification and certifications forms a part of many agreements.


After Transition, there will be separate UK & EU certification.  So, first question – where are your products certified – is this EU or UK?  Next, do they need re-certifying in the other jurisdiction?  Your customers may be able to help with this.

Also, which territories do your current certifications & labelling authorise you to sell to?  Will this change?  Specifically, an EU address is required on labels when selling food in EU, and UK is no longer a member, so a UK address is insufficient.

There were also special rules within the EU as regards country of origin declarations.  Now that UK is no longer a member of EU then how do the new rules apply?

Has the origin changed? Do you need re-assessment of products, and new labelling?

Will this relabelling have any effect on sales to other countries?

Are new certifications required to continue to trade in other territories too.

Finally, there is the redesign of labels and relabelling of products for these different territories.

Branding & Trademarks

Trademarks are licenced, and brands registered in a jurisdiction.  What do you own and where?  You may no longer be registered where you thought, so what are the implications – re-registering, or arranging new licences?

Additionally, there may be withholding taxes if royalties or dividends etc are paid cross border.

Business Licences & Agreements

Where are you licenced to sell – does the agreement say EU or Europe – is UK still included?

What about Data, UK has not yet been given adequacy to deal with EU data so what procedures have you in place to identify and deal with this?

Do you need to register for VAT in the EU after Transition?

What about agreements with customers & suppliers? – what law is applicable?

For more information see our other blogs in this series

  1. What is Brexit Transition
  2. Identity
  3. Staff
  4. Exports
  5. Imports
  6. Services
  7. Actions & Costs

Or Visit HMRC

Related Posts