COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Getting ready for changes Communication on readiness at the end of the transition period between the European Union and the United Kingdom
Date: 2020-07-09
Institutions: European Commission, UK Task Force
Subjects: United Kingdom, cooperation policy, foreign policy, transitional period (EU), withdrawal from the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 9.7.2020  COM(2020) 324 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Getting ready for changes  Communication on readiness at the end of the transition period  between the European Union and the United Kingdom  
 
 
Getting ready for changes 

Communication on readiness at the end of the transition 
period between the European Union and the United 
Kingdom  

I. 

INTRODUCTION ............................................................................................................................................................................. 3 

II.  CHANGES HAPPENING IN ANY SCENARIO ...................................................................................................................... 5 

A.  Trade in goods ...................................................................................................................................... 6 

A.1. Customs formalities, checks and controls ........................................................................................................... 6 

A.2. Customs and taxation rules for import and export of goods (tariffs, VAT, excise) ...................... 7 

A.3. Certificates and authorisations of products, establishment requirements, labelling and 
marking ............................................................................................................................................................................................. 9 

Examples of sectoral compliance .............................................................................................................................. 10 

B.  Trade in services .............................................................................................................................. 11 

B.1. Financial services ............................................................................................................................................................ 12 

B.2. Transport services .......................................................................................................................................................... 15 

B.3. Audiovisual services ...................................................................................................................................................... 17 

B.4. Recognition of professional qualifications ....................................................................................................... 17 

C.  Energy ................................................................................................................................................... 18 

D.  Travelling and tourism ................................................................................................................... 18 

Checks on persons .............................................................................................................................................................. 18 

Driving licences .................................................................................................................................................................... 19 

Roaming ................................................................................................................................................................................... 20 

Passenger rights .................................................................................................................................................................. 20 

E.  Mobility and social security coordination ............................................................................... 20 

F.  Company law and civil law ........................................................................................................... 21 

F.1. UK-registered companies ........................................................................................................................................... 21 

F.2. Contractual choice of jurisdiction ........................................................................................................................... 22 

G.  Other aspects: Data, digital and intellectual property rights ......................................... 23 

G.1. Intellectual property ...................................................................................................................................................... 23 

G.2. Data transfers and protection ................................................................................................................................. 23 

G.3. .eu domain name ............................................................................................................................................................ 24 

H. 

International agreements of the European Union ............................................................... 25 

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III.  Preparing for any scenario .................................................................................................................................................. 26 

BOX: The Withdrawal Agreement, including the Protocol on Ireland and Northern Ireland ........... 27 

IV. 

Conclusion: Readiness is key ........................................................................................................................................ 30 

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I.  INTRODUCTION  

The United Kingdom of Great Britain and Northern Ireland (‘United Kingdom’ or ‘UK’) left the 
European Union (‘EU’) and the European Atomic Energy Community (‘Euratom’) – hereafter 
referred together as ‘Union’ – on 1 February 2020. The Withdrawal Agreement1 concluded 
between  the  Union  and  the  United  Kingdom  entered  into  force  on that  date,  securing  the 
United  Kingdom’s  orderly  departure,  and  providing  legal  certainty  in  important  areas, 
including citizens’ rights, the financial settlement and avoiding a hard border on the island of 
Ireland (see Box in part III). 

As  a  third  country,  the  United  Kingdom  no  longer  participates  in  the  Union’s  decision-
making.  It  is  not  represented  in  the  EU  institutions,  EU  agencies,  offices  or  other  Union 
bodies. 

However,  in  accordance  with  the  Withdrawal  Agreement,  Union  law  continues  to  apply  to 
and in the United Kingdom2 for a ‘transition period’ lasting until 31 December 2020.3   

During the transition period, the United Kingdom continues to participate in the EU’s Single 
Market  and  Customs  Union,  to  benefit  from  Union  policies  and  programmes,  and  has  to 
continue to abide by the obligations of the international agreements, to which the Union is a 
party. This transition period therefore offers a period of continuity, which the Union is using 
to: 

1.  ensure  that  all  necessary  measures  and  arrangements  for  the  implementation  of  the 

Withdrawal Agreement, as of 1 January 2021, are put in place; 

2.  negotiate an agreement on a new partnership with the United Kingdom, and; 

3.  ensure readiness for the end of the transition period on 1 January 2021, when the United 
Kingdom will no longer participate in the EU’s Single Market and Customs Union, nor in 
Union policies and programmes,4 nor benefit from the Union’s international agreements. 
This choice was confirmed by the United Kingdom’s government in its approach to the 
negotiations  on  the  future  relationship  with  the  European  Union,  published  on  27 
February 2020 as well as in later statements by the UK government.5  

1 Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and 
the European Atomic Energy Community, OJ L 29, 31.1.2020, p. 7 (‘Withdrawal Agreement’). 
2 Subject to certain exceptions provided for in Article 127 of the Withdrawal Agreement, none of which is relevant in the 
context of this Communication. 
3 In line with Article 132(1) of the Withdrawal Agreement, it would have been possible to extend this transition period once, 
by up to one or two years by way of a joint decision by the European Union and United Kingdom before 1 July 2020. The 
United  Kingdom  refused  any  such  decision,  meaning  that,  by  legal  automaticity,  the  transition  period  will  end  on  31 
December 2020. 
4 Except those covered by Article 138 of the Withdrawal Agreement and Political Declaration (Peace Plus). 
5 HM Government, ‘The Future Relationship with the Union: The UK’s Approach to Negotiations’, 27 February 2020. 

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With  regard  to  the  negotiations  on  a  new  partnership  with  the  United  Kingdom,  the 
extraordinary situation resulting from the coronavirus pandemic meant that, apart from the 
first negotiation round, the subsequent three rounds had to be held by videoconference. For 
the  same  reason,  the  time  elapsing  between  the  first  and  second  rounds  was  longer  than 
originally intended.  

Negotiations so far have shown little progress. Discussions have now been intensified over 
the summer, with negotiation rounds and/or specialised sessions scheduled each week since 
29 June 2020. 

The Commission will continue to negotiate based on the mandate given to it by the Council 
in  February  2020  and  supported  by  the  European  Parliament.  The  Commission  services 
published a detailed draft legal text6 in line with this mandate. Our objective is to conclude, 
by  the  end  of  2020,  an  ambitious  partnership  covering  all  areas  agreed  with  the  United 
Kingdom  in the  Political Declaration7.  That  declaration  was  endorsed  by all  EU  leaders  and 
Prime Minister Johnson on 17 October 2019.  

Nonetheless, even if the European Union and the United Kingdom were to conclude, by the 
end of 2020, an ambitious partnership covering all areas agreed in the Political Declaration 
such an agreement would create a relationship which will be very different from the United 
Kingdom’s  participation  in  the  EU  Single  Market8  and  Customs  Union,  and  in  the  VAT  and 
excise duty area.  

Inevitably, the fact that the United Kingdom will no longer participate in Union policies as of 
the  end  of  the  transition  period  will  create  barriers  to  trade  in  goods  and  services  and  to 
cross-border  mobility  and  exchanges  that  do  not  exist  today.  This  will  happen  in  both 
directions,  i.e.  from  the  United  Kingdom  to  the  Union,  as  well  as  from  the  Union  to  the 
United Kingdom. Public administrations, businesses, citizens and stakeholders on both sides 
will be affected and must therefore prepare.  

The  choices  made by the  United  Kingdom’s  government  on  the  future  relationship  and on 
not extending the transition period mean that these inevitable disruptions will occur as of 1 
January 2021 and risk compounding the pressure that businesses are already under due to 
the COVID-19 outbreak.  

6 Draft text of the Agreement on the New Partnership between the European Union and the United Kingdom, published on 
17 March 2020, see: https://ec.europa.eu/info/publications/draft-text-agreement-new-partnership-united-kingdom_en 
7  Revised  text  of  the  Political  Declaration  setting  out  the  framework  for  the  future  relationship  between  the  European 
Union and the United Kingdom as agreed at negotiators’ level on 17 October 2019, OJ C34, 31 January 2020, 1-16. 
8 In particular, a free trade agreement does not provide for internal market concepts (in the area of goods and services) 
such  as  mutual  recognition,  the  ‘country  of  origin  principle’,  and  harmonisation.  With  a  free  trade  agreement  there  are 
customs formalities and controls, including those concerning the origin of goods and their input, as well as prohibitions and 
restrictions for imports and exports. 

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It  is  essential  that  all  stakeholders  be  made  aware  of  this,  and  that  they  ensure  their 
readiness  for  these  broad  and  far-reaching  changes,  which  will  arise  under  any  scenario, 
regardless  of  the  outcome  of  negotiations  between  the  European  Union  and  the  United 
Kingdom.  There  is  no  room  for  complacency  or  postponing  readiness  and  adaptation 
measures  in  anticipation  that  an  agreement  would  ensure  continuity,  because  a  large 
number of changes will be inevitable.  

This  Communication  in  no  way  seeks  to  prejudge  the  outcome  of  negotiations,  nor  to 
examine the possible implications of a failure to reach an agreement on a future partnership. 
Instead, it aims to highlight the main areas of inevitable change and to facilitate readiness 
and  preparations  by  citizens,  public  administrations,  businesses  and  all  other  stakeholders 
for these unavoidable disruptions.  

In  particular,  businesses  should  consider  revisiting  their  existing  preparedness  plans. 
Although these were drawn up for the risk of the UK’s withdrawal from the Union without a 
withdrawal agreement – a scenario which did not materialise – part of that work will still be 
very relevant for the changes at the end of the transition period. 

