Pregunta Parlamentaria (UE) de Geert Bourgeois: El Informe titulado "The Benefits of Brexit"

 

• 15 DE FEBRERO DE 2022 -  [P-000659/2022][*]

El Gobierno del Reino Unido ha publicado un informe titulado ‘The Benefits of Brexit'. Si bien establece pocas medidas específicas, anuncia la ambición de convertirse en una superpotencia científica en los campos de la tecnología cuántica, la IA, los medicamentos, etcétera.

Está planeando lograrlo, por un lado, alejándose de las normas de la UE (regulación financiera, ensayos clínicos, subsidios agrícolas, contratación pública, legislación de datos, etcétera) y, por el otro, tomando la iniciativa en el establecimiento de estándares y comprometiendo en sectores emergentes no sujetos a regulación, como la edición del genoma, la IA, etcétera.

1. ¿Ha analizado la Comisión este informe en detalle o tiene previsto hacerlo?

2. ¿Qué propuestas constructivas contenidas en el informe tratará de aplicar la propia Comisión para garantizar la competitividad de la UE?

3. ¿Advierte la Comisión alguna amenaza para la competitividad de la UE?

 

Respuesta de la Presidenta von der Leyen en nombre de la Comisión Europea (12 de abril de 2022):

«1. El Acuerdo de Comercio y Cooperación entre la UE y el Reino Unido está diseñado para proteger los intereses comunes de ambas partes y garantizar una competencia leal al incluir disposiciones para garantizar la igualdad de condiciones, en particular en lo que respecta al control de subsidios, impuestos, normativas laborales y sociales, así como como el medio ambiente y el clima.

Para garantizar el respeto de estas disposiciones, la Comisión, junto con la Delegación de la Unión Europea en el Reino Unido, supervisa la evolución de la legislación del Reino Unido junto con los cambios legislativos en el Reino Unido. La Comisión ha analizado detalladamente el informe al que se refiere Su Señoría. Cabe señalar que algunas de las áreas cubiertas por el informe, como la inteligencia artificial, van más allá del ámbito de aplicación del Acuerdo de Comercio y Cooperación.

2. Si bien las reformas llevadas a cabo por terceros países pueden servir de inspiración para nuestras políticas, la UE desarrolla su competitividad siguiendo su propia agenda proactiva, liderando el camino en la transición energética, asegurando una UE apta para la era digital y defendiendo un comercio dinámico, abierto y justo, el multilateralismo y un orden global basado en reglas, entre otras prioridades.

3. Si bien el Reino Unido es libre de decidir su política regulatoria, sigue sujeto a sus obligaciones en virtud del Acuerdo de Comercio y Cooperación y el Acuerdo de Retiro. La Comisión se mantiene alerta para garantizar que las empresas de la UE no sufran una desventaja competitiva desleal.».

 

El Informe puede consultarse en: 

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1054643/benefits-of-brexit.pdf

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[*] Traducción no oficial. Lengua original: holandés.

 

Food shortages, stockpiling and panic buying ahead of Brexit as reported by the British media: a mixed methods content analysis

 Authors: Paul C. Coleman (Honorary Research Fellow), Fatima Dhaif (Academic Clinical Fellow) and Oyinlola Oyebode (Assistant Professor)

https://app.box.com/s/xda442zjoh1fe92zcwayempfzb2pvfbz

ABSTRACT

Background - Government documents warn that if the UK and EU have not negotiated a trade deal by 31 December 2020 the UK could experience increasedfood prices and possible food shortages.

The media have an important role in influencing recipients’ behaviour by promoting reassurance or anxiety on this issue. This study examines how food supply and demand, in the context of Brexit, has been portrayed by the British media.

Methods - A mixed methods content analysis of articles reporting on food supply and demand in the context of Brexit, in three daily newspapers, between 01 January 2015 and 31 January 2020.

Results – Five themes emerged: food shortages and panic buying (appearing in 96% of articles); food supply chain disruption (86%); economic impacts of Brexit (80%); preparation and stockpiling by the government and food sector (63%) and preparation and stockpiling by individuals (22%).

Conclusion - Government messaging reported by the media sought to reassure the public that here will be no food shortages under a no-deal Brexit. These reassurances contradicted warnings from the food sector and leaked government reports of reduced availability of food items.

