Citizens' rights & Traveling
Existing residence rights arising from the Withdrawal Agreement will be maintained for the United Kingdom (UK) citizens who legally resided in the territory of the Czech Republic before 31 December 2020, as well as for their family members. Legal residence can be proven primarily through a certificate of temporary residence, or permanent residence permit issued for the UK citizens before 1 February 2020, or a residence document issued after 1 February 2020 in the same format, with an "EU Withdrawal Agreement" stamp on page 2 for a temporary residence certificate and on page 4 for a permanent residence permit.
For those residing legally, it is possible to submit the application for a temporary or permanent residence certificate even after 1 January 2021. However, a longer examination process of these applications can be expected due to the need for a more detailed evidence to prevent the abuse of rights and fraud, and higher degree of discretion in case of application deficiencies.
The Ministry of the Interior is currently preparing a necessary legislation on issuing respective certificates of residence that will prove the rights under the Withdrawal Agreement after the end of the transition period.
UK citizens who have travelled or will travel to the Czech Republic for the first time after 31 December 2020 fall into the third country citizens’ category. For stays in the territory of the Czech Republic exceeding 90 days, the UK citizens will have to request long-term visa or long-term residence permitat a diplomatic mission of the Czech Republic. The Czech Republic started accepting applications for long-term permit residence from UK citizens on 1 January 2021. The UK citizens are entitled to submit the long-term residence applications at all diplomatic missions of the Czech Republic abroad, i.e. the applications can be submitted not only through the Czech embassy in London, but also at other diplomatic embassies of the Czech Republic within the EU, e.g. in Berlin, Brussels, Bucharest, Dublin, Sofia, Warsaw, Vienna or Zagreb.
As far as short-term stays not exceeding 90 days during any 180-days period are concerned, UK citizens will be obliged to apply for a Schengen visa only if they travel to the territory of the Czech Republic for the purpose of work. The above mentioned period includes stay in both the Czech Republic and other countries of the Schengen area.
As from 1 January 2021, UK nationals and British citizens benefitting from the Withdrawal Agreement may not undergo border checks at the designated EU/EEA/CH checkpoints. They may neither use the easyGO system for automatic border control.
The border checkpoints are sufficiently staffed, nevertheless, longer waiting times in the checkpoints queues can be expected with regard to the scheduled flights. Another factor which will prolong the waiting time is the thorough border check procedure of nationals within the meaning of Article 8(3) of the Regulation of the European Parliament and the Council 2016/399 (Schengen Border Code) which includes more operations.
In the future, UK citizens will be subject to the registration procedure in the Entry/Exit System (EES) and the obligation to hold a travel authorisation obtained through the European Information and Authorisation System (ETIAS). However, it will not apply to those benefitting from the Withdrawal Agreement - they will be outside the scope of EES and ETIAS.
If you are planning to bring some food with you, please, see also the question “Are there any restrictions as regards the import of animal products from the UK to the EU for personal consumption?”
UK citizens who prove that, before 31 December 2020, they: 1) applied for a temporary or permanent residence certificate, 2) studied at a university in the Czech Republic or 3) were employed in the Czech Republic and are not yet holders of the permanent or temporary residence certificate, they can travel to the Czech Republic under the visa-free regime on the basis of a certificate issued by the Ministry of Foreign Affairs in accordance with the current epidemiologic measure of the Ministry of Health.
Within its coordination on temporary travel restrictions from third countries to the EU+ and taking into account the unfavourable epidemic situation in the UK, the EU decided not to list the UK as a safe country from epidemiologic point of view after 1 January 2021. Persons who are not holders of a residence permit or do not fall within the exemptions will be unable to travel to the Czech Republic at all. here.
From 1 January 2021, you can use UK driving licence in the Czech Republic for driving motor vehicle, it complies with the models set in the Conventions on Road Traffic (Vienna 1968, Geneva 1949) – learn more at this article on driving licences. Generally, this include photocard driving licence issued since July 1998.
You can find detailed information in the Ministry of Transport's article.
If you are visiting UKyou can drive on you valid Czech licence. If you are driving with you vehicle, do not forget an insurance „green card“ as a proof of insurance in the Czech Republic.
If you are resident of Great Britain, you can drive on your Czech licence until you are 70. If you were 67 or older when you became a resident, you can drive on your Czech licence for 3 years after that point. You can exchange your EU licence for a GB licence after this time or when you cannot drive on it anymore. In Northern Ireland, there is no age limit, you can drive on your valid Czech licence, or you can exchange the licence for a NI one to show your new details.
Díky dohodě o vystoupení mezi EU a UK je status pobytu občanů ČR, kteří přišli do Spojeného království před koncem přechodného období (tj. před 31. 12. 2020) chráněn a tito občané a jejich rodinní příslušníci mohou požádat o nový status pobytu podle právních předpisů Spojeného království v oblasti přistěhovalectví. Za tímto účelem zřídila vláda UK system registrace pobytu občanů EU “EU Settlement Scheme”, který rovněž vychází z dohody o vystoupení.
Pokud žádost v systému EUSS nepodáte před stanovenou lhůtou 30. června 2021, může být Váš budoucí pobyt ve Spojeném království protiprávní. Více informací získáte na stránkách české ambasády v Londýně.
Cestovat do UK na platný občanský průkaz budou Češi moct do 30. 9. 2021. Proto doporučujeme vyřídit si cestovní pas co nejdříve. Pro držitele statusu Settled Status/Pre-Settled Status bude možné občanský průkaz využít do 31. 12. 2025. Více informací naleznete HERE.
