Finally, after a lengthy and tumultuous campaign the votes have been returned and we have an answer to the big question - “Should the United Kingdom remain a member of the European Union or leave the European Union?” By a 52% to 48% majority the UK has voted to exit.
What does this mean for product regulatory compliance? There is a myriad of EU legislation, the aim of it being to protect our environment and our people, which governs the placing of products on the EU market and is applicable to member states, for example the WEEE Directive and the RoHS Directive. There are also EU regulations which are directly applicable in member states that do not require national transposition such as REACH, the overarching law on chemicals. With the UK now to depart, questions arise such as will there be a gap in legislation in the UK if EU Regulations are no longer applicable? Will the UK be able to continue to access the common market? If so, in what manner?
Will it be similar to the arrangement Iceland has, which is outside the EU but within the European Economic Area and enjoys free movement of goods and people, but is bound to implement much of EU law without the ability to influence it. Or could it be the Swiss model whereby the UK becomes a member of the European Free Trade Association and enters into a bilateral trade agreement with the EU.
The likelihood is that nothing much will change immediately as the general understanding is that it will take almost two years for the UK to leave the EU. The rules for exit are contained in Article 50 of the Treaty of the European Union under which the UK must first give notice to leave after which a period of negotiation will ensue to clarify the terms of withdrawal.
In the immediate term the likelihood is that there will be no immediate changes. However, the overarching question is what relationship will the UK have with the EU and what will the implications be for those accessing both markets.
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