 

These 20contradictory messages may have undermined trust in the government, potentially influencing stockpiling behaviour at the individual level.

[This paper is under peer-review].

📰 Legal NewsBITE: Food and Drink Quarterly (September 2019)

● Let Them Eat Cake (If We Coordinate) Will UK Government Waive Competition Rules in Response to Food/Drink Shortages? ● New Legislation on Allergen Information Published ● Changes to Immigration Rules ● Philadelphia Ad Banned in UK Following New Rule Against Harmful Gender Stereotypes ● Brexit Readiness and Retailer Contracts ● Cannabidiol (CBD) in Food and Drink Products ● Sector Deals A Round-up of Recent M&A Activity ● Delivery Vehicles Focus on Bridge Strikes

See: https://www.squirepattonboggs.com/~/media/files/insights/publications/2019/09/legal-newsbite-food-and-drink-quarterly/legalnewsbitefoodanddrinkquarterlyseptembernewsletter.pdf

Información facilitada por el

Scotland's food and drink: preparing for Brexit

Scotland's food and drink sector, like many others, faces continued uncertainty as the Brexit debate rolls on. The extension agreed until 31 October 2019 means that one cliff-edge has been avoided, but you cannot bet against businesses again facing the prospect of a no deal Brexit in a few months' time. In the meantime there is little clear advice about how businesses can prepare for selling their produce in the EU, an unsatisfactory position for a sector which needs to plan ahead in relation to production, packaging and sales.

There are many issues, but an obvious one is what should go on labels if and when the UK eventually leaves the EU. Although the UK government is emphasising that it will encourage pragmatic enforcement of food labelling rules and that there will be a transition period wherever possible, the EU's approach will depend on whether a deal which addresses labelling issues is agreed before 31 October 2019 (or by any further extension).

One basic but key question is what address(es) to put on the label of a food product. Currently, in order to legally sell pre-packaged products in the EU, you must place the name and address of a "food business operator" on the label. This is the operator under whose name or business name the food is marketed or, if that operator is not established in the EU, the importer into the EU. 

At the moment, this requirement can easily be met by using a UK address. In order to export food to the EU following a no deal Brexit, UK businesses will still have to comply with this mandatory requirement of EU law. It will no longer be enough to include only a UK name and address on the label.

Identifying which EU address to put on the label in this scenario may not be obvious and may depend on how your business and route to market is structured. If you have an existing EU hub for importation and distribution (for example, your own subsidiary or a single importer/distributor in the EU) it may be straightforward to use that company's address. If not, UK government advice is that businesses may need to consider a single hub or importer.

However, many businesses do not operate on the basis of a single EU hub or importer. Goods may enter continental Europe in different ways. Different addresses on labels for each importer may be the clear way to achieve compliance, but may not be practical or desirable for many reasons, including provenance.

A single address (which could be a newly incorporated company or existing subsidiary in an EU Member State), which ensures that consumers and authorities in the EU have an appropriate point of contact in relation to the product, would seem to be a pragmatic and low-risk approach which meets the aim of the relevant food information rules.

However, the reaction of the enforcing authorities across the EU and at customs cannot confidently be predicted. Enforcement of the mandatory food information rules is left to individual Member States. Penalties can be applied for failing to comply with mandatory food information. Currently in Scotland, for example, a person is guilty of an offence for failing to display a mandatory name and address and can be fined up to £5,000. In England and Wales, improvement notices can be used requiring the label to be changed. It is an offence to fail to comply with those notices. Other Member States will have their own rules and enforcement priorities. One might expect enforcement to focus on issues most likely to cause consumer harm, such as incorrect ingredients, rather than a more technical breach in relation to which address should appear on a label.

To complicate matters further, businesses will have to place a UK address on the products in order legally to sell pre-packaged products in the UK. This means that many products will require two addresses, in order to be sold in both the UK and the EU.

