Latest No Deal documents cover everything from animal breeding to industrial disinfectant regulation

no deal Brexit(Picture credit Shutterstock)

A further raft of detailed guidance notes on how to prepare for a no deal Brexit has been issued by Whitehall. Anna Tobin examines their contents

The collection of notices on how to prepare for a no deal Brexit continues to grow, although the Government is still working towards a deal with the EU. The full list can be seen here. These are the points most relevant to business:

  • Climate change regulations, emissions trading, ecodesign and energy labelling will be radically affected in the event of no deal.
  • The Mutual Recognition of Professional Qualifications (MRPQ) Directive will no longer apply to the UK and there will be no system of reciprocal recognition of professional qualifications between the remaining EEA states and the UK.
  • As the UK will no longer be an EU Member State, there may be an impact on the extent to which UK consumers are protected when buying goods and services in the remaining Member States.
  • UK-recognised animal-breeding operations involved in the trade and movement of purebred livestock and germinal products will no longer be recognised societies or operations in the EU. A recognised UK breed society or breeding operation will no longer be automatically entitled to enter their pedigree breeding animals into an equivalent breeding book in the EU and will have no right to extend a breeding programme into the EU.
  • For the pesticide industry, the UK will have to establish an independent standalone Plant Protection Products (PPP) regime, and all decision making will be repatriated from the EU to the UK.
  • The UK will have to establish an independent standalone biocidal products regime.
  • Hauliers are asked to consider taking steps to prepare for future permitting and trailer registration requirements, and to ensure drivers have the right documentation.
  • The aviation industry is asked to review potential implications for supply chains and staff with specialist qualifications.
  • The movement of mercury materials, including mercury waste, from the EU to the UK will be classified as exports and, therefore, prohibited under the current EU Regulation.
  • UN sanctions will be implemented in UK domestic law.
  • The UK will not be entitled to use any abbreviation in the health and identification marks on meat, fish and dairy products that imply membership of the EU. The form of the health and identification marks must, therefore, change.
  • The UK will have to establish an independent standalone regulatory framework for the Export and Import of Hazardous Chemicals Regulation (known as the PIC Regulation), so that the UK can continue to meet its international obligations under the Rotterdam Convention. UK-based companies exporting or importing listed chemicals (including to or from EU countries) will need to comply with the requirements of the new UK PIC Regulation.
  • Businesses involved in exporting GM food and animal feed products are advised to establish an entity in the EU or EEA or have a representative that is established in the EU or EEA in order to continue trading in the EU.
  • The corporate reporting regime will be unchanged in many respects; but, certain changes will be necessary to reflect that the UK is no longer a Member State.
  • The UK will leave the Common Fisheries Policy (CFP) and introduce its own fisheries policies.
  • There will be changes to the regulations governing the shipments of waste.
  • The movement of equines to countries within the EU will be subject to EU third country rules. All horses or other equines will need an appropriate ID document and health documentation.
  • Organisations running clinical trials in the UK should consider their supply chains for investigational medicinal products (IMPs) to mitigate against potential border delays.
  • There will be changes to the IT system for pre-notifying the import of high-risk food and feed from outside the EU; changes to the import requirements for high-risk food and feed transiting through the EU from a non-EU country to the UK; and, a new requirement for the pre-notification of the import of high-risk food and feed originating within the EU.
  • EU energy law will no longer apply to the UK, and the UK will no longer play a role in the EU organisations that support the implementation of these laws, such as the Agency for the Cooperation of Energy Regulators (ACER).
  • The UK version of the Geo-Blocking Regulation will cease to have effect in UK law.
  • Only UK licences will be required to export cultural objects from the UK to any destination, and the UK will stop issuing EU licences.
  • The UK will establish an independent standalone chemicals regime for the classifying, labelling and packaging of chemicals.
  • UK international trade in rough diamonds will cease until new KP participation is secured. To prepare for this scenario, traders are being advised to consider making arrangements to have any rough diamonds on consignment or loan to countries in the KP (including the EU) returned before the UK has left the EU to avoid delays until independent participation is secured.

To help prepare your business for no deal, download the Ready for Brexit Brexlist, a comprehensive and continually updated to-do list, designed to make the transition to Brexit as smooth as possible

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