Mutual Recognition Agreements (MRAs)

Mutual Recognition Agreements or ‘MRAs’ are agreements between two countries to recognise the other’s standards. This means that manufacturers only need a product to be certified by the domestic standard and the trading partner will accept this.  For this to work it is important that the two sets of standards are sufficiently similar, if not actually identical.  MRAs can apply to services as well as goods, for instance there are many professional qualifications that have equivalence in other countries.

An example of an MRA would be that between Australia and the EU.  This includes veterinary medicines and those produced to the required standards of the EU or Australia can be traded with the other without need for additional testing.

There are benefits to both parties, typically MRAs take cost out of the system, for instance by eliminating the need for duplicative testing – particularly important in sectors where the lifecycle of a product is short, such as telecoms.  Other benefits are the sharing of best practice amongst laboratories, certification bodies and manufacturers.

In preparation for leaving the EU the UK has signed a number of MRAs with non-EU countries including the US, Australia and New Zealand.  These will will roll-over the relevant areas of the US-EU MRS so that where a particular standard is acceptable now, it will continue to be acceptable in future.

Currently the UK does not have any MRAs with the EU because it does not need them:  the UK is working to the same standards and certification from UK bodies is automatically recognised.  However when the UK leaves the EU it will no longer be bound by EU legislation and could be expected to fall back on some MRAs instead.

A UK-EU MRA is a contentious issue though.  The UK wants to regain control over standards and regulations so that it can make changes or diverge from the EU position in future and instead rely on MRAs to have these standards recognised automatically by the EU.  Clearly however the EU are wary that the UK seeks to maintain unfettered access to the single market whilst diverging from the EU’s standards.