Businesses have also expressed concern in relation to the additional cost and burden the following labelling changes will have if the UK exits with no deal:

• Country of origin labels – Food or ingredients produced in the UK following a no deal Brexit could no longer be labelled as of "EU" origin. Businesses would need to change this to "UK" origin for sale in the UK or "non-EU" for certain products to be sold in the EU. Products with the UK mark cannot be sold in the UK until the UK has officially left the EU, although there will be a transition period.
• Products protected by geographical indications (GI) – There are currently 86 UK GI, with 15 relating to Scottish products, for example Arbroath smokie, Scotch whisky and Stornoway black pudding. These will continue to be protected in the UK. However, it is less clear whether they will also continue to receive protection in the EU. In the worst case scenario fresh applications to the EU may be required to be submitted. The EU logo for products protected by GI will also need to be replaced with a UK one. The transition period for this UK requirement is currently proposed by the UK government to be until 2022.
• Packaging of meat, fish and dairy – If you are a producer of fish, meat and/or dairy, the current health/indication mark required by EU law may need to be changed. The current oval shape and the approval number will stay the same; however, the use of "EU" will no longer be correct. You cannot use packaging with the UK mark on it prior to Brexit and there will be no phasing in of the change.

Clearly there may be a range of issues depending on the products, many of which have specific and detailed EU rules with which to comply. The recent political developments may raise hopes that a pragmatic way forward can still be found which avoids a no deal and minimises the impact of Brexit on Scotland's food and drink sector. Adopting the Withdrawal Agreement would mean no changes to labelling are necessary until the end of the agreed transition period (and potentially beyond that if the terms of a deal on the UK's future relationship with the EU so permit). However, until a deal is finally concluded businesses have no option but to continue with their contingency planning.

Melanie Martin and Michael Dean

W

UK government offers no-deal Brexit advice to food companies

The UK government has issued advice to the country's food producers in the event of the country leaving the EU on 29 March without a trade deal.

The Government's guidance covers areas such as importing and exporting, food labelling, marketing standards and employing EU nationals.

The advice was published today (13 March), following the vote in the House of Commons last night in which UK Prime Minister Theresa May's Withdrawal Bill was defeated by 149 votes. The defeat makes a no-deal Brexit a real possibility.

The guidance on importing and exporting includes prompting businesses to get a UK Economic Operator Registration and Identification (EORI) number so they can continue to import or export goods and apply for authorisations.

The Government also advises businesses decide if they want to hire an import-export agent, or make the declarations themselves. It suggests companies contact the organisation that moves their goods (for example, a haulage firm) to find out what information they need to make the declarations for those goods, or if they will need to make them themselves.

On labelling, the Government says the rules for what producers must show on food labels will change for some food and drink products if the UK leaves the EU without a deal.

The changes include country-of-origin labelling, food business operator (FBO) address labelling, use of the EU emblem, use of the EU health and identification marks, use of the EU organic logo and use of the geographical indication (GI) logo.

On marketing standards it advises some of the processes food producers follow will change if the UK leaves the EU without a deal. Products that may be subject to changes include fruits and vegetables, beef and veal, eggs and poultry meat.

On employing EU workers, the Government guides that if the UK leaves the EU without a deal, citizens from the bloc who are resident in the UK before 29 March 2019 will be able to apply to the EU Settlement Scheme to get settled or pre-settled status, which will mean they can continue to live, work and study in the UK.

If the UK leaves the EU without a deal, there will be a new process for EU citizens arriving in the UK before 31 December 2020. From 1 January 2021, a new skills-based immigration system will launch.

https://www.just-food.com/news/uk-government-offers-no-deal-brexit-advice-to-food-companies_id141131.aspx

Brexit - Litigation Risk for the Food and Beverage Industry?

AUTHOR(S): Michael Finn Partner – Dublin michael.finn@matheson.com

PRACTICE AREA GROUP: Commercial Litigation and Dispute Resolution, Food and Beverage

The food and beverage industry, Ireland’s largest indigenous sector, is currently facing into an unprecedented challenge with the UK’s imminent departure from the EU. The UK market is by far the most important export market for this sector with an export value of €4.4 billion (1). The precise impact Brexit will have, and the opportunities it may present, is unclear..

The withdrawal agreement (2) envisages specific provisions for the food and beverage industry at the time of the UK’s exit from the EU, but this, of course, is subject to that agreement being adopted.

As is well publicised, Ireland’s food and beverage industry has been contingency planning for some time in the event that the withdrawal agreement is not adopted. Notwithstanding these contingency plans, there is an increased litigation and regulatory risk for this sector as a direct result of Brexit. For example, the sector may be facing an increased risk of contractual disputes between supply chain partners or logistics service providers as a result of delays at custom points.  For those in the industry whose contingency plans involve the stockpiling of certain essential goods or materials, there is an increased risk of disputes with insurers (aside from the increased exposure to theft or fraud) in the event that insurance cover is not increased to take account of the additional stock and there is a loss. Directors and officers should also bear in mind that they are at increased risk of potential litigation from shareholders stemming from the level of contingency planning for Brexit.