Pokud občan přicestuje do UK po 31. 12. 2020 a nebude se jednat o krátkodobý turistický pobyt, bude muset předem zažádat o povolení k pobytu podle nových imigračních pravidel, která budou zavedena od 1. 1. roku 2021. Více informací o cestách do UK po 1. 1. 2021 naleznete HERE.
Obecnou informaci o novém bodovém migračním systému, který bude platit od 1. ledna 2021, naleznete HERE.
Pokud jde o ochranu osobních údajů, nová dohoda mezi Evropskou unií a Spojeným královstvím obsahuje přechodné ustanovení, které umožňuje po následujících nejvýše šest měsíců přenos osobních údajů z Evropské unie do Spojeného království, pokud nedojde k podstatné změně platných britských předpisů, a to do doby přijetí rozhodnutí Evropské komise o odpovídající ochraně osobních údajů ve Spojeném království. Po tuto dobu se přenosy osobních údajů do Spojeného království nepovažují za přenosy do třetích zemí a nevztahují se tedy na ně příslušná omezení plynoucí zejména z nařízení 2016/679/EU (GDPR). Situace pro správce a zpracovatele osobních údajů se tedy momentálně nemění. Ochrana osobních údajů v UK je tímto zmražením vnitrostátních předpisů po přechodnou dobu zajištěna v zásadě na dosavadní, evropské, úrovni.
Study & Scientific Research
The change will apply for the calls announced under the Erasmus + 2021-2027 programming period. The UK will fully participate in the Erasmus+ programme until the end of the current programming period, which means that EU students can study, do traineeships or volunteer in the UK under the current Erasmus+ programme in the academic year 2022/2023, according to individual agreements concluded by the sending higher education institutions. Please check this information with the sending institution.
From 1 January 2021, new visa requirements apply to EU students and a new points immigration system is introduced. To arrive in the UK, students must meet certain requirements. In order to obtain a student visa, they will need to achieve 70 points in the new system. A visa can be applied for at the earliest 6 months before the planned start of the study. Students who come to the UK and who want to stay in the UK for more than 6 monthsmust apply for a student visaIt will be possible to apply for a student visa up to 6 months before the planned start of the course/study program in 2021. The visa application fee is GBP 348, and it is also necessary to pay additional health insurance - more information can be found here: https://www.gov.uk/healthcare-immigration-application/how-much-pay.
Students from the EU/EFTA who come to the UK and want to stay in the UK for up to 6 monthswill be visa-freeMore information is available here:It is recommended that sending organizations in the EU countries refer students to the need to follow
Více k podmínkám studia v UK naleznete HERE.
The UK government has published a statement on a new
For more informartion follow Ministry of Education's article on the future of Erasmus programme
Zahraniční studenti ve Velké Británii mohou pracovat, pokud studují prezenční formu studia na vysokých školách.
Zákonný počet pracovních hodin závisí na úrovni kurzu, resp. konkrétním programu:
- krátkodobé studium, včetně typu distančního vzdělávání/part-time study, neumožňuje pracovat,
- studenti, kteří např. studují kurz anglického jazyka (nižní úroveň – nejedná se o studijní program zakončený titulem) a mají studentská víza, mohou pracovat maximálně na částečný úvazek 10 hodin týdně (a na plný úvazek během prázdnin),
- studenti studující akademický studijní program (jedná se také o krátkodobé pobyty) na vysoké škole mohou pracovat na částečný úvazek maximálně 20 hodin týdně.
British researchers who resided in the Czech Republic before the end of the transitional period (until December 31st, 2020) will have all rights guaranteed even if they decide to stay in the Czech Republic. However, to avoid complicated administrative procedures in the future, we recommend that they apply for a temporary residence certificate permit.
Although a temporary residence certificate is not a condition for a UK citizen to stay in the Czech Republic today, this document proves that the holder is a UK citizen who resided in the Czech Republic before the UK left the EU or during the transitional period. If these researchers have lived in the Czech Republic for more than five years and still want to reside in the Czech Republic after a transitional period, they should apply for a permanent residence permit..
In case British researchers come to the Czech Republic after the January 1st, 2021 with the intent of staying for more than three months, they shall be subject to the rules for third-country citizens (they will have to request a long-term residence permit for the purpose of scientific research).
Recognition of foreign education takes place according to the legislation of individual EU member states.
In the Czech Republic, in principle, public higher education institutions decide on the recognition of foreign higher education. Professional courses (eg masseur, beautician, etc.) obtained abroad are not subject to academic recognition, as they do not declare the level of education obtained. https://www.msmt.cz/eu-and-international-affairs/academic-recognition
After the transition period the Directive 2005/36/EC on the recognition of professional qualifications ( which establishes a system of mutual recognition of qualifications for regulated profession) no longer applies to the British citizens. In the Czech Republic, Professional qualifications of the British and EU citizens that have been acquired in the UK after the transition period will not be recognised according to, the Professional Qualifications Recognition Act No. 18/2004 Coll.The recognition of professional qualifications will follow the procedure of academic recognition. http://www.msmt.cz/areas-of-work/tertiary-education/recognition-of-foreign-higher-education-in-the-czech
The Professional Qualifications Recognition Act No. 18/2004 Coll. will further apply to the EU citizens who have acquired professional qualifications before the withdrawal of the UK, from the EU because in this case the professional qualifications were acquired when the UK was still an EU member. https://www.msmt.cz/eu-and-international-affairs/recognition-of-professional-qualification
Yes, provided that the UK meets all the criteria necessary to join the programme.
British researchers who resided in the Czech Republic before the end of the transitional period (until December 31st, 2020) will have all rights guaranteed even if they decide to stay in the Czech Republic. However, to avoid complicated administrative procedures in the future, we recommend that they apply for a temporary residence certificate permit. Although a temporary residence certificate is not a condition for a UK citizen to stay in the Czech Republic today, this document proves that the holder is a UK citizen who resided in the Czech Republic before the UK left the EU or during the transitional period. If these researchers have lived in the Czech Republic for more than five years and still want to reside in the Czech Republic after a transitional period, they should apply for a permanent residence permit.