In this spirit, the Commission is also reviewing all 102 stakeholder notices which it published 
during the phase of withdrawal negotiations, most of which continue to be relevant for the 
end  of  the  transition  period.  So  far,  51  of  these  notices  have  been  updated  to  reflect  the 
changes  that  will  occur  at  the  end  of  the  transition  period,  and  further  updates  will  be 
published soon. A list can be found in Annex I to this Communication. 

II. CHANGES HAPPENING IN ANY SCENARIO 

This  section  provides  an  overview  of  the  main  areas  of  change  that  will  take  place  in  any 
event  as  of  the  end  of  the  transition  period,  whether  there  is  an  agreement  on  a  future 
partnership between the European Union and the United Kingdom or not.  

The changes described here will result automatically from the fact that, as of 1 January 2021, 
the transition period allowing for the temporary participation of the United Kingdom in the 
EU  Single  Market  and  Customs  Union  will  cease,  thereby  putting  an  end  to  the  free 
movement  of  persons,  goods  and  services.  Leaving  the  Single  Market  and  Customs  Union 
will  lead  to  additional  barriers  to  trade  and  to  the  cross-border  mobility  of  people,  and 
adjustments will be necessary both on the side of the Union and of the United Kingdom. By 
leaving  the  Union,  the  United  Kingdom  is  also  leaving  all  Union  international  agreements, 
automatically and by law. 

If  not  yet done, public  administrations, businesses  and  citizens  in  the  Union  must urgently 
take  all  the  necessary  readiness  measures  to  prepare  for  these  changes  with  a  view  to 
minimising the cost of disruptions as much as possible.  

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A.  Trade in goods9  

The  changes  described  in  the  following  sub-sections  will  not  apply  with  respect  to  trade 
between the EU and Northern Ireland, where the Protocol on Ireland and Northern Ireland, 
which  is  an  integral  part  of  the  Withdrawal  Agreement,  will  apply  as  of  the  end  of  the 
transition period, alongside any agreement on a future partnership.10 

In  accordance  with  that  Protocol,  Union  rules  relating  to  goods  (including  fiscal  rules,  i.e. 
indirect  taxation  and  non-fiscal  rules)  and  the  Union  Customs  Code  will  also  continue  to 
apply to and in Northern Ireland (see Box in part III for more information). 

A.1. Customs formalities, checks and controls 

During  the  transition  period,  the  United  Kingdom  is  part  of  the  EU  Single  Market  and 
Customs  Union.  Therefore,  there  are  currently  no  customs  formalities  for  goods  moving 
between the United Kingdom and the Union. 

As of 1 January 2021, the United Kingdom will no longer be part of the EU Customs Union. 
Therefore, customs formalities required under Union law will apply to all goods entering the 
customs territory of the Union from the United Kingdom, or leaving that customs territory to 
the United Kingdom.  

This  will  happen  even  if  an  ambitious  free  trade  area  is  established  with  the  United 
Kingdom, providing for zero tariffs and zero quotas on goods, with customs and regulatory 
cooperation.  

On the EU side, customs authorities will carry out controls on the basis of the Union Customs 
Code, according to the common risk-based system applied to any other external border of 
the  Union  with  regard  to  the  movement  of  goods  in  relations  to  third  countries.  These 
controls  are  likely  to  lead  to  increased  administrative  burdens  for  businesses  and  longer 
delivery times in logistical supply chains. 

As of 1 January 2021, EU businesses wishing to import from or export to the United Kingdom 
will need to ensure they have an Economic Operators Registration and Identification (EORI) 
number11  in  order to  go through  customs  formalities.  In  addition,  EORI  numbers  issued by 
the  United  Kingdom  will  no  longer  be  valid  in  the  Union.  Businesses  based  in  the  United 
Kingdom  wishing  to  import  into  the  Union  will  need  to  receive  an  EU  EORI  number,  or 
appoint  a  Union  customs  representative  where  applicable.  Furthermore,  as  of  1  January 

9 The Withdrawal Agreement enables goods placed on the market before the end of the transition period to continue to be 
further made available on the EU or UK market until they reach their end-user, with no need for re-certification, re-labelling 
or product modifications. 
10 Subject to the consent, four years after the end of the transition period, by the Northern Ireland Legislative Assembly to 
the continued application of the Protocol. 
11 EORI numbers are identification numbers that all businesses and people wishing to trade outside of the EU must use for 
identification  in  all  customs  procedures  and  formalities  and  more  generally  when  exchanging  information  with  customs 
administrations. 

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2021,  Authorised  Economic  Operators  authorisations or other  authorisations  issued  by  the 
United Kingdom will cease to be valid in the Union. Where the economic operators wish to 
obtain EU authorisations, they need to apply for them in an EU Member State. 

Advice to businesses and Member State administrations 

EU  businesses  must  acquaint  themselves  with  the  formalities  and  procedures  for  doing 
business with the United Kingdom as a third country as of 1 January 2021. They should also 
factor in the increased administrative obligations and potentially longer timeframes resulting 
from  these  formalities  and  procedures.  This  might  entail  significant  changes  to  the 
organisation  of  existing  supply  chains.  Businesses  are  responsible  for  assessing  the  actions 
needed in view of these changes, in light of their individual situation. 

The  administrations  of  EU  Member  States  have prepared the  major  border  passage points 
and  developed  solutions  to  ensure  the  application  of  the  Union  Customs  Code  in  this 
context.  Where  necessary,  they  should  continue  implementing  and  refining  those  options, 
and pursue their efforts to raise awareness among businesses, targeting small and medium-
sized enterprises (SMEs) in particular.12 

A.2. Customs and taxation rules for import and export of goods (tariffs, VAT, excise) 

During the transition period, the United Kingdom is part of the EU Customs Union and part 
of the EU’s VAT and excise territory.  

Therefore,  no  tariffs  or  quotas  are  applied  on  goods  traded  between  the  European  Union 
and the United Kingdom, and there is no need to demonstrate the origin of goods traded.  

Furthermore, the regime applied for taxes (VAT, excise duties) is the one applied for intra-
Union trade, meaning there is no need for corresponding controls at the border between the 
United Kingdom and the Union. 

As of 1 January 2021, the originating status of goods traded will have to be demonstrated in 
order  for  them  to  be  entitled  to  preferential  treatment  under  a  possible  future  EU-UK 
agreement. Goods not meeting origin requirements will be liable to customs duties even if a 
zero-tariff, zero-quota EU-UK trade agreement is put in place. Trade between the EU and its 
preferential  partners  will  also  be  affected,  as  UK  content  (in  terms  of  both  material  and 
processing  operations)  will  become  ‘non-originating’  under  Union  preferential  trade 
arrangements for the determination of the preferential origin of the goods that incorporate 
such  UK  content.  In  practice,  this  entails  a  need  for  EU  exporters  to  reassess  their  supply 
chains. They may have to relocate production or change suppliers for certain inputs in order 

12  During  the  UK’s  withdrawal  phase,  the  Commission  and  national  customs  authorities  have  already  made  available  a 
significant number of detailed information notices regarding how the new customs borders between the Union and the UK 
will be operated. 

7 

 
                                                 
 
to  continue  to  benefit  from  Union  preferential  trade  arrangements  with  current  Union 
preferential  partners.  Union  importers  claiming  preferential  treatment  in  the  EU  will  also 
need to ensure that the third-country exporter is able to prove that the goods comply with 
the requirements on preferential origin after the end of the transition period. It should also 
be noted that, in order to maintain their preferential originating status, goods will need to 
meet  provisions  related  to  direct  transport/non-manipulation  contained  in  EU  preferential 
agreements if passing through or stopping over in UK territory. 

Furthermore, Value Added Tax (VAT) will be due upon importation of goods brought into the 
VAT  territory  of the  European  Union  from  the  United  Kingdom,  at  the  rate  that  applies  to 
supplies of the same goods within the Union. Goods exported from the Union to the United 
Kingdom  will  be  exempt  from  VAT  if  they  are  dispatched  or  transported  to  the  United 
Kingdom,  as  would  be  the  case  for  any  other  destination  outside  the  European  Union.  In 
such situations, the supplier of exported goods must be able to prove that the goods have 
left the Union. 

As  with  any  import  from  third  countries  into  the  Union,  excise  duties  for  excisable  goods 
(alcoholic  beverages, tobacco  products,  etc.)  will  be  due  upon  importation  into  the  Union, 
and  payable  when  goods  are  put  on  the  market.  In  the  future,  imports  from  the  United 
Kingdom could also be subject to anti-dumping, countervailing or safeguard measures in the 
framework of the European Union’s trade defence policy. 

Advice to businesses and Member State administrations 

Traders will need to be able to demonstrate the originating status of goods traded for them 
to  be  entitled  to  preferential  treatment  under  a  possible  future  EU-UK  agreement.  Goods 
not  meeting  origin  requirements  would  not  benefit  from  those  preferential  trade 
arrangements. 

EU businesses should also be ready to start treating any UK  content (inputs and processes) 
as ‘non-originating’ in the context of trade with current Union preferential partner countries, 
in  order  to  be  sure  that  their  exports  can  continue  to  benefit  from  the  preferential 
treatment accorded by the Union’s Free Trade Agreements in any event as of the end of the 
transition  period.13  United  Kingdom  content  incorporated  in  goods  obtained  in  third 
countries with which the Union has preferential trade arrangements and imported  into the 
Union will be also ‘non-originating’. The United Kingdom will henceforth be a third country 
for the purpose of the direct transport/non-manipulation rule and businesses should adapt 
their logistics accordingly. 