There is also exposure to potential disputes or regulatory investigations over compliance with the post-Brexit regulatory requirements in the UK.

What happens in the event of no-deal?

The UK government has published a number of technical notices to UK food and beverage producers which provide guidance in the event of a “no-deal” scenario. While these notices are addressed to UK producers, they do however offer some guidance for Irish producers.

The key areas focused on in these notices are:

• geographical indications (“GI”);
• export and import of animal products;
• labelling; and
• tariffs and customs duties.

GI

A GI is a sign or labelling placed on products that have a specific geographical origin and as a result possess certain qualities, characteristics, or reputation attributable to that particular place.  A notice published on 5 February 2019 (3) indicates that the UK will have its own GI scheme that will mirror that in the EU, ie using the same classes provided by the EU scheme.  UK producers will have three years to comply with the UK GI logo scheme.  The notice states that Irish whiskey, cream and poteen produced in Ireland will have EU and UK GI protection and will not be required to apply for further protection.  UK producers will have to reapply to the European Commission in order to regain EU protection and the right to use the EU GI logo.

Export and Import of Animal Products

The UK Government has stated that in the event of a “no-deal” withdrawal, the health and identification marks required on the labelling of animal products produced in the UK must be updated, removing EU references (4).

Labelling

Unless the EU and the UK reach an agreements in advance of 29 March 2019 whereby both recognise each other’s standards, the EU emblem must be removed from products produced in the UK, and the EU organic logo must be removed on organic products produced in the UK.  References will also need to be removed from all food and beverage labels, including products where some ingredients are made in EU countries (5).

The food and beverage industry will also have to consider any UK legislation that is enacted in relation to labelling and whether current EU labels would be compliant.  If the UK enacts legislation that is not in compliance with EU laws, and further if current EU compliant labels are prohibited by such legislation, producers will have to modify labelling of products being sold in the UK market.

Any product that have been placed in the UK market on or before 29 March 2019 will be acceptable to be sold until those stocks are exhausted, regardless of whether the labelling complied with UK legislation.  The European Commission has published guidance in relation to the concept of goods placed on the market prior to the withdrawal date (6).  This publication also offers guidance in relation to considering whether goods will be subject to the payment of imports and export tariffs and duties.

Tariffs & Custom Duties

The UK Government also states (7) that customs and excise duties, and declarations that apply currently between the UK and non-EU countries will cease to apply between the UK and the EU from 30 March 2019.  Trade will therefore be on the default World Trade Organisation terms, which are often significant for food and drinks products.   The WTO's "most favoured nation" rule provides that the UK cannot simply lower these tariffs for the EU, or any other specific countries, unless it agrees a trade deal with that country.  For UK food and beverage producers exporting to the EU, the tariffs will be on average 35.9% on dairy products, 15.5% on animal products, and 21.1% on sugars and confectionary.  Lower tariff rates are set on cereals, fish, and fruit and vegetables (8).

There will be further logistical difficulties in the event of a “no-deal” Brexit, when exports and imports will be required to cross border control points and deal with further administrative burdens.  On top of the payment of VAT, customs and tariffs, and paperwork requirements, product checks such as veterinary checks will have to be carried out.  It is also possible that Irish cargo travelling through the UK by land, on the way to the EU, will have to go through two custom controls, when entering the UK and when leaving the UK to enter the EU. This will greatly increase the cost and time for importing and exporting food and drink produce, especially as such delays will impact the short shelf life of these products.

What happens in the event of a negotiated exit?

In the event that the UK does ratify a withdrawal agreement prior to 29 March 2019, there is likely to be a transition period during which the laws of the EU will still apply to the UK.  This would likely be the best possible outcome for the industry.  This transition period may be in place until 31 December 2020, and may be extended further.  During this period EU law will apply to and in the UK.  Further, if a backstop is agreed upon, a single customs territory between the EU and the UK will be created during the transition period, which shall apply until an agreement has been reached following 31 December 2020.  If no such agreement can be reached, the provisions set out in the withdrawal agreement shall apply following the termination of the transition period.

