Bilaterals III: The Compliance Implications for EU-Switzerland Trade
The EU–Switzerland Bilaterals III package, signed on the 2nd of March, signals a significant update to the regulatory framework for trade and cooperation between the two partners.
For manufacturers and importers operating across the EU-Swiss border, the updates to the Mutual Recognition Agreement (MRA) and the new food safety framework may change how compliance, product certification, and market access are managed across both jurisdictions.
In this article, we explain what the agreement changes, where the compliance exposure sits, and what your business should be doing now.
Contents:
- What the bilaterals III package actually changes
- Food safety: what the new agreement means for your goods
- Medical devices: mutual recognition updated
- Conformity assessment: what changes in practice
- Why this matters for your business
- How Customs Support Group can help
What the Bilaterals III Package Actually Changes
Bilaterals III is not a single free trade agreement but a broad package designed to modernise the framework governing EU–Swiss relations.
The package updates four existing agreements, covering air transport, land transport, free movement of persons, and the mutual recognition of conformity assessments. It also introduces new agreements covering electricity market cooperation, food safety, and public health coordination.
Additional elements of the package include arrangements governing Switzerland’s participation in EU programmes, a financial contribution mechanism, and new institutional governance structures designed to stabilise the bilateral relationship over the long term.
An Important Note: The Package Is Signed but Not Yet in Force.
Although the agreement was signed on the 2nd of March, it still needs to be ratified in both countries.
On the EU side, ratification requires the consent of the European Parliament, followed by formal approval by the Council.
In Switzerland, the agreements must pass through the federal parliamentary process and may ultimately be subject to a public vote.
Until ratification completes on both sides, the current framework remains unchanged. That creates a natural preparation window for your business and trading partners – but not an indefinite one.
Food Safety: What the New Agreement Means for Your Goods
The food safety agreement establishes a common food safety area covering the entire food chain – where the previous framework only covered specific products.
In practice, this means that goods already assessed against EU food safety standards will no longer require a parallel Swiss conformity review – and vice versa – once the agreement enters into force.
The operational implications lie primarily with regulatory compliance and documentation rather than tariff classification. Where companies previously navigated parallel EU and Swiss regulatory processes, the common food safety area aims to create a more integrated framework across the entire food chain.
Businesses trading agri-food products between the EU and Switzerland may therefore need to review product compliance documentation, certification processes, and regulatory references used in customs and supply-chain documentation.
Misaligned compliance documentation does not always surface immediately. Often, gaps between regulatory status, certification records, and customs documentation only become visible during audits or regulatory checks.
Where businesses continue using documentation aligned to the previous framework, they may miss opportunities to simplify cross-border procedures or face questions during compliance reviews. To review your documentation and requirements, contact our team today.
Medical Devices: Mutual Recognition Updated
The updated Mutual Recognition Agreement brings conformity assessment arrangements back into closer alignment with current EU regulatory frameworks.
This is significant, as the MRA covers, in terms of value, approximately two thirds of industrial trade between Switzerland and the EU.
For medical device manufacturers and importers, updates to EU medical device legislation created operational friction for companies operating in both markets. The updated framework is intended to reduce this regulatory divergence and restore more predictable conditions for cooperation and certification.
Conformity Assessment: What Changes in Practice
The updated MRA covers conformity assessments across 20 product sectors, with sector-specific rules set out in its Annex.
If your goods fall within those sectors, the key change is that conformity assessment certificates issued in one market are accepted in the other without duplicative procedures. The requirement for parallel assessment in both jurisdictions falls away.
Yet, the operative word in any mutual recognition arrangement is defensibility. Customs authorities on both sides will expect documentation that correctly identifies which regulatory framework the conformity assessment was conducted under, and that the goods classification is consistent with it.
A business claiming the benefit of mutual recognition without supporting compliance documentation carries audit exposure, rather than saving time.
At the same time, Switzerland’s new formal role in contributing to EU legislation across the covered sectors means that future regulatory changes will land on both sides of the border with greater alignment.
For businesses with long-term supply chain investment in EU-Swiss trade lanes, that structural stability has commercial value. So, as we discovered in our Strategic Radar Survey, the question is whether your internal compliance infrastructure is positioned to use it.
You can check your readiness by arranging a customs compliance scan with our team.
Why This Matters for Your Business
Bilaterals III delivers legal certainty for EU-Swiss trade in food products and medical devices – allowing products certified by recognised bodies in one market to be accepted in the other market without duplicate testing.
That certainty has commercial value, but those benefits only materialise when internal compliance processes reflect the updated framework. Companies that continue relying on certification references, regulatory assumptions, or documentation aligned with earlier arrangements may not fully benefit from the improved recognition of conformity assessments.
Financial exposure does not require a deliberate error or even a customs penalty once one is discovered – inefficiency can also silently erode margins, and for a long time.
How Customs Support Group Can Help
CSG operates on both sides of the EU-Swiss border. That means the compliance review, documentation update, and defensibility audit is managed as a single end-to-end programme.
Customs Support Group provides practical assistance with:
- Product checks against the Bilaterals III regulatory framework to verify it is applied to the correct goods
- Paperwork auditing to identify documentation gaps between the previous and updated Mutual Recognition Agreement
- Origin governance review to check preferential origin claims are defensible under the new food safety and conformity assessment frameworks
- CustomsTech integration to centralise and standardise data across EU and Swiss trade flow
- End-to-end compliance management across both EU and Swiss jurisdictions from a single specialist team with offices in both territories
It all begins with a customs compliance scan, where our experts assess your EU-Swiss trade operation and return actionable insights. Contact our team today to find out where your exposure sits.