In case British researchers come to the Czech Republic after the January 1st, 2021 with the intent of staying for more than three months, they shall be subject to the rules for third-country citizens (they will have to request a long-term residence permit for the purpose of scientific research).
Work & Social Security
Residence rights are maintained to the UK nationals and their family members even after 1st January 2021. UK nationals and their family members can apply for a „new residence status“ according to the Withdrawal Agreement and for a document certifying that status. This document is issued by the Ministry of the Interior and ideally should be applied for before the end of transitional period (until 31st of December 2020). More information about the issuance of document certifying residence in the CZ according to the Withdrawal Agreement you can find on the website of the Ministry of the Interior on BREXIT:
in the case that you legally stay/work in the CZ before the end of the transitional period, you can continue to work at that employment and you can also get new employed elsewhere within the Czech Republic (or begin studies, get self-employed) after 1st January 2021. The same applies to your family members. A basic condition is stay/residence or employment before the end of transitional period. A burden of proof that you have residential rights is on you, that is why we recommend applying for a document certifying the status (see previous question).
For more information see the Ministry of Labour article on frequently asked questions of labour market.
If I was posted from the UK to the Czech Republic before the end of 2020, then my employer was contacted by the relevant branch of the Labour Office in the Czech Republic to be issued a work permit to enable me to complete the originally intended posting. If I applied to maintain my social and health insurance in the UK before leaving, this exception continues to apply.
From 1 January 2021, the free movement of workers between the EU and the UK ceased to function. This means that if I am to be newly posted from 1 January 2021, I must obtain a work permit and a residence permit and meet the related requirements before the trip, see the previous question. That is the main change. However, what remains the same as before is the possibility of keeping social and health insurance in my home country, which posts me. This possibility is provided to me by the Protocol on the coordination of social security annexed to the newly concluded Agreement on Trade and Cooperation between the EU and the UK with effect from 1 January 2021.
You can apply for a certificate of rights for a cross-border worker. One of the rights of the cross-border worker is a maintenance of his/her job after the end of transitional period without the need of obtaining an employment permit. You can apply for the certificate at the CZ regional employment service branches, competent according to a place where the work is performed in the end of transitional period. To access the certificate, you need to submit an ID, employment certificate, employment contract or other document, that proves you were employed in the CZ.
Social security after brexit is a complex system of rules and exceptions, covering area of family benefits, pensions and other benefits. Your status will also be affected by whether you are covered by the Withdrawal Agreement (which makes improves your position,) or not. At the same time, it is crutial and we recommend all Czech citizens intending to stay and work on in the UK to register into EU Settlement Schemeuntil 30 June 2021 at latest. (The information in Czech language are available in EU Settlement scheme article on the website of Ministry of Foreign Affairs.
You can find guidelines for specific life situation on the list of frequently asked questions of Ministry of Labour and Social affairs or consult the Ministry itself.
Yes, there is no change. A valid EHIC entitles you to receive necessary healthare during your stay.
Yes, it is possible, provided if it was necessary healthcare.
- Necessary healthcare means care for which a person has not intentionally travelled to another state. It does not have a fixed scope, it also depends on the planned length of stay in the state of treatment. It is provided in such a way that the person is not forced to return to the state of insurance earlier than intended or to undergo the necessary treatment there. In general, necessary healthcare is all the healthcare for which the person did not travel to another state.
- Using such healthcare then takes place in such a way that the person sees a doctor, who could also be visited by a local insured person, submits the EHIC and subsequently pays only the costs that the local insured person would also have to bear. If a person pays for the healthcare costs in cash, he or she can claim reimbursement from the competent health insurance fund after returning to the state of insurance. The same regime will then apply to the use of care by British insured persons in the territory of EU Member States.
No, there is no such obligation. It is up to each individual to decide, your EHIC is valid throughout EU and Great Britain.
No, it is not possible because of the one-only competent Member State principle.
No, dependant family members should be insured in the state in which the wage earner is insured.
Custom Duties & Other Financial Matters
As of 1 January 2021, the United Kingdom is no longer part of the EU customs union. Therefore, the customs formalities required under Union law apply to all goods entering/leaving the EU customs territory from/to the United Kingdom. It is mainly the filing of a customs declaration, or entry (import) / exit (export) summary declaration, if required.
On the EU side, the customs authorities will, based on the Union Customs Code, carry out controls at the external borders of the Union according to the common risk system applicable to the transport of goods from third countries.
As to the import / export of goods from / to the United Kingdom after 1 January 2021, you need to obtain an Economic Operator Registration and Identification Number (EORI), if you do not already have one, read the Customs office's article on EORI number..
In connection with the import and, especially, the export of goods, from/to the UK, it is recommended to use the common transit procedure.
The provisions of the EU-UK Agreement do not govern trade in goods between the EU and Northern Ireland, where the Protocol on Ireland and Northern Ireland, which is part of the Withdrawal Agreement, applies.
As of 1 January 2021, EU and UK businesses established in the EU, that intend to import from or export to GB, need to ensure they have an EU Economic Operators Registration and Identification number (EORI) in order to complete customs formalities. For more details about how to get an EORI number, read an article on EORI number..
EORI numbers issued by the United Kingdom will no longer be valid in the EU from 1 January 2021. It is therefore necessary to obtain a new one (see the question above.)