For the food and beverage industry this means that the current status quo will be maintained, and it will not be until 2021 when changes will be seen in relation to food and drink legislation and labelling, and customs and excise duties.

The Irish Government has published a contingency plan in the event of a “no-deal” Brexit, in the form of a Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Bill 2019, and a Brexit Contingency Action Plan (9).  The Bill provides for amendments to existing legislation that will be required in the event of a “no-deal” Brexit.  The contingency plan offers some guidance to Irish citizens and industries, and sets out steps being taken by the Irish Government that are relevant to the food and drinks industry.

For example, the Government is increasing staffing and ICT systems in Revenue and at ports and airports, including veterinary staff, to ensure that any necessary infrastructure will be in place and operational by 29 March 2019 in order to reduce delays expected as a result of import and export controls.  The Government is also considering the disruption to the so-called land bridge that is used by Irish importers and exporters to transport goods through the UK to international markets, and locating new routes that could be used following Brexit.  Further, the EU has confirmed that the UK can join the Common Transit Convention.  This reduces the requirement for additional customs checks for goods passing through one country on the way to their final destination in another.  This will hopefully enable Irish carriers to continue using the UK as a route to continental Europe, and offers some certainty for carriers focused on this route.

Summary 

Whether the UK will leave the EU on 29 March 2019 and be it with or without a withdrawal agreement, or whether the Brexit process will be extended, remains uncertain.  However, it is clear that the impact of any of these scenarios will be felt by the Food and Beverage industry.  This will be seen in all aspects of production and trade from ingredients, labelling, distribution and customs checks, insurance and the payment of tariffs and excise duties.  Certainly, the ratification of a withdrawal agreement would provide certainty.  However, the food and beverage industry should be prepared in either event, to adjust current trading patterns, plan for increased costs, consider potential UK legislation regarding packaging and labelling, and also potential litigation as a result.

This article was co-authored by Senior Associate, Aoife McCluskey.

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1. “Brexit – the challenge for the food and drink sector” https://www.fooddrinkireland.ie/Sectors/FDI/FDI.nsf/vPages/Key_pillars~brexit/$file/Brexit+-+the+challenge+for+the+food+and+drink+sector.pdf
2. https://ec.europa.eu/commission/sites/beta-political/files/draft_withdrawal_agreement_0.pdf
3. https://www.gov.uk/guidance/protecting-food-and-drink-names-if-theres-no-brexit-deal
4. https://www.gov.uk/government/publications/importing-animals-and-animal-products-if-theres-no-brexit-deal/importing-animals-and-animal-products-if-theres-no-brexit-deal
5. https://www.gov.uk/government/publications/producing-and-labelling-food-if-theres-no-brexit-deal/producing-and-labelling-food-if-theres-no-brexit-deal
6. https://ec.europa.eu/info/sites/info/files/qa_brexit_industrial_products_en.pdf
7. https://www.gov.uk/government/publications/trading-with-the-eu-if-theres-no-brexit-deal/trading-with-the-eu-if-theres-no-brexit-deal
8. https://www.wto.org/english/res_e/booksp_e/tariff_profiles18_e.pdf
9. https://www.dfa.ie/media/dfa/eu/brexit/brexitcontingency/No-Deal-Brexit-Contingency-Action-Plan-December-

No-deal Brexit threat: Gove admits ‘no absolute guarantee’ food trade with EU will continue

Food Navigator.com [William Reed] News & Analysis on Food & Beverage Development - Europe

By Katy Askew

The UK has said it will extend the deadline on some food policy consultations as Environment Secretary Michael Gove admits a no-deal exit from the EU could see an immediate halt to food trade with the bloc.

https://www.foodnavigator.com/News/Policy/No-deal-Brexit-threat-Gove-admits-no-absolute-guarantee-food-trade-with-EU-will-continue?utm_source=copyright&utm_medium=OnSite&utm_campaign=copyright


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No-Deal Brexit Does Not Have to Mean Non-Compliance for Your Products

by Raminta Dereskeviciute, Clare Reynolds

18 February 2019

With less than six weeks left to the 29 March deadline - and little political consensus, the possibility of a ‘no-deal’ Brexit and the UK crashing out of the customs union and becoming a ‘third country’ increases. If your business manufactures, exports or imports, distributes, or otherwise deals in consumer or industrial products in the UK or the EU, you may need to take steps now to ensure that your products remain compliant under applicable UK and EU law in the event of a no-deal Brexit.