Furthermore,  EU  businesses  should  get  acquainted  with  the  relevant  VAT  procedures  and 
prepare for their application. They should factor in increased administrative obligations and 

13 Supplier declarations, including long-term supplier declarations will have to be adapted accordingly. 

8 

 
                                                 
 
potential delays where relevant. This might entail significant changes to the organisation of 
existing supply chains and accounting processes.  

The administrations of EU Member States should prepare for the additional burden created 
by  these  changes,  both  in  terms  of  staffing  and  training,  and  step  up  awareness-raising, 
targeting small and medium-sized enterprises in particular. 

A.3. Certificates and authorisations of products, establishment requirements, labelling and 
marking 

During the transition period, the United Kingdom takes part in the Single Market, including 
the Single Market for goods. Goods can be freely traded between the European Union and 
the  United  Kingdom  without  being  subject  to  checks  thanks  to  the  existence  of  a  single, 
Union regulatory framework for the placing on the market of goods, including harmonised 
technical  rules,  safety  and  environmental  standards,  and  mutual  recognition.  The  EU 
institutions  and  bodies,  such  as  EU  agencies,  oversee  the  good  functioning  of  this 
framework. 

As  of  1  January  2021,  the  Union  and  the  United  Kingdom  will  be  two  separate  regulatory 
and legal spaces.  

This  means  that  all  products  exported  from  the Union  to  the  United  Kingdom  will  have  to 
comply  with  UK  rules  and  standards  and  will  be  subject  to  any  applicable  regulatory 
compliance checks and controls on imports. Similarly, all products imported from the United 
Kingdom  to  the  Union  will  need  to  comply  with  Union  rules  and  standards  and  will  be 
subject  to  all  applicable  regulatory  compliance  checks  and  controls  on  imports  for  safety, 
health and other public policy purposes. 

EU  businesses  that  currently  distribute  products  coming  from  the  United  Kingdom  will 
become  exporters  or  importers  for  products  they  place  on  the  Union  market.  This  means 
that they will need to comply with the obligations of an exporter or an importer according to 
the applicable Union rules. 

As regards the authorisation and certification of products, on the Union side: 

  Certificates or authorisations issued by UK authorities or by bodies based in the United 
Kingdom will no longer be valid for placing products on the Union market. This means, 
for instance, that a motor vehicle with a type approval issued by the United Kingdom can 
no longer be placed on the Union market. Where Union legislation requires certification 
by an EU Notified Body – e.g. for some medical devices, machinery, personal protective 
equipment  or  construction  products  –  products  certified  by  UK-based  bodies  will  no 
longer be allowed to be placed on the Union market.  

9 

 
  Where Union legislation requires registration of products in databases, this may have to 
be  done  by  an  importer  in  the  Union  or  an  authorised  representative  of  the  UK 
manufacturer.14 

  Where  Union  legislation  provides  for  a  requirement  to  be  established  in  the  Union  for 
certain  economic  operators  or  other  natural  or 
legal  persons  (e.g.  authorised 
representatives  of  third-country  manufacturers  or  ‘responsible  persons’  for  regulatory 
compliance),  establishment  in  the  United  Kingdom  will  no  longer  be  recognised  in  the 
Union. This means that a relocation of the authorised representative/responsible person 
from  the  United  Kingdom  to  the  Union  will  be  necessary,  or  a  new  authorised 
representative/responsible  person  established  in  the  European  Union  will  have  to  be 
appointed.  

  Markings  or  labelling  of  goods  placed  on  the  Union  market,  which  refer  to  bodies  or 
persons  established  in  the  United  Kingdom,  will  no  longer  comply  with  Union  labelling 
requirements. 

Finally, Union rules prohibiting or restricting certain imports / exports of goods15 for public 
policy  reasons  such  as  the  protection  of  health,  safety  and  the  environment  will  apply  to 
trade with the United Kingdom, as with any third country. 

Examples of sectoral compliance  

Chemical products 

As  of  1  January  2021,  Union  rules  on  the 
registration,  evaluation,  authorisation  and 
restriction  of  chemicals  (REACH)16  will  no 
longer apply in the United Kingdom. 

Registrations  held  by  manufacturers  and 
producers established in the United Kingdom 
will  no  longer  be  valid  in  the  European 
Union. These entities will have to ensure that 
their  substances  are  registered  with  a 
manufacturer  or  importer  in  the  European 
Union or appoint an ‘Only Representative’ in 
the  European  Union  as  registrant  for  the 
substance. 

Downstream  users  will  have 
to  check 
whether  substances  they  use  are  registered 

(medical  devices  and 
Health  products 
medicinal  products  for  human  or  veterinary 
use) 

As  of  1  January  2021,  the  United  Kingdom 
will  exit  the  Union’s  regulatory  system  for 
medicinal products and medical devices. 

As a result: 

  all  marketing  authorisation  holders  need 
to be established in the European Union; 
testing  and  batch  release  sites  will  need 
to be located in the European Union;  

 

  qualified 

persons 

responsible 

for 
pharmacovigilance  and  batch  release 
(including 
investigational  medicinal 
products)  will  need  to  be  established  in 

14 For example in the case of the European Product Database for Energy Labelling (EPREL). 
15 Examples include waste, firearms, ‘dual use goods’, specimens of endangered species, and certain hazardous chemicals. 
16  Regulation  (EC)  No  1907/2006  of  the  European  Parliament  and  of  the  Council  of  18  December  2006  concerning  the 
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and establishing a European Chemicals Agency 
OJ L 396, 30.12.2006, p. 1. 

10 

 
                                                 
 
by  a  registrant  established  in  the  European 
Union.  Where  this  is  not  the  case,  they 
should: 

  adapt  their  supply  chain  accordingly  (i.e. 

identify an alternative supplier); 

  check  whether  the  UK  registrant  they 
deal  with  plans  to  appoint  an  ‘Only 
Representative’  in  the  European  Union; 
or 

 

register  the  substance  in  the  capacity  of 
importer. 

the European Union; 

 

in 

established 

  any clinical trials authorised in the Union 
will  need  to  have  a  sponsor  or  a  legal 
the 
representative 
European Union; 
information  and  labelling  will  have  to 
comply  with  Union 
requirements, 
regards  co-labelling  of 
including  as 
medicines  according  to  the  terms  of  the 
marketing  authorisation  granted  in  the 
UK; 
the  certification  of  medical  devices  will 
have to be carried out by notified bodies 
established in the European Union. 

 

Advice to businesses and Member State administrations 

EU businesses placing goods on the UK market will need to make sure that they comply with 
all relevant UK rules as of 1 January 2021. 

As  regards  authorisation  and  certification  processes,  while  preparatory  measures  should 
have been taken already in 2019, EU businesses should double-check compliance well ahead 
of 1 January 2021.  

The administrations of EU Member States should step up awareness-raising, targeting small 
and medium-sized enterprises in particular. 

B.  Trade in services 

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  EU  Single  Market, 
including the Single Market for services. Therefore, UK businesses benefit from the freedom 
of establishment and from the possibility to provide services in any EU Member State. They 
benefit  from  a  common  regulatory  and  supervisory  environment,  which  frames  possible 
measures that national authorities can adopt. This environment also allows service providers 
to benefit from an advanced system of recognition of professional qualifications.  

Furthermore, in certain areas regulated at Union level, the cross-border exchange of services 
benefits from the country-of-origin approach or concept of ‘passporting’, which implies that 
the authorisation issued by one Member State based on Union rules is sufficient to access 
the  entire  EU  Single  Market  due  to  a  harmonisation  of  standards,  technical  rules  and 
regulatory  and  supervisory  frameworks.  These  principles  underpin  the  free  movement  of 
certain services between EU countries, for instance in the financial, audiovisual, or transport 
areas. 

11 

 
 
As of 1 January 2021, the freedom of establishment and the freedom to provide services, as 
provided for by the Union treaties, will no longer benefit individuals and businesses from the 
United Kingdom operating in the European Union or EU individuals and businesses operating 
in the United Kingdom.  

Authorisations  granted  by  UK  authorities  under  the  EU  Single  Market  framework  will  no 
longer be valid in the Union as of 1 January 2021. This has particular relevance for the areas 
of financial services, transport, audiovisual media, and energy services.   

In order to access the Union market, UK service providers and professionals established in 
the United Kingdom will need to demonstrate compliance with any rules, procedures and/or 
authorisations  that  condition  the  provision  of  services  in  the  European  Union  by  foreign 
nationals and/or companies established outside the Union.17 Those requirements might be 
set out in Union law or, more frequently, in national regimes, but will be conditioned by the 
commitments taken by the European Union under the World Trade Organization’s General 
Agreement on Trade in Services, and also within the future relationship agreement with the 
United Kingdom.   

Similarly,  EU  service  providers  and  professionals  established  in  the  Union  and operating  in 
the United Kingdom will need to demonstrate compliance with all relevant UK rules. 

B.1. Financial services 

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  EU’s  Single  Market, 
including the Single Market for financial services. Therefore, currently, financial services can 
be provided from the United Kingdom to the EU with a single authorisation or ‘passport’ per 
relevant  financial  services  area,  issued  by  the  UK  authorities.  Union  operators  can  use  the 
‘passports’ of their home state to provide financial services to and in the UK. 

As of 1 January 2021, authorisations to provide services from the United Kingdom across the 
EU will stop applying. The provision of financial services from the United Kingdom to the EU 
will be possible subject to the relevant third country rules of the Member State concerned. 
Union businesses, banks or investors that currently rely on these services should be aware of 
this change and prepare accordingly. EU financial services providers with operations in the 
United Kingdom should also prepare to abide by all relevant UK rules.  