The removal of personal belongings from the UK to the Czech Republic is subject to customs clearance. Personal belongings may be admitted free of import duties in accordance with Council Regulation (EC) 1186/2006 of 16 November 2009 setting up a Community system of reliefs from customs duty. You can read the whole text of the regulation on the reliefs from custom duty. Relief from import duties shall be granted only to persons whose normal place of residence has been outside the customs territory of the Community for a continuous period of at least 12 months. However, the customs authorities may grant an exemption provided that the person concerned shows that he/she intended to stay outside the customs territory of the Community for at least 12 months.
The Withdrawal Agreement can also be applied. If a person proves that the moved belongings have the status of Union goods, the goods will also be exempt from duty, but will be subject to the same customs clearance.
Customs clearance is free of charge. The Customs Administration of the Czech Republic does not collect any fees for customs clearance. However, fees may be charged by private bodies for representation in the dealings with customs authorities.
The EU-UK Trade and Cooperation Agreement provides for zero tariffs and zero quotas on all trade in goods originating in the EU or the UK, from 1 January 2021. The zero tariff and zero quota provisions apply to all goods that comply with the appropriate rules of origin ant is able to provide this.
In case that appropriate documentation will not be provided during the custom proceeding, a standard rate of duty according to the EU Common Customs Tariff will apply. (Similar conditions apply for number of countries, e. x. Canada or Japan.)
The EU-UK Trade and Cooperation Agreement provides for zero tariffs and zero quotas on all trade in goods originating in the EU or in the UK. The zero tariff and zero quota provisions apply to all goods that comply with the appropriate rules of origin.
The agreement provides for a preferential system which will make it possible to achieve a zero rate of duty. For the zero rate to apply, the relevant documents proving the origin of the goods in the EU or in the United Kingdom must be available. In case the relevant documents are not available during the customs clearance, a standard rate of duty according to the EU Common Customs Tariff will apply. A similar principle is introduced in several EU trade agreements with third countries (e.g. between the EU and Canada, the EU and Japan, the EU and South Korea, etc.).
Goods sent from the UK are subject to customs clearance and will therefore be subject to customs duties and VAT. The amount of the customs duty depends on the tariff classification of the goods and the VAT (VAT at the basic rate is 21%). If a proof of origin (e.g. statement on origin on the invoice) is issued by the seller in the UK, the preferential (zero) duty rate will be used. At the same time, the duty exemption can be used for shipments up to 150 euros (for VAT up to 22 euros, but only until 1.7.2021).
Excise goods that leave the consignor's premises in the UK after 1 January 2021 (inclusive) and are moved to the EU are treated as an import from a third country. Such goods are subject to excise duty according to the national legislation of the EU Member State in which the goods are under excise duty suspension or released for free tax circulation. For movements under excise duty suspension, it is necessary to issue an e-AD at the place of import, the consignment in free tax circulation must be accompanied by a simplified accompanying document.
From 1 January 2021, the transport of excise goods from Northern Ireland to the EU (and vice versa) continues to be subject to EU legislation.
It is possible to transport the goods directly by truck/rail and ship. In this case it will be an intra-EU transport. You can also transport the goods through the territory of the GB. In this case, it is most appropriate to use the Convention on a common transit procedure. The document T1/T2 or Carnet TIR/ATA is used.
Yes. The EU and the UK have agreed to recognise each other’s ‘Authorised Economic Operators’ (AEO) programmes, enabling trusted traders to enjoy certain customs simplifications and/or facilitations related to security and safety in their customs operations with the customs authorities of the other Party.
Northern Ireland traders may continue to apply for AEO status through the UK authorities.
As of 1 January 2021, EU prohibitions and restrictions on the international movement of certain goods, justified on the grounds of e.g. public security, protection of health and life of humans, animals and plants, etc. will apply to goods imported from the UK to the EU, and vice versa. Custom's office article on export and import of prohibited and restricted goodswill give you more information as well as the European Commision's guidelines: https://ec.europa.eu/taxation_customs/sites/taxation/files/prohibition_restriction_list_customs_en.pdf.
All consignments of agri-food products must be accompanied by health certificates. They will also have to undergo sanitary and phytosanitary controls at Border Inspection Posts on import.
Opening and maintaining payment accounts in the Czech Republic to UK citizens is not forbidden or made more difficult by law. Thus it will depend on approach of each bank in CZ to opening payment accounts to UK citizens. Please note that fees for credit transfers to UK may be different now.
The rules on income tax liabilities in the context of the country of residence of the taxpayer and the country of the source of income remain the same and they are not changed due to the Brexit (or the end of the transition period).
The rules contained in the domestic laws of both states and in the Convention between the Government of the Czech and Slovak Federal Republic and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation with Respect to Taxes on Income and Capital Gains (in the Czech Republic 89/1992 Coll.) remain decisive when determining the respective tax liability. The Convention addresses taxation of all types of income.
However, in relation to taxation of specific types of income, it is not possible to provide a generally valid answer, as different rules for allocating the taxing right apply to different types of income. In general, it can be stated that tax residents of the Czech Republic are liable to tax in the Czech Republic with respect to their worldwide income, which includes both, the income from sources in the territory of the Czech Republic and the income from sources abroad. Czech non-residents are liable to tax in the Czech Republic only with respect to income from sources in the territory of the Czech Republic (Sec. 22 of the Czech Income Tax Act, 586/1992 Coll.). Additionally, the taxation must be in line with the Convention.
If the Convention allows for taxation of specific income in both, the country of source and the country of residence of the taxpayer, double taxation is eliminated in the country of residence of the taxpayer pursuant to Article 22 of the Convention.
Trade in Goods
With the departure of the United Kingdom (UK) from the customs union and the EU single market, conditions for exchange of gods between the EU and the UK have changed significantly. To determine which business regime applies to your business, it is necessary to distinguish between the United Kingdom (England, Scotland, Wales) and Northern Ireland. Trade with Northern Ireland is governed by specific rules under the Protocol on Ireland and Northern Ireland (discussed in the next question).
