News article

Brexit: Placing manufactured goods on the EU internal market if the UK leaves the EU with no deal

4 April 2019


How to comply with regulations on manufactured goods you place on the EU internal market after exit day if there is no deal

What you will need to do after the UK leaves the EU will depend on whether your goods are:

  • regulated under the new approach
  • regulated under the old approach
  • non-harmonised goods subject to national regulation

You should speak to a solicitor if you are unsure which regulatory framework applies to your goods.

New approach goods

Goods are ‘placed on the market’ when they are made available on the market for the first time.

Read the guidance on when placing on the market is considered to take place for manufactured goods on the EU and UK market (PDF, 178KB).

All goods placed on the EU internal market after the UK leaves the EU will need to conform with EU goods regulations.

If you have already placed a good on the market in an EU country, other than the UK, before 12 April 2019 then it can continue circulating after Brexit.

Read more about goods regulated under the new approach.

Non-harmonised goods

In the EU, non-harmonised goods are subject to the ‘mutual recognition principle’. This is the principle of EU law under which EU countries must allow goods that are legally sold in another EU country to be sold in their own territory. After 12 April 2019 the mutual recognition principle will not apply to UK non-harmonised goods placed on the EU internal market.

If you export non-harmonised goods to the EU or EEA after 12 April 2019 you will need to make sure they meet the national requirements of the first EU country they are exported to.

If you have already placed a non-harmonised good on the EU market, which meets the relevant national requirements, you will not need to take any action.

You can find information about different national regulations of non-harmonised goods for EU countries through the product contact points.

Read more about non-harmonised goods subject to national regulation.

Old approach goods

Old approach goods are subject to detailed regulatory requirements and approvals by public bodies. The relevant regulators have produced detailed guidance on goods subject to the old approach so you should check the guidance on:

Read more about goods regulated under the old approach.