Under the equivalence frameworks foreseen in certain Union legal acts, the European Union 
has  the  possibility  to  facilitate  specific  interactions  between  the  Union  and  UK  financial 
systems  by  recognising  that  the  relevant  UK  regulatory  and  supervisory  regimes  are 
equivalent to the corresponding Union legislation and requirements. Only a limited number 
of  these  equivalences  allow  third-country  firms  to  provide  their  services  to  EU  clients. 

17 Including immigration and visa requirements, where applicable. 

12 

 
                                                 
 
include  the  areas  of  central  securities  depositories,  and  central  clearing 
Examples 
counterparties  (CCPs).  Specifically  for  investment  firms,  a  new,  improved  equivalence 
framework will enter into force in mid-2021. In most areas, such as insurance, commercial 
bank  lending  or  deposit-taking,  equivalence  does  not  allow  third-country  firms  to  provide 
services to the EU but provide prudential or reporting reliefs to EU firms.  

Union equivalence decisions do not replicate the benefits of the Single Market for the United 
Kingdom  as  the  obligations  and  safeguards  of  the  EU’s  Single  market  eco-system  will  stop 
applying in the United Kingdom. Equivalence decisions can be unilaterally withdrawn at any 
time,  in  particular  if  third-country  frameworks  diverge  and  the  conditions  for  equivalence 
are no longer fulfilled. 

As the Union’s equivalence frameworks are unilateral, neither the equivalence assessments, 
nor possible decisions for granting equivalence are part of the negotiations with the United 
Kingdom. The current interconnectedness between the EU and the United Kingdom market 
requires that the Commission, in assessing equivalence, be particularly mindful of the risks 
for  the  EU  in  terms  of  financial  stability,  market  transparency,  market  integrity,  investor 
protection  and  level-playing  field.  In  addition,  the  United  Kingdom  government’s  stated 
intention to diverge from the Union’s regulatory and supervisory frameworks in the area of 
financial  services  after  the  transition  period  requires  that  the  Commission  assess  UK 
equivalence in each area on a forward-looking basis.  

The  Political  Declaration  on  the  future  relationship18  states  that  both  the  European  Union 
and  the  United  Kingdom  will  endeavour  to  conclude  their  respective  equivalence 
assessments  before  the  end  of  June  2020.19  The  Commission  shared  with  the  United 
Kingdom  questionnaires  covering  28  equivalence  areas.  By  the  end  of  June,  only  4 
completed  questionnaires  had  been  returned.  On  this  basis,  the  Commission  could  not 
conclude its equivalence assessments by the end of June.  The Commission will continue the 
assessments  based  on  further  replies  that  it  is  currently  receiving.  The  assessments  may 
lead, in each of the areas, to decisions on equivalence or to no equivalence. The Commission 
will take decisions based on a comprehensive assessment, including of the EU interest.  

In  a  number  of  areas,  the  Commission  has  not  initiated  an  assessment,  either  because 
equivalence  decisions  have  already  been  granted20  or  because,  for  instance,  the  EU  legal 

18 See Part IV on ‘Financial Services’ of the Revised text of the Political Declaration setting out the framework for the future 
relationship between the European Union and the United Kingdom as agreed at negotiators’ level on 17 October 2019, OJ 
C34, 31 January 2020, 1-16. 
19 COM (2019) 349 final. Communication from the Commission, Equivalence in the area of financial services 
20 Areas already granted:  

- Regulation (EU) No 648/2012 on OTC derivatives, central counterparties and trade repositories (EMIR), as 
amended; Art. 1(6) - Exemption central banks and public bodies  
- Regulation (EU)2015/2365 on transparency of securities financing transactions and of reuse (SFTR); Art. 2(4) - 
Central bank exemption 
- Regulation (EU) N° 600/2014 on markets in financial instruments (MIFIR); Art. 1(9) - Central bank exemption 

13 

 
                                                 
 
framework is not yet fully in place. With regard to the latter areas21, the Commission will not 
adopt an equivalence decision in the short or medium term. 

On the basis of an analysis conducted with the European Central Bank, the Single Resolution 
Board  and  the  European  Supervisory  Authorities,  and  of  the  preparation  undertaken  by 
financial  services  firms,  the  Commission  has  identified  only  one  area  which  may  present 
financial  stability  risks,  namely  the  central  clearing  counterparties  (CCPs)  of  derivatives. 
Therefore, in the short term and in order to address the possible risks to financial stability, 
the  Commission  is  considering  the  adoption  of  a  time-limited  equivalence  decision  for  the 
United Kingdom in this area. 

Such a time-limited decision would allow EU-based CCPs to develop further their capacity to 
clear  relevant  trades  in the  short  and  medium  term  and EU  clearing  members to  take and 
implement the necessary steps, including by reducing their systemic exposure to UK market 
infrastructures. 

In order to enhance the supervision and regulation of clearing activities that are of systemic 
importance  for  the  Union,  the  EU  is  currently  implementing  the  EMIR  2.2  Regulation.  The 
Commission  is  adopting  the  implementing  measures  that  will  determine  the  degree  of 
systemic  risk  of  third-country  CCPs  and  the  necessary  measures  to  strengthen  the 
supervision of such CCPs, as well as the possible need for further measures to mitigate those 
risks.  

Advice to businesses and Member State administrations 

Insurance  operators,  banks,  investment  firms,  trading  venues  and  other  financial  services 
providers should finalise and implement their preparatory measures by 31 December 2020 

- Regulation (EU) No 596/2014 on insider dealing and market manipulation (MAR Market Abuse Regulation); Art 
.6(5) - Exemption central banks and public bodies 

21 - Directive 2004/109/EC - Transparency Directive - Accounting Standards; Art. 23(4)[first subparagraph, point (ii)] - 
General transparency requirements  

- Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts (Statutory Audit); Art. 
45(6) - Equivalence to the international auditing standards of the standards and requirements in the third country 
- Regulation (EU) N° 600/2014 on markets in financial instruments (MIFIR); Art. 33(2) - Derivatives: trade 
execution and clearing obligations; Art. 38(3) - Access for third-country trading venues and CCPs; Art. 47(1) - 
Investment firms providing investment services to EU professional clients and eligible counterparties 
– Directive 2014/65 on markets in financial instruments and amending Directive 2002/92/EC and Directive 
2011/61/EU (MiFID 2 – recast; Art. 25(4)[a] - Regulated markets for the purposes of easier distribution in the EU 
of certain financial instruments 
– Regulation (EU) No 596/2014 on insider dealing and market manipulation (MAR Market Abuse Regulation); Art. 
6(6) - Exemption for climate policy activities 
– Regulation (EU) No 236/2012 on short selling and certain aspects of Credit Default Swaps (SSR); 
Art. 17(2) - Exemption for market making activities 
– Regulation (EU)2017/1129 of 14 June 2017 on the prospectus to be published when securities are offered to the 
public or admitted to trading on a regulated market, and repealing Directive 2003/71/EC; Art. 29(3) - Prospectus 
rules  

14 

 
                                                                                                                                                         
 
 
 
at  the  latest  to  be  ready  for  the  changes  that  will  happen  under  all  scenarios,  including 
wherein  their  area,  there  is  no  equivalence  decision  taken  by  the  European  Union  or  the 
United Kingdom.  

Union  businesses,  banks  or  investors  that  currently  rely  on  UK  service  providers  should 
consider how this may affect their operations and take all the necessary steps to prepare for 
all possible scenarios. EU financial services providers with operations in the United Kingdom 
should also prepare to abide by all relevant UK rules. EU clearing members of UK CCPs and 
their clients should take active steps to prepare for all scenarios, including by reducing their 
systemic exposure to UK market infrastructures.  

EU  and  national  supervisors  and  regulators  will  need  to  continue  their  dialogue  with 
stakeholders with a view to ensuring that all necessary actions for readiness are taken by the 
end of 2020. 

B.2. Transport services 

During the transition period, the United Kingdom takes part in the Single Market, including 
the Single Market for transport services. Therefore, currently, railway services, air transport 
services,  and  road  haulage  operations  can  be  carried  out  throughout  the  European  Union 
with one single licence, issued by one Member State. This also benefits EU operators in the 
United Kingdom during the transition period. 

As  of  1  January  2021,  UK  companies  will  no  longer  be  able  to  perform  transport  services 
within the Union as part of the Single Market. The possibilities and conditions for EU and UK 
transport  operators  to  perform  services  between  the  European  Union  and  the  United 
Kingdom will largely depend on the negotiations on the future EU-UK relationship in the area 
of transport. 

However, in any case, as of 1 January 2021, licences issued to railway undertakings by the 
United  Kingdom  will  no longer be  valid  in  the  European  Union,  and  certificates  or  licences 
issued  in  the  United  Kingdom  to  train  drivers  will  no  longer  be  valid  for  the  operation  of 
locomotives and trains on the EU’s railway system. 

Railway  undertakings from  the European  Union  or the  United  Kingdom that  provide  cross-
border services between the United Kingdom and the European Union will have to comply 
with the legal requirements applicable both in the European Union and the United Kingdom. 
This relates to the license and safety certificate for the railway undertaking, the rolling stock 
authorisations and personnel (train drivers) licenses. Stakeholders concerned therefore have 
to ensure that they have valid licences in the European Union for the sections of the cross-
border  services  located  in  the  territory  of  the  European  Union,  and  valid  licences  in  the 
United Kingdom for the sections of the cross-border services located in the territory of the 
United Kingdom.  

15 

 
In any case, as of 1 January 2021, air carriers holding operating licences granted by the UK 
licensing  authority  for  the  commercial  carrying  by  air  of  passengers,  mail  and/or  cargo, 
will no longer be able to provide air transport services within the European Union. 