Dohoda o obchodu a spolupráci mezi EU a UK se prozatímně provádí od 1. 1. 2021. Díky Dohodě je nadále možné obchodovat s Velkou Británií (VB) bez cel a kvót, ale pouze za splnění požadavků na původ zboží (tzv. pravidla původu). Tato pravidla jsou stanovena v Dohodě a jejich účelem je zajistit, aby byly preferenční celní sazby uplatňovány pouze na zboží, které pochází z Velké Británie nebo EU, a nikoli ze třetích zemí. Ustanovení o „plné kumulaci“ obchodníkům umožňuje zohlednit nejen původ použitých materiálů, ale také to, zda k jejich zpracování došlo na území jedné ze stran Dohody. Tento mechanismus umožňuje, aby Dohoda co nejvíce zachycovala přidanou hodnotu v zóně volného obchodu. Více informací k původu zboží naleznete na General Directorate of Customs (Czech) or on the website of the British Government.
Goods that do not comply with the rules of origin can still be traded under the Agreement. However, they will not be able to benefit from the preferential treatment under the Agreement and will be subject to the EU Customs Tariff (in the case of imports from the Great Britain) or the UK Customs Tariff (in the case of exports to the Great Britain). For some goods, tariffs can be very low or even zero, but other types of goods can be more affected.
Despite the existence of the Agreement, there have been changes in the following areas:
a) Customs supervision and formalities, VAT and excise duty
Trade in goods is now subject to customs supervision and customs formalities. To be eligible for relief from the customs debt, the goods must comply with the relevant rules of origin, including the relevant documentation. As a result of leaving the customs union and the EU's internal market, customs supervision is also linked to the obligation to present a customs declaration and to undergo border checks before goods are released for free circulation. The regime for VAT and excise duty payments has changed as well. For the time being, on the British side, the customs declaration will be very simplified for the first half of the year, especially for non-risk goods. More detailed information is provided by the Border Operating Model. On the Union side, the standard regime applies from 1 January 2021.
b) Border checks
Border controls are basically of three types - security (especially for goods of animal and plant origin), financial (related to customs declaration, tax, etc.) and market surveillance controls (especially for industrial goods, which must meet legislative and other requirements). Border controls have been taking place since 1 January 2021, independently of the conclusion of the Agreement. This is related to the exit from the customs union and the EU internal market. On the British side, inspections will be introduced in three phases, as detailed in the Border Operating Model.
c) Certification of goods
Most goods marketed in the UK, which are currently subject to the CE marking, will have to use the new UK Conformity Assessed (UKCA) equivalent. CE marked goods that meet EU requirements (as long as these requirements meet the requirements of the United Kingdom) can continue to be placed on the UK market until 1. 1. 2022, but there are certain exceptions where the UKCA needs to be applied already from 1. 1. 2021. However, we recommend a change as soon as possible. More information can be found on the UK Government website. The UKCA mark will not be recognized in the EU and therefore goods placed on the EU market will continue to require the CE marking.
Businesses exporting goods from the EU to the UK will become exporters and will have to fulfill the abovementioned conditions. The consignee of goods in the United Kingdom will be an importer and will have to be prepared for changes according to this list.
You can find more about customs procedures on the website of the General Directorate of Customs (Czech), at the Customs Administration Advice and Information Center or at the locally competent customs office.
You can contact the Ministry of Industry and Trade via e-mail email@example.com or via the Brexit line on 800 133 331.
The Access2Markets tool created by the European Commission can also be used to obtain practical information on duties, taxes, rules of origin and product requirements.
You can also read the Czech Embassy's article on new rules for trade.
From 1 January 2021, the Protocol on Ireland and Northern Irelandshall apply to trade with Northern Ireland. This means that EU customs rules will continue to apply to all goods entering and leaving Northern Ireland. The purpose of the Protocol, which was agreed as part of the exit agreement, is to prevent customs and other controls on the island of Ireland. Thus, for businesses in the EU that exchange goods directly with Northern Ireland and vice-versa, there will be no change in taxes and duties as long as these goods remain in Northern Ireland or the EU.
According to the Protocol, Northern Ireland will comply with the relevant EU rules on the marketing of industrial goods. If you are marketing certain goods in Northern Ireland, you must use the conformity marking. In Northern Ireland, EU conformity markings continue to be used to demonstrate that goods comply with EU rules. Most manufactured products bear the CE mark. If you use the UK authority to perform mandatory third-party conformity assessment, you must also use the UKNI label. The UKNI mark can never be used alone - it is always accompanied by the EU conformity mark, such as the CE mark. However, both CE and UKNI marked goods cannot be placed on the market in the EU. More information can be found on the British website..
In the event of transportation of goods from the EU via Northern Ireland to Great Britain, or goods from Great Britain via Northern Ireland to the EU, it is necessary to prepare for the new rules as specified above.
You can find more about customs procedures on the website of the General Directorate of Customs (Czech), at the Customs Administration Advice and Information Center or at the locally competent customs office.
Goods transported between the EU and the UK, with the exception of air transport, will mostly cross the EU's external border in France, Belgium and the Netherlands. These countries have therefore developed digitized customs and border control systems. Controls and customs supervision apply from 1 January 2021.
The solutions of individual countries are as such:
France has introduced SMART BORDER SYSTEM. The system is built on three principles:
- preparation before arriving to the border,
- pairing of carrier and transported goods and
- maximum automation in the evaluation of customs authorities. Through the SI Brexit system, it will be necessary to enter all the documentation and generate a bar code that the carrier will have paired with the truck's license plate. Subsequently, the system automatically evaluates whether the cargo will be able to continue the journey, or will be stopped for further inspections or measures after disembarkation or exit from the tunnel.
