EU regulations during the Brexit transition period
As we all know, the United Kingdom left the EU on January 31 in the beginning of this year. Since then, a transitional period has entered into force which will last until December 31, 2020. Although the EU legislation and regulations are still in force during this transitional period, there may still be some problems.
Requesting documents during the Brexit transitional period
In principle, the application for documents of origin (EUR.1 certificates or certificates of origin) will not change during the transitional period. Nor will there be any change to the proof of origin required for applying for these documents of origin. The fact that, during the transitional period, the UK will continue to be treated simply as an EU Member State has been communicated by the Commission to all the EU's trading partners in a 'note verbale'. If you export from the EU, no distinction will be made between parts and components coming from the UK or from an EU Member State. You can therefore still make use of the preferential duty during this period if your product originates in the UK.
However, it cannot be guaranteed that non-EU countries will still treat the UK as an EU Member State. This could mean that, when exporting to a country with which the EU has a trade agreement, UK products would no longer be considered as preferential origin and UK parts would no longer count towards the determination of this preferential origin. According to the origin protocols underlying the trade agreements, preferences can only be refused after a check has been carried out. And only if the exporting country does not provide answers to questions, or the answer is inadequate.
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