EU  air  carriers  and  holders  of  aviation  safety  certificates  will  need  to  ensure,  and  uphold 
compliance with Union requirements, including airlines’ requirements on principal place of 
business and EU majority ownership and control, as well as the Union aviation safety acquis.  

Finally,  in  any  case,  as  of  1  January 2021,  road transport  operators that are  established  in 
the United Kingdom will no longer hold a Community licence. They will therefore no longer 
benefit from the automatic access rights to the Single Market that such a licence entails, and 
namely the right of EU operators to conduct journeys and carry goods across the Union.  

The  access  rights  that  EU  operators  and  UK  operators  will  have  to  each  other’s  respective 
markets  will  depend  on  the  outcome  of  the  negotiations  between  the  EU  and  the  United 
Kingdom.  In  the  absence  of  an  agreement,  the  limited  quotas  already  available  under  the 
mechanism  of  the  European  Conference  of Ministers  of Transport  (ECMT)  will  be  available 
for  EU  operators  to  conduct  journeys  to  the  United  Kingdom,  and  for  UK  operators  to 
conduct journeys to the EU.  

Advice to businesses and Member State administrations 

All transport businesses conducting operations between the European Union and the United 
Kingdom must ensure compliance respectively with EU and UK certification requirements as 
of 1 January 2021. 

Access rights for air and road transport between the Union and the UK will largely depend on 
the outcome of the negotiations with the United Kingdom.  

In any case, transport operators will be affected by changes in the formalities required when 
crossing  the  UK-EU  border.22  Beyond  sector  specific  transport  rules,  administrations  of  EU 
Member  States  should  step  up  awareness-raising,  targeting  SMEs  in  particular,  on  how 
border  formalities  will  affect  transport  and  logistics  operators  going  forward,  as  well  as 
passengers  and  cross-border  workers.  This  also  includes  border  checks  on  persons  – 
entailing  the  verification  of  entry  and  stay  requirements,  stamping  of  passports,  and  visa 
requirements if applicable. 

22 With the exception of Northern Ireland, which, in accordance with the Protocol on Ireland and Northern 
Ireland will remain aligned to a limited set of Union rules, so as to avoid customs checks and controls on the 
island of Ireland. 

16 

 
 
                                                 
 
B.3. Audiovisual services 

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  Single  Market  for 
audiovisual  services.  Therefore,  currently,  the  country-of-origin  principle  applies,  whereby 
any service provider that is established in a Member State and conforms to the rules of that 
state’s  national  regulator  benefits  from  the  freedom  of  reception  rule,  and  is  able  to 
broadcast content to any other Member State without having to seek approval by that other 
Member State. 

As of 1 January 2021, businesses established in the United Kingdom will no longer be able to 
benefit from the country-of-origin principle of the Audiovisual and Media Services Directive.  

As a result, UK-based audiovisual media service providers will need to comply with each of 
the rules of the relevant Member State in which they would want to provide their services. 

Advice to businesses and Member State administrations 

Audiovisual  media  service  providers  established  in  the  United  Kingdom  and  supplying 
audiovisual  media  services  to  the  European  Union  should  take  the  necessary  measures  to 
ensure compliance with each of the national regimes where they intend to provide services. 
EU  providers  wishing  to  supply  services  in  the  United  Kingdom  will  need  to  abide  by  UK 
rules.   

B.4. Recognition of professional qualifications 

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  EU  Single  Market, 
including  the  freedom  of  establishment,  the  free  movement  of  persons  and  the  free 
provision  of  services.  Therefore,  currently,  UK  nationals  and  EU  citizens  holding  a 
qualification  in  the  United  Kingdom  benefit  from  a  simplified  –  in  some  cases  automatic  – 
recognition regime in other EU countries, which allows professionals such as doctors, nurses, 
dental  practitioners,  pharmacists,  veterinary  surgeons,  lawyers,  architects  or  engineers  to 
move and provide services across the European Union and the in the United Kingdom during 
the transition period. 

As of 1 January 2021, the United Kingdom will no longer be covered by Union rules on the 
recognition  of  professional  qualifications,  and  the  recognition  of  qualifications  obtained  in 
EU Member States by the United Kingdom will be a matter of UK law. 

UK  nationals,  irrespective  of  where  they  acquired  their qualifications,  and  EU  citizens  with 
qualifications  acquired  in  the  United  Kingdom  will  need  to  have  them  recognised  in  the 

17 

 
relevant Member State on the basis of that country’s rules for third-country nationals and/or 
third-country qualifications as of the end of the transition period.23 

Advice to persons, businesses and Member State administrations 

Persons  concerned  should  seek  to  obtain  recognition  of  their  UK  qualification  in  the 
European Union before 1 January 2021 in order to be prepared for the end of the transition 
period. Businesses decisions should take into account that from January 2021, after the end 
of transition, such recognition will happen in the relevant Member State on the basis of that 
country’s rules for third-country nationals and/or third-country qualifications. 

C.  Energy 

During the transition period, the United Kingdom takes part in the integrated Union energy 
market. Therefore, EU-UK trading of energy products via electricity and gas interconnectors 
is currently managed through dedicated Union platforms. 

As  of  1  January  2021,  although  electricity  and  gas  interconnectors  can  of  course  still  be 
used,  the  United  Kingdom  will  no  longer  participate  in  the  Union’s  dedicated  platforms. 
Alternative  fall-back  solutions  will  be  used  instead  to  trade  electricity  on  interconnectors 
with Great Britain.24 These should allow electricity trade to continue, although not with the 
same level of efficiency as within the Single Market today. 

Advice to businesses and Member State administrations 

Businesses and Member State administrations should take into account that, from January 
2021, trades over electricity interconnectors with Great Britain will not be managed through 
Union platforms and will become third country energy flows. Stakeholders concerned should 
consider necessary measures to adapt to the new regulatory environment. 

D.  Travelling and tourism 

Checks on persons25 

During  the  transition  period,  UK  nationals  are  treated  like  Union  citizens.  Therefore,  UK 
nationals currently benefit from freedom of movement when entering the European Union 
and the Schengen area. 

23 However, persons falling under the scope of Part Two of the Withdrawal Agreement will benefit from the application of 
EU Single Market rules in respect of the procedures for recognition which are ongoing on 31 December 2020.   
24 This does not apply to the electricity interconnectors between Northern Ireland and Ireland, given that under Article 9 of 
the Withdrawal Agreement, Northern Ireland will continue to participate in the Integrated Single Electricity Market across 
the island of Ireland. 
25 This section (checks on persons) does not apply to travels between the UK and Ireland, given that, under the Protocol on 
Ireland and Northern Ireland, the United Kingdom and Ireland may continue to make arrangements between themselves 
relating to the movement of persons between their territories (the ‘Common Travel Area’), while fully respecting the rights 
of natural persons conferred by Union law. 

18 

 
                                                 
 
As of 1 January 2021, UK nationals travelling to the European Union and the Schengen area 
will  be treated  as third-country  nationals,  and  therefore  subject  to thorough checks at the 
Schengen area border. This means that intended stays on the territory of EU Member States 
cannot have a duration of more than 90 days in any 180-day period, and UK nationals will 
have to meet the entry conditions for third-country nationals. They can also no longer make 
use of the EU/EEA/CH lanes reserved for persons enjoying the right to free movement when 
crossing the border.   

Visa requirements 

During the transition period, UK nationals are treated like Union citizens. Therefore, they are 
not  subject  to  any  visa  requirements  in  the  European  Union,  in  particular  when  crossing 
Schengen borders. 

Recent EU  preparedness  legislative  measures have  ensured  that,  as  of 1  January  2021,  UK 
nationals  will  remain  exempt  from  the  requirement  to  be  in  possession  of  visas  when 
crossing  the  European  Union’s  external  borders for  short-term  stays  (up  to  90  days  in  any 
180-day period). This visa exemption does not provide for the right to work in the Union and 
is subject to the reciprocity mechanism applying to third countries, i.e. it could be suspended 
if  Union  citizens  would cease  to be  given  visa-free  access  to the  United Kingdom for  short 
stays. 

Visa rules will also change for certain third-country nationals residing in the UK when they 
travel  to  the  Union.  For  example,  as  of  1  January  2021,  UK  residence  documents  will  no 
longer  exempt  the  holder  from  airport  transit  visa  requirements  in  the  Union,  and  school 
pupils  residing  in  the  United  Kingdom  will  no  longer  automatically  benefit  from  visa-free 
access to the Union when going on school excursions.   

Travelling with pets 

During the transition period, pet owners resident in the United Kingdom can use the ‘EU pet 
passport’ to facilitate travel in the European Union with their pets.  

As  of  1  January  2021,  an  EU  pet  passport  issued  to  a  pet  owner  resident  in  the  United 
Kingdom  will  no  longer  be  a  valid  document  for  travelling  with  pets  from  the  United 
Kingdom to any of the EU Member States. The requirements for pets accompanying those 
travelling from the United Kingdom in the future will be set by the Union.  

Driving licences 

During  the  transition  period,  Union  law  on  the  recognition  of  driving  licenses  across  the 
European  Union  applies.  Therefore,  currently,  holders  of  UK-issued  driving  licences  can 
continue to drive in the EU without additional documentation.  

As of 1 January 2021, driving licenses issued by the United Kingdom will no longer benefit 
from mutual recognition under Union law. The recognition of driving licences issued by the 
United  Kingdom  will  be  regulated  at  Member  State  level.  In  Member  States  that  are 
Contracting  Parties  to  the  1949  Geneva  Convention  on  Road  Traffic,  this  Convention  will 

19 

 
apply.  For  further  information  the  responsible  authority  of  the  respective  Member  State 
should be consulted.  