Belgium does not have a uniform system - the port of Antwerp uses the Nxtport system (detailed instructions are given in the published White Book) and another system is used by the Belgian port of Zeebrugge, where cargo is transported without accompaniment of the driver. Conditions for successful transport in the port of Zeebrugge are: (1) the reservation of a seat on the ferry, and (2) notification of arrival at the border area through the RX/SeaPortsystem. Relevant customs documents must also be uploaded to the system in advance. Subsequently, as in the French case, it is automatically evaluated whether the cargo can continue freely to the destination or whether further checks and additions to the documents will be required.
The Netherlands , in cooperation with the private sector, then developed a unified PORTBASEsystem. The system is based on the cooperation and responsibility of all actors - exporters, importers, shippers and shipping companies in the chain. The condition for transport across the Channel is registration in the PORTBASE, ensuring all documents are attached to the application and pairing with the carrier's license plate is completed. The scanned license plate will then be a ticket to the port area. Without registration, documents or notification of arrival, the transport of goods will not be possible.
The United Kingdom has also published a three-tier plan for the Border Operating Model. Also, Guidelines for the transporting goods between the United Kingdom and the EU are available. For the passage of trucks (over 7.5 t) through the county of Kent in the direction from Great Britain to France through the Eurotunnel and the port of Dover, it is necessary to obtain the so-called Kent Access Permit.
The end of the transition period means:
- the end of the principle of mutual recognition and the obligation to adapt goods to the requirements of the target market;
- the obligation to obtain a conformity assessment certificate for regulated products separately for the Union and United Kingdom markets, unless otherwise specified;
- the expiry of a conformity assessment certificate issued by a British testing laboratory after 1 January 2021. Goods placed on the EU market after the end of the end of transition period must possess a new EU-27 certificate or the original certificate must be transferred to the EU-27.
The EU-27 distributor will have the status of an importer after the end of the end of transition period and will have associated obligations. Goods requiring the appointment of an authorized representative must be established in the EU-27.
For exports of certain goods to the United Kingdom, nothing will change temporarily (until 1 January 2022). It will still be possible to place on the market an industrial product * that meets the requirements of EU regulations. More information can be found in the article on the export of industrial goods..
*Is only valid for certain EU goods fulfilling demands of the UK.
Control of foreign trade in military equipment, non-military weapons and ammunition, dual-use items and goods that could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment of instruments, as well as control of imports of certain pyrotechnic articles from third countries will be affected by the UK's exit from the customs union and the EU internal market.
It will be necessary to apply for a license or permit for export, resp. imports in the case of military material and weapons and ammunition of a non-military nature, as well as imports of certain pyrotechnic articles from third countries. The transfer or transportation permits should remain valid. However, it is necessary to record the current drawdown on the depreciation sheet. In the case of dual-use items and items that could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, the United Kingdom has been added to the list of countries where a General Export Authorization is sufficient. The EU regime will apply in Northern Ireland.
Despite leaving the EU, the UK remains an attractive market for Czech companies. Due to the size of its market, the development of infrastructure, incl. research capital, a strong banking sector, as well as significant changes to a service-based economy, there is clearly high potential for engagement of Czech companies and development of new partnerships. The United Kingdom has also been an important gateway to third markets, whether in the Commonwealth or the United States.
Despite all the uncertainties regarding Brexit, the United Kingdom is one of the Czech Republic's key trading partners. In 2019, it was the fifth largest market for Czech goods and the fifteenth largest exporter to Czech market. According to current data from the Czech Statistical Office, in 2019 it accounted for 4.5% of total Czech exports, 1.7% of imports and 3.2% of turnover. A "record" trade balance asset of almost CZK 138 billion was achieved.
More information will be provided by the Ministry of Industry and Trade, the CzechTrade office in London, the CzechInvest office in London, the Embassy of the Czech Republic in London (all Czech) or the Embassy of United Kingdom in Prague.
The cross-border movement of cultural goods between the EU and the UK is governed by Czech legislation (Act No 20/1987 on state heritage conservation, Act No 122/2000 on the protection of museum collections, Act No 499/2004 on archiving and the records service, and Act No 71/1994 on the sale and export of cultural artefacts items of cultural value), and by European legislation (Act No 214/2002 on the export of certain cultural goods from the customs territory of the European Communities, as amended (Council Regulation (EEC) No 3911/92 of 9 December 1992 on the export of cultural goods and Commission Regulation (EEC) No 752/93 of 30 March 1993 laying down provisions for the implementation of Council Regulation (EEC) No 3911/92 on the export of cultural goods, or, where applicable, Council Regulation (EC) No 116/2009 of 18 December 2008 on the export of cultural goods and Commission Implementing Regulation (EU) No 1081/2012 of 9 November 2012 for the purposes of Council Regulation (EC) No 116/2009 on the export of cultural goods; Act No 214/2002 on the export of certain cultural goods from the customs territory of the European Communities, as amended (Council Regulation (EEC) No 3911/92 of 9 December 1992 on the export of cultural goods and Commission Regulation (EEC) No 752/93 of 30 March 1993 laying down provisions for the implementation of Council Regulation (EEC) No 3911/92 on the export of cultural goods, or Council Regulation (EEC) No 116/2009 of 18 December 2008 on the export of cultural goods and Commission Regulation (EEC) No 1081/2012 of 9 November 2012 laying down provisions for the implementation of Council Regulation (EEC) No 116/2009 on the export of cultural goods).
The essential factor is whether an object is classified under any of the categories covered by Czech and European law.
