September 7, 2020

BREXIT 2021 – The end of ‘The Transition Period’

BREXIT 2021 – The end of ‘The Transition Period’

During Members’ Week, on 29th September, GK Strategy (the GGF’s political advisers) will host a special webinar on BREXIT 2021 – The end of ‘The Transition Period’.

Ahead of the webinar, GK Strategy has provided this update for GLASSi, on the status of the key issues that may impact business as the UK prepares to leave the European Union with or without a deal.

State of play in Brexit negotiations and what the end of the transition period with the EU will mean for business

With less than four months until the UK exits the EU Single Market and Customs Union as the agreed transition period comes to an end, it is vital that members are aware of what this exit means in practice, what are the changes you may have to make and the wider implications for trade with the EU.

Although several elements of future trade with the EU are the subject of ongoing negotiations – on which more below – several decisions have already been reached that are of particular relevance to the glass, glazing and fenestration sectors and it is important that members are familiar with them.

Import and export:

Although negotiations will determine the extent of checks on the UK-EU border, and the levels of tariffs and quotas on goods, the core framework for the new Border Operating Model (BOM) has been published. Known as the BOM, the new model will be phased in from 1st January 2021, and all businesses will be required to complete point of importation customs requirements for all goods from 1st July 2021. All businesses that import and export from the EU need to research what steps they need to take in advance of 2021. Further information is available here.

Product standards:

Product standards are still subject to negotiations, but the UK has announced plans to replace CE marking with a new UK Conformity Assessed (UKCA) mark from 2021. It is expected that the UK will accept both marks on products placed on the UK market for a time-limited period following the transition period.

Businesses should be aware that, if no agreement is reached in talks, products covered by the Construction Products Regulation (CPR) by Notified Bodies and Technical Assessment Bodies (TABs) in the UK will no longer be permitted on the EEA market.

There is also a possibility for a Mutual Recognition Agreement (MRA) with the EU and UK recognising the standardisation (and documentation) for products under the CPR. Though any such agreement has yet to be confirmed by either the UK or EU.

Please see the latest guidance on CE Marking and UKCA mark here:

Data protection and GDPR:

The UK will no longer be covered by GDPR following the conclusion of the transition period on 31st December 2020. Although the UK has transcribed the EU legislation into UK law, there is no guarantee that the EU will accept the UK’s data protection standards from 2021.

The issue of data protection is not on the table in negotiations, and the UK will be subject to a judgement by the UK Commission which will decide whether personal data can continue to flow freely from the EU to UK. The UK has already announced that this data will be allowed to move in the opposite direction after transition.

The GGF/GK Strategy will provide a update on any changes to this situation either from the EU and from the UK Commission.


Regardless of the outcome of negotiations, the UK will implement a new ‘points-based’ immigration system from 1st January 2021. Details of the new system have been known for some time and makes no distinction between EU and non-EU citizens.

You can read more details on this from the Government’s website.

Status of wider negotiations:

In the ongoing trade talks with the EU, timeframes are tight and goodwill lacking. The EU has stated that an agreement would need to be reached by the 15 October to allow for ratification by the end of the year, raising the stakes for negotiations in September. The UK would also like to have clarity on the likely outcome by this time, in order to help industry prepare for a ‘no deal’ outcome, if this is the likelihood.

Both sides have expressed frustration at the way the negotiations are being conducted. The UK have been vocal in criticising the EU’s insistence that the most contentious issues, such as state aid and environmental standards must be agreed before moving on to issues on which agreement can easily be reached. This should not come as a surprise to the UK, as this is standard practice for the EU in trade talks, but it means that very little further agreement has happened.

The UK insist that the ability to deviate on standards was an essential factor in the decision to leave the EU and claim that it is unreasonable for the EU to insist on alignment following the conclusion of the transition period. EU negotiators are adamant that UK access to the EU single market will be correlated with the degree of alignment on standards.

Both sides still insist that agreement on a Free Trade Agreement (FTA) is still possible by the October deadline, but it is difficult to imagine that this will amount to more than a thin agreement on tariffs and quotas for goods.

The GGF is continuously gathering information from the UK and EU Governments on BREXIT and translating into guidance for the sector.

On 29th September at 3.30pm, as part of Members’ Week, the GGF in conjunction with GK Strategy will be hosting the end of ‘The Transition Period’ webinar with former Cabinet Minister, David Laws, who will share his views on Brexit and open the discussion on the issues and scenarios.

Book your place at Members’ Week, BREXIT 2021 – End of ‘The Transition Period’ webinar on 29th September at 3.30pm, please click the banner below

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