Roaming 

During  the  transition  period,  Union  law  on  roaming  applies  with  respect  to  the  United 
Kingdom. Therefore, currently, the regulation ensuring roaming without additional charges 
applies vis-à-vis and in the United Kingdom. 

As of 1 January 2021, access for United Kingdom consumers to Roam-Like-At-Home in the 
European  Union  will  no  longer  be  guaranteed  by  Union  law;  nor  will  it  be  guaranteed  for 
Union consumers travelling to the United Kingdom.  

Both  United  Kingdom  and  EU  mobile  operators  will  thus  be  able  to  apply  a  surcharge  on 
roaming customers. 

Passenger rights 

During the transition period, Union law on passenger rights for air, rail, bus, coach and ship, 
including assistance to passengers with disabilities or reduced mobility, continues to apply to 
passengers  departing  from  the  United  Kingdom  to  an  EU  Member  State,  irrespective  of 
whether the carrier is a UK or a Union carrier.  

As of 1 January 2021, the level of protection of passengers travelling between the EU and 
the United Kingdom will be affected. Depending on the transport mode, passengers may no 
longer be protected by EU passenger rights when travelling to or from the United Kingdom.  

Advice to persons, businesses and Member State administrations 

People  travelling  should  take  into  account  changes  relating  to  border  checks,  visa 
requirements,  pet  passports,  driving  licences  and  roaming  charges  when  travelling  to  and 
from the United Kingdom. 

Businesses supplying travel services should get acquainted with the changes, and may need 
to adapt processes accordingly.  

National authorities must make sure that there is sufficient staff available at border crossing 
points, and if need be adapt infrastructure. They should also make sure that passengers and 
travelers are well informed about any changes to their rights and obligations. 

E.  Mobility and social security coordination 

During  the  transition  period,  UK  nationals  continue  to  benefit  from  the  free  movement  of 
persons  in  the  Union.  EU  citizens  can  also  still  use  their  free  movement  rights  to  go  and 
work,  study,  start  a  business  or  live  in  the  United  Kingdom.  All  Union  rules  on  the 
coordination  of  social  security  systems  also  apply  and  will  –  under  the  terms  of  the 
Withdrawal Agreement – continue to apply, even after the end of the transition period, to 

20 

 
people who were in a cross-border situation involving the United Kingdom and the European 
Union  before  the  end  of  transition  period.  The  Withdrawal  Agreement  also  protects  the 
residence and work rights of EU citizens lawfully residing in the United Kingdom and of UK 
nationals lawfully residing in an EU Member State at the end of the transition period and the 
members of their families.26  

As of 1 January 2021, free movement between the European Union and the United Kingdom 
ends.  This  will  have  repercussions  on  the  ease  of  mobility  for  all  EU  citizens  who  are  not 
beneficiaries  of  the  Withdrawal  Agreement  and  wish  to  stay  in  the  United  Kingdom  for 
longer periods, be they students, workers, retired people or their family members. All their 
movements to the United Kingdom will be governed by UK immigration laws. UK companies 
wanting to recruit EU citizens will  have to follow UK rules that do not apply today under the 
Union  regime.  All  movements  to  the  EU  of  UK  nationals  who  are  not  beneficiaries  of  the 
Withdrawal Agreement will be governed by Union and Member States’ migration rules. EU 
companies  wanting  to  recruit  UK  nationals  will  have  to  follow  the  relevant  rules  for  third-
country nationals of the Union and their respective Member States.  

For those EU citizens who will exercise some form of mobility under the new UK regime, the 
current coordination of social security systems foreseen by Union regulations will cease to 
exist. The same will be true for UK nationals in the EU, unless they are covered by specific 
Union  rules  related to third-country  nationals.  There  will not  be the  same  extensive  cross-
border social security protection as under current Union rules, as Union rules will no longer 
apply.  Even  under  a  future  partnership  agreement  with  the  United  Kingdom,  only  certain 
social  security  entitlements  could  potentially  be  ensured.  The  exact  terms  that  will  apply 
depend  on  the  outcome  of  negotiations  between  the  European  Union  and  the  United 
Kingdom on the future partnership, for instance on health care costs or pension rights. 

F.  Company law and civil law 

F.1. UK-registered companies  

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  Single  Market,  which 
includes  the  fundamental  freedom  of  establishment.  Therefore,  currently,  a  company  may 
be registered in the United Kingdom while having its central administration or the principal 
place of business in an EU Member State. 

As of 1 January 2021, UK incorporated companies will be third-country companies and will 
not automatically be recognised under Article 54 of the TFEU. Their recognition will become 
subject to national law for third country-incorporated companies.  

26  Union  citizens,  except  those  with  Irish  citizenship,  need  to  apply  to  obtain  “settled”  or  “pre-settled”  status  under  the 
United Kingdom’s Union Settlement Scheme. 

21 

 
                                                 
 
Branches  in  EU  Member  States  of  UK  incorporated  companies  will  be  branches  of  third-
country  companies.  Subsidiaries  of  UK  companies  in  the  Union  are,  in  principle,  EU 
companies and will continue to be covered by all relevant Union and national legislation. 

Advice to businesses and Member State administrations 

In case companies incorporated in the United Kingdom wish to become EU companies, they 
should take all the necessary steps to incorporate in an EU Member State.  

F.2. Contractual choice of jurisdiction 

During  the  transition  period,  the  United  Kingdom  takes  part  in  elements  of  the  European 
civil  judicial  area.27  Therefore,  currently,  judgements  in  both  civil  and  commercial  matters 
that  are  handed  down  by  a  UK  court  are  swiftly  enforceable  in  the  European  Union.  In 
practice, commercial contracts often establish UK jurisdiction for litigation. 

As of 1 January 2021, Union rules facilitating the cross-border recognition and enforcement 
of  judgements  in  the  EU  and  in  the  United  Kingdom  during  the  transition  period  will  no 
longer  apply.28  Should  the  United  Kingdom  accede  to  the  2005  The  Hague  Convention  on 
Choice  of  Court  Agreements  in  its  own  right  after  the  end  of  the  transition  period,  this 
Convention  would  only  apply  to  the  recognition  and  enforcement  of  judgments  given  by 
courts  designated  in  exclusive  choice  of  court  agreements  concluded  after  the  United 
Kingdom has become party to that Convention. Thus, for the time being, the recognition and 
enforcement of UK judgments will be governed by the national rules of the Member State in 
which recognition/enforcement is sought. 

Advice to businesses and Member State administrations 

All  businesses  are  advised  to  consider  this  situation  when  assessing  contractual  choices  of 
international jurisdiction. 

Businesses should be aware that judgments handed down by a UK court might no longer be 
swiftly enforceable in the European Union compared to today’s situation. 

27 While the United Kingdom continues to apply the Union's Justice and Home Affairs policy during the transition period, it 
has  enjoyed  the  right  to  opt-out  in  this  field  and  it  never  opted  to  participate  in  all  instruments  in  the  field  of  judicial 
cooperation in civil and commercial matters. 
28 It is also noteworthy that, as of 1 January 2021, the EU Online Dispute Resolution (ODR) platform will no longer be 
available for the out-of-court resolution of disputes between consumers residing in the European Union and traders 
established in the United Kingdom.  

22 

 
                                                 
 
G. Other aspects: Data, digital and intellectual property rights 

G.1. Intellectual property 

During  the  transition  period,  the  United  Kingdom  takes  part  in  the  EU  Single  Market. 
Therefore,  currently,  a  holder  of  an  intellectual  property  right,  such  as  an  EU  trademark, 
cannot invoke such a trademark to oppose the shipment of goods from the United Kingdom 
to  the  European  Union,  so  long  as  the  goods  have  been  put  on  the  UK  market  under  that 
trademark  by  the  right-holder  or  with  its  consent  (‘principle  of  exhaustion’  of  the  rights 
conferred by the intellectual property right), and vice versa.   

As of 1 January 2021, traders in the European Union can no longer invoke exhaustion vis-à-
vis right-holders when sourcing products from the United Kingdom. 

Advice to businesses and Member State administrations 

Businesses engaged in parallel trade from the United Kingdom should re-visit their business 
arrangements. 

In addition, as of 1 January 2021, while existing EU unitary intellectual property rights (EU 
trademarks,  Community  designs,  Community  plant  variety  rights  and  geographical 
indications) remain protected under the Withdrawal Agreement, any new EU unitary rights 
will  have  a  reduced  territorial  scope  as  they  will  no  longer  have  effect  in  the  United 
Kingdom.29  

Advice to businesses and Member State administrations 

Stakeholders  concerned  should  take  the  necessary  measures  to  ensure  protection  in  the 
United Kingdom of future intellectual property rights, where relevant.  

G.2. Data transfers and protection 

During  the  transition  period,  the  United  Kingdom  is  bound  by  Union  data  protection 
legislation. Therefore, currently, personal data can be transmitted from the European Union 
to the United Kingdom without any restrictions. 

As  of  1  January  2021,  transfers of personal data  to the  United  Kingdom can  continue,  but 
they will have to comply with specific Union rules and safeguards relating to the transfer of 
personal  data  to  third  countries,  as  set  out  in  the  EU  General  Data  Protection  Regulation 
(GDPR)30 or in the Law Enforcement Directive.31  

29 Existing unitary rights are safeguarded in the United Kingdom under Articles 54 and 57 of the Withdrawal Agreement by 
being converted into United Kingdom rights. 
30Regulation (EU) 2016/679,https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1594051658864&uri=CELEX:32016R0679 

23 

 
                                                 
 
In  particular,  Chapter  V  of  the  GDPR  provides  for  a  number  of  tools  ensuring  that,  when 
transferring  personal  data  to  third  countries,  the  level  of  protection  of  natural  persons 
guaranteed  within  the  Union  is  not  undermined.  Among  those  tools,  the  European  Union 
can  adopt  a  unilateral  ‘adequacy’  decision,  on  the  basis  of  Article  45  of  the  General  Data 
Protection  Regulation,  if  it  deems  that  the  third  country  offers  an  adequate  level  of  data 
protection. 