The requirements for placing products on the UK and EU markets (including conformity assessments, marking and labelling) will change overnight unless a deal transitional arrangements or otherwise an extension is agreed before the 29 March deadline. In case of a ‘no-deal’ scenario, the following issues in particular may need to be addressed in respect of product trading in the EU or the UK post-Brexit:

CE marking and conformity assessment - EU market: 

The consequences of the UK’s withdrawal for trading within the EU-27 will depend upon the particular product type and specific conformity assessment procedure, and importantly, whether that product was placed on the EU-27 market before the withdrawal date. Products not placed on the EU-27 market before this date may need to be re-certified, re-labelled or modified in order to trade within the EU post withdrawal. 

In particular, for products where the applicable conformity assessment procedures require intervention by a notified body, UK notified bodies will lose their status as EU recognised bodies. Unless such products have been placed on the EU-27 market before the withdrawal date, the European Commission advises operators to consider obtaining a new certificate from (or arrange for a transfer of the certificate to) an EU recognised notified body. How this works in practice will depend on the specific conformity assessment procedure for the applicable product,although the European Commission advises that any transfer of certificates would need to take place before the withdrawal date.

Where manufacturers place a CE mark on products on the basis of a self-declaration that the product is compliant, this declaration will remain valid when exporting to the EU. 

CE marking and conformity assessment - UK market: 

Goods already placed on the UK market by 29 March 2019 can continue to be lawfully circulated on the UK market. For goods placed on the market after the withdrawal date, the UK Government has unveiled a new logo to replace the CE mark in the UK, dubbed the “UKCA” (“UK Conformity Assessed”), which would require companies to change their product packaging, advertising and labelling at additional cost for manufacturers. Goods made in the UK for export to the EU may need to be stamped with both the CE and UKCA marks. There is still a lot of uncertainty about how the UKCA will work in practice; whilst the government may in time grant concessions to industry, significant disruption for businesses is inevitable.

Economic operators established in the EU: 

UK-based importers and manufacturers will no longer be considered as “economic operators established in the Union” under the EU’s product legislation following Brexit. For products entering the EU post Brexit, EU distributors who previously relied on UK economic operators will become “importers” for the purposes of EU law when making the products available on the EU market for the first time. This will require them to meet more stringent obligations in relation to product compliance. For example, EU legislation generally requires the contact details of the importer or manufacturer to be provided on the product itself or its label, which may need to be updated where this previously referred to a UK-based party.

Authorised representatives and responsible persons: 

Certain EU product legislation requires the appointment of an authorised representative (e.g. medical devices, marine equipment) or a responsible person (e.g. cosmetic products) within the EU. Post-withdrawal, UK-based authorised representatives or responsible persons will not be recognised as such in the EU. As a result, manufacturers must take steps to ensure that their designated representatives or responsible persons are established in one of the remaining EU Member States and that appropriate notification is carried out in relation to such legal entity change. 

Product specific regimes and requirements: 

Several product sectors - Automotive, Aerospace, Pharmaceutical Products, Medical Devices, Batteries, Chemicals, etc and non-harmonised goods subject to national regulations - are subject to specific regimes and requirements. Each regime will have to be assessed for specific changes in order to ensure uninterrupted trade. For example, we have recently advised a number of chemicals manufacturers and traders on transferring UK REACH registrations to the EU, which can be time consuming if a new entity needs to be established. We recommend that businesses seek advice on the available options as soon as possible, as it may take time to implement any necessary changes. 

K&L Gates can advise on the full spectrum of EU product compliance matters to help your business prepare contingency plans for Brexit. We also have lawyers who can help manage Brexit concerns in relation to: Trade & Tariffs, State Aid & Merger Clearance, Intellectual Property, Commercial Contracts, the Workforce, and Travel. 

Contacts

• Raminta Dereskeviciute
  P +44.(0)20.7360.8264
  raminta.dereskeviciute@klgates.com
• Clare Reynolds
  P +44.(0)20.7360.8184
  Clare.Reynolds@klgates.com

http://www.klgates.com/no-deal-brexit-does-not-have-to-mean-non-compliance-for-your-products-02-15-2019/