This agreement may enter into force on 1 January 2021 if the EU-US agreement no longer applies to the United Kingdom. The EU internal market is the most comprehensive version of mutual recognition between trading partners. According to the Dijon Cassis principle, a product that can be legally sold in one Member State can be legally sold in any other Member State, even if the rules are not harmonised. For example, the European Commission`s recent free trade agreements with Canada and Korea provide for the conclusion of a compliance assessment MMA, without asking their partners to adapt their regulatory requirements to those of the EU. There are other examples of mutual recognition of the rules, including the EU-US marine equipment regulation in 2004, the Trans-Tasman Mutual Recognition Arrangement between Australia and New Zealand (TTMRA) in 1998 and the EU-Swiss MRA in 2002. The treaty provides for mutual recognition of the UK-US compliance assessment. Parties to an MRA do not need to change their technical rules and that is why the UK government is now proposing MRA for compliance assessment as part of its new trade agreements. In the context of the ongoing negotiations between the European Union and the United Kingdom on a possible BREXIT agreement, Glass for Europe wishes to stress the importance, for the good trade of stained glass and glazed products, that European harmonised technical standards remain the only regulatory benchmark in the United Kingdom. For the European flat glass sector, it is also essential that third-party assessment systems, i.e.
notified bodies, remain coordinated, including notification procedures. It is only when these two conditions are met that a mutual recognition agreement can be concluded to prevent trade barriers. It is essential that “traditional” MRA does not require states to harmonize the rules (i.e. establishing technical standards and common rules) and do not require parties to one MRA to recognize each other`s requirements as equivalent – MRA is limited to the recognition of the partner`s CAB`s responsibility for assessing compliance. Although there has been little progress in accession negotiations, Turkey has gradually expanded its legislation on EU legislation to remove technical barriers. The results of THE CAB tests notified by Turkey are mutually recognised in the EU (and vice versa). However, recent free trade agreements indicate a change in approach and acceptance of “traditional” MMAs. For example, Article 4.6 and Article 7.21, paragraph 4, of the EU-Korea Free Trade Agreement provide for the negotiation of mutual recognition of the assessment of the compliance of goods and services.