Trade in Services
Since having left the EU, the United Kingdom became a so-called third country. The Trade and Cooperation Agreement (TCA) includes provisions facilitating short-term business trips and transferring qualified workers. However, these provisions do not remove visa requirements or any other obligations relating to the entry and temporary stay of such workers. Those obligations are entirely within the UK’s authority and need to be carefully followed and complied with. The British Embassy in the Czech Republic can provide information in more detail.
The TCA is a comprehensive agreement and the cross-border trade in services constitutes its integral part. However, for each different sector, it is necessary to follow the laws and other specific rules applicable in the UK. The requirements relating to foreign service providers (e.g. the requirement to be legally established in the UK or other requirements specific to foreign service providers) are listed, in the form of reservations, in the annexes to Part Two, Title Two (Services and Investment) of the Agreement, which provide an overview of the existing and future measures.
Your company will be considered a foreign services provider when offering services in the UK. The Trade and Cooperation Agreement provides for a better treatment as opposed to trading under the World Trade Organization rules. Moreover, the new agreement ensures that service providers from the EU will not be subject to a less favorable treatment than their UK counterparts. At the same time, such arrangement affords EU service providers a certain level of advantage over providers from third countries that do not have a similar agreement with the UK in place.
Given than the United Kingdom is no longer a member of the EU single market, EU service providers and investors must follow and comply with the rules, procedures and authorization requirements currently in force in the UK, the binding interpretation of which can only be provided by the UK authorities.
The level of access to the UK market (and vice versa) is determined by the Agreement and the commitments set out in the annexes. These also specify the sectors where specific reservations have been undertaken by the Parties, which specify the conditions for foreign service providers (e.g. on the basis of applicable laws).
Workers that are transferring abroad within a company are accounted for in the Trade and Cooperation Agreement as “Intra-Corporate Transferees” (ICTs). Such workers need to fulfill certain conditions (e.g. having worked in the company for at least a year, on a managerial or specialist position). If the workers meet such condition, they can be transferred to work in the Czech Republic (or the UK) for a period up to 3 years. More information on the concrete steps to take can be found here:
For the ICTs transferring to the UK: https://www.gov.uk/guidance/recruiting-people-from-outside-the-uk and https://www.gov.uk/intracompany-transfer-worker-visa/eligibility
For the ICTs transferring to the Czech Republic: https://www.mvcr.cz/mvcren/docDetail.aspx?docid=22082926&doctype=ART
Under the Trade and Cooperation Agreement, the EU and the UK have agreed that the European Data Protection Framework (GDPR) would remain in force for a maximum period of 6 months, for the purpose of adopting a so-called adequacy decision by the European Commission.
As a result, data will be able to flow freely between the EU and the UK and personal data will continue to be protected under the current framework until July 1, 2021 (or the date of entry into force of the Decision). The transfer of data between the EU and the UK will thus not be considered as a transfer to a third country. Therefore, no formalities or further steps are required in order to maintain free flow of data for the time being. Meaning, it is not necessary to introduce measures related to the transfer of data to third countries (under Articles 46 and 47 of the GDPR).
At the end of this period given that no adequacy decision will be made by the European Commission , all transmits will be considered to be done towards the third country.
For the purpose of temporary export of equipment, it can be convenient to obtain an ATA carnet to register the goods in question. In the Czech Republic, ATA carnets are issued by the Chamber of Commerce. The Carnet is a suitable tool if you need to temporarily export or import goods and can therefore be used for the export of equipment, tools and other materials necessary in the exercise of your profession, as marketing materials or samples etc. Carnets are like passport for goods. By registering your equipment, tools, materials or other goods in the ATA carnet, you will not be subject to VAT or customs duties. However, it is necessary to verify whether the ATA carnet can be used in your specific situation, as restrictions may apply. The second option is to move the goods in question in a “temporary admission procedure”.
Food & Agriculture
Rules for imports of products of animal origin, composite products and products obtained from by-products of animal origin for personal consumption from third countries are regulated by Commission Delegated Regulation (EU) 2019/2122. These rules also apply for persons travelling from the UK to EU.
Rules for imports from all third countries therefore apply for persons travelling from UK to EU. There is a strict ban on imports of meat, meat products, milk and milk products for personal consumption in personal baggageIt is no longer possible for a natural person to have those products sent for personal consumption. For further information, please see State Veterinary Administration.
From 1 January 2021, there is the requirement for pre-notification and phytosanitary certificates for plants and plant products that pose the greatest potential risk to GB biosecurity (including foodstuff) and which are already subject to regulation within the EU. They will also be subject to import checks away from the border at places of destination.
Further requirements will be introduced in stages (from 1 April and 1 July 2021). For more information, follow the webpage of Ministry of Agriculture, State Veterinary Administration and Central Institute for Supervising and Testing in Agriculture.
Great Britain no longer has access to the RASFF and AAC systems. However, as a third country (non-EU) we will continue to be notified of any alerts impacting on the UK via RASFF Windows. The status of Northern Ireland (NI) is different. NI has 3rd country access to RASFF, but also has a requirement to report issues and respond to requests reported via iRASFF – including RASFF and AACS notifications. NI’s obligations to share information and respond to requests also extend to food fraud notifications.
The UK will continue to notify EU member states of food feed safety concerns in a timely manner according to expectations set out in the International Health Regulations 2005. The UK will in future engage with other countries on issues of food safety using the INFOSAN network – the UK Emergency Contact Point firstname.lastname@example.org.
The UK will no longer contribute to fulfilling the joint commitment of the EU and its Member States under the Paris Agreement. However, the UK itself remains a party to the Agreement and is therefore obliged to fulfill its own commitment. Besides, compliance with the Paris Agreement is one of the so-called ‘essential elements’ of the EU–UK Agreement, which means that either Party may decide to terminate or suspend, in whole or in part, the operation of this Agreement if it considers that the other Party’s actions materially defeat the object and purpose of the Paris Agreement.