As underlined in the Political Declaration,32 the EU will use its best endeavours to conclude 
the  assessment  of  the  UK  regime  by  the  end  of  2020  with  a  view  to  possibly  adopting  a 
decision if the United Kingdom meets the applicable conditions. The Commission is currently 
conducting  this  assessment  and  has  held  a  number  of  technical  meetings  with  the  United 
Kingdom  to  gather  information  in  order  to  inform  the  process.  On  the  side  of  the  United 
Kingdom, its Data Protection Act conferred adequacy on EU Member States until the end of 
2024, with the need to be re-examined by that date. 

Advice to businesses and Member State administrations 

Businesses  and  public  administrations  should  take  the  necessary  steps  to  ensure  the 
compliance of any personal data transfers to the United Kingdom with Union data protection 
law, irrespective of the scenario whereby an EU adequacy decision will be taken with regard 
to  the  United  Kingdom.  Compliance  can  be  achieved  by  having  appropriate  safeguards  in 
place  as  foreseen  by  the  General  Data  Protection  Regulation,  including  binding  corporate 
rules, or through specific derogations.  

G.3. .eu domain name 

During  the  transition  period,  Union  law  on  the  .eu  top-level  domain  names  applies  with 
respect  to  the  United  Kingdom.  Businesses  established  in  the  United  Kingdom  and  UK 
citizens and residents remain eligible to register and hold a .eu domain name. 

As of 1 January 2021, businesses that are established in the United Kingdom, but not in the 
European  Union,  and  UK  residents  who  are  not  EU  citizens  will  no  longer  be  eligible  to 
register or hold .eu domain names.  

If these persons are not able to demonstrate their continued eligibility to be holders of .eu 
domain  names,  their  domain  names  will  be  withdrawn33  after  the  end  of  the  transition 
period. However, EU citizens residing in the United Kingdom will be able to hold .eu domain 
names, or register new ones, even after the end of the transition period. 

31 Directive (Union) 2016/680, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016L0680  
32 See Part I.I.B on ‘Data protection’ of the Revised text of the Political Declaration setting out the framework for the future 
relationship between the European Union and the United Kingdom as agreed at negotiators’ level on 17 October 2019, OJ 
C34, 31 January 2020, 1-16. 
33 A withdrawn domain name no longer functions. It can no longer support any active service, such as websites or emails. 

24 

 
                                                                                                                                                         
 
H.  International agreements of the European Union 

During  the  transition  period,  the  United  Kingdom  continues  to  be  bound  by  international 
agreements concluded by the European Union. Moreover, the European Union has informed 
its  international  partners  that  the  United  Kingdom  is  treated,  during  the  transition  period, 
like a Member State, for the purposes of those agreements. 

As  of  1  January  2021,  the  United  Kingdom  will  no  longer  be  covered  by  the  agreements 
concluded by the Union, or by Member States acting on behalf of the Union, or by the Union 
and its Member States jointly. The European Union informed its international partners of the 
consequences  of  the  United  Kingdom’s  withdrawal  from  the  Union  by  way  of  a  ‘Note 
Verbale’ sent after signature of the Withdrawal Agreement.34 

As a consequence, the United Kingdom, including UK nationals and economic operators, will 
no  longer  be  able  to  benefit  from  several  hundred  international  agreements  of  the  Union 
such as Free Trade Agreements, mutual recognition agreements, veterinary agreements or 
bilateral agreements in relation to air transport or aviation safety. Businesses established in 
the  Union  will  of  course  continue  to  benefit  from  all  existing  Union  international 
agreements.  

This  is  without  prejudice  to  the  status  of  the  United  Kingdom  in  relation  to  multilateral 
agreements  to  which  it  is  a  party  in  its  own  right.  For  instance,  the  United  Kingdom  will 
remain a member of the World Trade Organization in its own right and will be covered by 
the relevant World Trade Organization agreements in relation notably to its concessions and 
commitments regarding trade in goods, services or intellectual property rights.  

34 https://ec.europa.eu/info/sites/info/files/model-note-verbale-international-partners_en.pdf  

25 

 
 
 
                                                 
 
III.  Preparing for any scenario 

The changes described in part II of this Communication will happen in any case, whether 
the European Union and the United Kingdom agree on an ambitious new partnership by 31 
December 2020, or not.  

It  is  nonetheless  clear  that  failing  to  reach  an  agreement  would  lead  to  disruptions  that 
would be more far-reaching than the changes outlined in part II. In case of no agreement, 
each side’s ‘Most Favoured Nation’ tariffs would apply to exports from the other side; that 
is,  goods  imported  from  the  United  Kingdom  into  the  Union  would  be  levied  the  EU’s 
“Common Customs Tariff”, while goods imported from the Union into the United Kingdom 
would be subject to UK tariffs.35  

This  Communication  does  not  seek  to  prejudge  the  outcome  of  the  ongoing  negotiations 
between the European Union and the United Kingdom. In this respect, its main focus is on 
issues  that  are  not  currently  under  negotiation.  The  Commission  acknowledges  that  this 
leaves  considerable  uncertainty  for  public  administrations,  citizens,  businesses  and  other 
stakeholders across the economy and society. One example of such uncertainty is what will 
happen with a possible UK participation in Erasmus+ and Horizon Europe as of January 2021. 
Only the outcome of ongoing negotiations can lift such uncertainty.  

The consequences of failing to agree on a new partnership by 31 December 2020 would be 
significant.  Nevertheless,  the  Commission  notes  that  the  ‘no  deal’  scenario  on  the  future 
relationship would differ from the ‘no deal’ scenario during the negotiations on the United 
Kingdom’s withdrawal from the European Union, and this for several reasons: 

1.  Firstly, the Withdrawal Agreement provides legal certainty in a number of important 
areas  where  the  United Kingdom’s  withdrawal  from  the  Union  created uncertainty. 
This  includes  the  protection  of  citizens’  rights,  the  financial  settlement,  the 
establishment of a legally operative solution to avoid a hard border on the island of 
Ireland,  the  continued  protection  of  the  stock  of  EU  unitary  intellectual  property 
rights  (including  existing  geographical  indications),  and  provisions  for  an  orderly 
winding  down  of  all  ongoing  procedures  between  the  EU  and  the  United  Kingdom 
(see Box).  

2.  Secondly,  the  transition  period  set  out  in  the  Withdrawal  Agreement  provides 
stakeholders  with  additional,  albeit  limited,  time  to  prepare  for  any  scenario, 
including  one  where  there  is  no  agreement  on  a  future  partnership  in  place  by  1 
January 2021. 

35 The United Kingdom has published information on its new UK Global Tariff that would be applicable from 1 
January 2021 also to EU goods in case of there being no agreement on the future EU-UK relations. 
https://www.gov.uk/guidance/uk-tariffs-from-1-january-2021 

26 

 
                                                 
 
 
3.  Thirdly, a limited number of Union legislative measures adopted in 2019 in view of 
preparedness for any scenario in terms of the United Kingdom’s withdrawal from 
the  EU,  will  remain  in  force  or  become  applicable  at  the  end  of  the  transition 
period.  They  include,  for  example,  the  listing  of  the  United  Kingdom  as  a  third 
country whose nationals are exempt from the visa requirement for short-term stays, 
as well as the apportionment of the EU’s WTO tariff rate quotas (TRQs) between the 
European Union and the United Kingdom.   

Taking all the above into consideration, the Commission will continue to monitor closely the 
situation and will endeavour to protect the interests of the European Union, of its citizens 
and its economy in any scenario.  

BOX: The Withdrawal Agreement, including the Protocol on Ireland and Northern Ireland 

The  Withdrawal  Agreement  concluded  between  the  European  Union  and  the  United 
Kingdom entered into force on 1 February 2020.  

It includes detailed provisions aimed to limit the impact of the United Kingdom’s withdrawal 
from the European Union and its Single Market and the Customs Union, in particular in the 
following areas: 

Citizens’  rights:  The  Withdrawal  Agreement  protects  the  rights  of  EU  citizens  lawfully 
residing under Union law in the United Kingdom at the end of the transition period, as well 
as of UK nationals lawfully residing under Union law in one of the EU Member States at the 
same point in time, and of their family members, to continue to live, study and work in their 
respective host States.36 

Financial settlement: The Withdrawal Agreement provides that the United Kingdom and the 
European  Union  will  honour  all financial  obligations  undertaken  while the  United  Kingdom 
was  a  member  of  the  European  Union,  also  for  commitments  that  give  rise  to  actual 
spending occurring after 2020.37  

Protocol on Ireland and Northern Ireland: The Protocol on Ireland and Northern Ireland will 
become applicable at the end of the transition period and represents a stable solution that 
will  continue  to  apply  alongside  any  agreement  on  the  future  partnership,  subject  to  the 

36 For detailed information, see the Commission Guidance Note (2020/C 173/01) on Part II of the Withdrawal Agreement 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020XC0520(05)&from=EN  

37 Article 138 of the Withdrawal Agreement provides that, in respect of the implementation of the Union programmes and 
activities committed under the Multiannual Financial Framework 2014-2020 or previous financial perspectives, applicable 
Union law continues to apply to the United Kingdom after 31 December 2020 until the closure of those Union programmes 
and activities. UK participation in future programmes depends on the new partnership agreement unless the programme 
exceptionally allows for participation of third countries and their entities without requiring an agreement.   

