- The U.K. has officially left the European Union, marking the start of the next phase of the Brexit process. Under the terms of the withdrawal agreement, the U.K. will remain subject to EU law until at least the end of the year, during which time the two entities will work on negotiating a trade deal that sets the terms of their future relationship.
- Trade groups including MedTech Europe want the U.K. and EU to remain aligned, thereby enabling members to benefit from the frictionless trade, unified regulatory system and health technology assessment cooperation that characterized the pre-Brexit relationship. The EU also wants a common set of rules and standards, or “level playing field.”
- Although the industry has lobbied for the departing member state to implement the Medical Device Regulation and stick close to EU rules, a minister in the U.K. government said legislative alignment “just ain't happening,” per an interview with the BBC.
On Jan. 31 at 11 p.m. local time, the U.K. ceased to be part of European institutions for the first time since its accession to a precursor of the EU in 1973. The departure is the oft-delayed consequence of the U.K.’s 2016 referendum on leaving the EU, but does not mark the end of the changes initiated by the vote. Rather, the U.K.’s exit from the EU is another milestone in an ongoing process.
As has been the case throughout the Brexit process, it is unclear what the U.K.-EU relationship will look like once all the details are agreed.
The U.K. government, its position strengthened by the big parliamentary majority won in last year’s general election, appears to be pushing for a cleaner break from the EU. Speaking on U.K. television over the weekend, Dominic Raab, the foreign secretary, said aligning with EU regulations would “defeat the point of Brexit” and that such an outcome “just ain't happening.”
Boris Johnson, the U.K. prime minister, is expected to make parallel points in an upcoming speech. In a briefing to media outlets including The Guardian, the government revealed Johnson will say there is “no need for a free trade agreement to involve accepting EU rules ... any more than the EU should be obliged to accept U.K. rules.”
Johnson’s predecessor, Theresa May, made similarly bullish statements during the previous phase of the Brexit process, only to abandon her red lines during the negotiations. The U.K. government aims to strike a trade deal consistent with Johnson’s position within months, despite Switzerland having spent years in similar negotiations with the EU without reaching an agreement. The U.K. and EU can extend the current transition period by up to two years to buy more time to reach a deal.