27 

 
                                                 
 
 
future consent by the Northern Ireland Assembly to its continued application. 

It  provides  a  legally  operative  solution  that  avoids  a  hard  border  on  the  island  of  Ireland, 
protects  the  all-island  economy  and  the  Good  Friday  (Belfast)  Agreement  in  all  its 
dimensions, and safeguards the integrity of the EU Single Market as well as the UK internal 
market. 

In  accordance  with  this  Protocol,  Northern  Ireland  will  remain  aligned  to  a  limited  set  of 
Union  rules,  notably  related  to  goods,  and  the  Union  Customs  Code,  VAT  and  excise  rules 
will apply to all goods entering or leaving Northern Ireland. This avoids any customs checks 
and controls on the island of Ireland.  

Checks and controls will take place on goods entering Northern Ireland from the rest of the 
United  Kingdom,  for  example  on  food  products  and  live  animals  to  ensure  adherence  to 
sanitary  and  phytosanitary  (‘SPS’)  requirements.  All  goods  entering  or  leaving  Northern 
Ireland must fully comply with relevant Union rules and standards. 

EU customs duties will apply to goods entering Northern Ireland unless the Joint Committee 
sets out a framework of conditions under which these goods are considered not to be at risk 
of entering the EU's Single Market. Based on such a framework, no customs duties will be 
payable if it can be demonstrated that goods entering Northern Ireland from the rest of the 
UK are not at risk of entering the EU's Single Market. 

Union customs formalities and procedures will apply to goods brought into Northern Ireland 
from the outside of the EU or exported from Northern Ireland. 

EU VAT and excise rules apply to goods entering (or leaving) Northern Ireland from (or to) 
the rest of the UK. 

Separation  issues:  The  Withdrawal  Agreement  also  ensures  an  orderly  winding-down  of 
existing arrangements with regard to matters on-going at the time of withdrawal: 

 

 

 

 

 

it  enables  goods  placed  on  the  market  before  the  end  of  the  transition  period  to 
continue to be further made available on the EU or UK market until they reach their 
end-user, with no need for re-certification, re-labelling or product modifications; 

it  provides  for  processes  for  managing  and  terminating  ongoing  intra-Union 
movements  of  goods,  ongoing  customs  procedures  as  well  as  VAT  and  excise  duty 
matters; 

it protects existing unitary intellectual property rights, including the existing stock of 
EU geographical indications; 

it winds down public procurement procedures  ongoing at the time of the end of the 
transition  period  and  guarantees  the  rights  of  those  concerned  by  the  procedures 
under Union law; 

it  includes  provisions  for  winding  down  ongoing  police  and  judicial  cooperation  in 
criminal matters;  

 

it  includes  provisions  for  winding  down  administrative  and  judicial  procedures  (e.g. 

28 

 
state aid and infringement cases); 

 

 

it  addresses  the  use  of  data  and  information  exchanged  before  the  end  of  the 
transition period and makes sure that data transferred before the end of transition 
period remain protected under the principles and provisions foreseen by Union law; 

it provides for the disconnection of the UK from networks, information systems and 
databases established on the basis of Union law at the end of the transition period, in 
particular those networks that are only accessible to Union Member States or the 
Schengen associated countries; 

 

it  deals  with  ongoing  judicial  cooperation  on  commercial  matters  in  order  to  make 
sure court judgements can be relied upon; 

 

it addresses all issues related to the United Kingdom’s departure from Euratom. 

With  regard  to  the  implementation  of  the  Withdrawal  Agreement,  the  Joint  Committee, 
which oversees the application of the Withdrawal Agreement, has been established. It is co-
chaired  by  European  Commission  Vice-President  Maroš  Šefčovič  and  the  UK  Chancellor  of 
the Duchy of Lancaster, the Rt Hon Michael Gove and has met twice (by teleconference), on 
30  March  and  on  12  June  2020.  The  Specialised  Committees  on  Gibraltar,  Citizens’  Rights, 
Financial  Provisions,  the  Sovereign  Base  Areas  in  Cyprus  and  the  Protocol  on  Ireland  / 
Northern Ireland have begun their work. 

29 

 
 
 
 
 
IV.  Conclusion: Readiness is key 

The  European  Union  will  do  its  utmost  to  reach  an  ambitious  future  agreement  with  the 
United Kingdom.  

However,  this  Communication  shows  that,  even  in  case  of  the  most  ambitious  future 
partnership  –  based  on  the  European  Union’s  negotiating  directives  for  a  new  partnership 
with  the  United  Kingdom,38  adopted  on  25  February  2020,  and  on  the  draft  text  of  the 
Agreement on the New Partnership between the European Union and the United Kingdom,39 
published  on  17  March  2020  –  there  will  be  far-reaching  and  automatic  changes  and 
consequences  for  citizens,  consumers,  businesses,  public  administrations,  investors, 
students and researchers, as of 1 January 2021.  

These changes are unavoidable – whatever the outcome of the ongoing negotiations  – due 
to the United Kingdom’s decision to withdraw from the  European Union, its Single Market 
and  Customs  Union.  Free  movement  of  persons,  goods  and  services  as  provided  by  Union 
law will cease to apply at the end of the transition period. This will have wide-ranging effects 
in  particular  for  cross-border  trade  of  goods  and  services,  as  well  as  for  the  mobility  of 
people.  

The Commission therefore calls on all public administrations, citizens, businesses and other 
stakeholders to make sure they are ready for those unavoidable changes. Failing to take such 
preparatory measures will increase the negative impact and cost to their operations at the 
end of the transition period.  

It is ultimately for businesses and other stakeholders to undertake their own risk assessment 
and implement their own readiness actions in light of their individual situation, but no one 
should  underestimate  the  logistical  challenges  that  will  occur  as  of  1  January  2021,  in 
addition to the legal changes described in this Communication. 

The  Commission  calls  on  Member  States  to  continue  national  communication  and 
awareness-raising  activities  encouraging  public  administrations,  citizens,  businesses  and 
stakeholders to take the necessary measures for readiness. These efforts need to be adapted 
to the  situation of  stakeholders  in  the  individual  Member States.  Over the  coming  months 
the Commission will work with all Member States in order to review their readiness for all 
aspects,  and  to  facilitate  awareness-raising  efforts  by  public  administrations  towards  their 
stakeholders. 

38 https://www.consilium.europa.eu/media/42736/st05870-ad01re03-en20.pdf 
39 Draft text of the Agreement on the New Partnership between the European Union and the United Kingdom, published on 
17 March 2020, see: https://ec.europa.eu/info/publications/draft-text-agreement-new-partnership-united-kingdom_en 

30 

 
                                                 
 
Stakeholders are also invited to re-consult the notices that were published during the Article 
50-negotiations  with  the  United  Kingdom  and  to  consult  the  Commission’s  readiness 
webpages for further updates of previous preparedness notices. The Commission will work 
with all relevant stakeholder associations to draw their attention to this information. 

Finally,  the  Commission  calls  on  all  consumer,  business  and  trade  associations,  national  as 
well as European, to make sure that their members are fully aware of the changes that will 
occur irrespective of the future relationship with the United Kingdom. 

31 

 
 
 
Annex 1: List of Updated Notices on Readiness for end of transition 
The following 59 readiness notices have been published since 16 March 2020 with a view to 
supporting stakeholder preparations for the end of the transition period. They can be found 
https://ec.europa.eu/info/european-union-and-united-kingdom-forging-new-
here: 
partnership/future-partnership/getting-ready-end-transition-period  

This list will continue to be updated on a regular basis as new notices become available. 

  Air transport 
  Animal breeding (zootechnics) 
  Animal transport 
  Asset management 
  Audiovisual media services 
  Aviation and maritime security 
  Aviation safety 
  Banking and payment services 
  Biocidal products 
  Chemicals (REACH) 
  Clinical trials 
  Company law 
  Consumer protection and passenger rights 
  Copyright 
  Cosmetic products 
  Credit rating agencies 
  Data protection 
  E-commerce 
  E-signature (electronic identification and trust services for electronic transactions) 
  Electronic communications, incl. roaming 
  Emissions trading system 
 
  EU Ecolabel 
  European Works Council 
  Excise duties 
  Exhaustion of intellectual property rights 
  Feed 
  Food law 
  Genetically-modified organisms 
  Geo-blocking 
  Geographical indications 
  Good laboratory practice (GLP) 
 

.eu domain names 

Industrial products 

32 

 
  “Invasive alien species” 
  Maritime transport 
  Medicinal products (human use, veterinary) 
  Movements of live animals 
  Natural mineral waters 
  Online purchase with subsequent parcel delivery 
  Organic products 
  Plant health 
  Plant protection products 
  Plant reproductive material 
  Plant variety rights 
  Prohibitions and restrictions of import/export (incl. import/export licenses) 
  Protection of animals at the time of killing 
  Pyrotechnic articles 
  Rail transport 
  Recreational craft and personal watercraft 
  Security of network and information systems 
  Ship recycling 
  Substances of human origin (blood, tissues and cells, organs) 
  Supplementary  protection  certificates  for  medicinal  products  and  plant  protection 

products 

  Tobacco products 
  Trade marks and designs 
  Transportable pressure equipment 
  Value Added Tax (VAT – Goods) 
  Value Added Tax (VAT – Services) 
  Waste shipments 

33 

 
 
 
 
34