No. The Agreement contains only a non-binding provision stating that the EU and the UK shall continue to strive to increase their respective levels of environmental or climate protection. By analogy, the UK may increase its level of protection on its own, i.e. without the need for reciprocity on the part of the EU.
In the field of environment, this principle applies to EU and UK legislation which has the purpose of protecting the environment, including the prevention of a danger to human life or health from environmental impacts. Explicitly, there shall be no regression from the current level of environmental protection in, among others, the following areas: a) industrial emissions; b) air emissions and air quality; c) nature and biodiversity conservation; d) waste management. The full list can be found in specific Ministry of Environment's article. In the field of climate, the principle applies to emissions and removals of greenhouse gases and the phase-out of ozone depleting substances.
No. The UK was part of the EU ETS until 31 December 2020. As of 1 January 2021, the UK replaced it with its own system (UK ETS) which, according to the Agreement, shall cover greenhouse gas emissions from electricity generation, heat generation, industry and, within 2 years at the latest, aviation. The effectiveness of the UK ETS shall uphold the level of protection applicable on 31 December 2020.
Besides, there is a possibility of linking the EU and UK systems in the future.
The Agreement does not set any new targets in this field. However, the EU and the UK reaffirm their ambition of achieving climate neutrality by 2050 and commit to uphold a level of climate protection that is in line with the target of reducing greenhouse gas emissions by 40 % by 2030. At the same time, the UK is no longer bound by the Effort Sharing Regulation which sets a binding greenhouse gas emission reduction target in non-ETS sectors for each Member State. Since the UK contribution in this area was quite significant, it can be expected that the target set for the Czech Republic will increase accordingly in the ongoing revision of the Regulation.
From the perspective of international trade in endangered species protected by CITES, the UK has been a third country since 1 January 2021, which means that a CITES permit is required for the import or export of specimens between the EU and the UK (in the Czech Republic, this permit is issued by the Ministry of Environment). More information on the impacts of Brexit on CITES is available in the relevant notice from the European CommissionUnder the Agreement, the EU and the UK shall promote the use of CITES as an instrument for conservation and sustainable management of biodiversity, including through the inclusion of animal and plant species in the Appendices to this Convention.
As of 1 January 2021, Regulation (EC) No 1013/2006 on shipments of waste no longer applies to the UK. As a result, the handling of notifications concerning the UK (mainly imports of waste from the UK) is now governed by the rules for third countries, which brings some restrictions and increased administrative and financial burden for participants in transboundary shipments of waste. Specifically, it is no longer possible to export waste for disposal and mixed municipal waste for recovery operations to the UK. The Agreement does not provide for any exceptions in this regard. More information on the impacts of Brexit on transboundary shipments of waste is available in the relevant notice from the European Commission..
Trademarks & Industrial Property
EU trademarks registered in the EU trademark register are replaced with the equivalent registered United Kingdom trademarks - the "comparable UK trademarks" in the United Kingdom on 1 January 2021. They are treated as trademarks applied for and registered in the United Kingdom. Thus, almost 1.4 million EU trademarks should be transferred to comparable UK law, which will enter into force on 1 January 2021. These rights are subject to the same filing date as the relevant EU trademarks. This is important because the new registration is not published, and no certificate is issued. There are no administrative fees for maintaining protection. Owners of an existing EU trademark, which do not wish to hold a comparable UK trademark, may notify the United Kingdom Intellectual Property Office (UKIPO) of their decision at any time after 1 January 2021. Owners of EU trademarks in the United Kingdom will be able to invoke both the filing date and the right of priority and the reputation of their trademark acquired in the EU until 31 December 2020. According to the agreement, the level of protection in the United Kingdom should be in line with EU protection.
The UKIPO has created comparable UK trademarks also from EU trademarks for which the term of protection expired within six months before 1 January 2021 and they have an additional six-month renewal period. These comparable UK trademarks have the status of "expired" and the continuation of their protection in the UK depends on the renewal of the registration of the existing EU trademarks at EUIPO. The comparable UK trademark will thus be automatically renewed due to the subsequent renewal of the EU trademark. In such a case, no renewal fee is required for the first renewal of a comparable UK trademark. If an EU trademark whose term of protection has expired is not renewed at EUIPO within an additional period, the comparable UK trademark that was created on 1 January 2021 will be removed from the UK register after the expiry of the additional period with effect from the date on which it was created.
An EU trademark application filed before 1 January 2021 which was not registered or refused before that date, can be the subject of an application for the same UK trademark for some or all goods or services filed by the applicant (or his successor in title) before 30 September 2021. This mark will have the same filing date or priority date as the date of the corresponding EU trademark. If an EU trademark application claims seniority from a UK trademark registration, this seniority may also be claimed in the UK trademark application based on the EU trademark application if the UK trademark application is filed before 30 September 2021. The applicant will have to pay an application fee for the UK trademark application.
Once a comparable UK trademark is created, a separate renewal fee will apply for each compara-ble UK trademark. The fees will need to be paid separately to UKIPO for comparable UK trademark and the EUIPO for existing registered EUTM. For the purposes of future renewal, the comparable UK trademark will retain the existing renewal date of the corresponding EUTM according to the Withdrawal Agreement. Under existing law, UKIPO sends a renewal reminder to any UK trademark owner whose right is due to expire, and the Office does so six months ahead of the expiry date. This practice will be retained for all comparable UK trademarks with renewal dates that fall more than six months after 31 December 2020.
In cases, where the comparable UK trademark expires in the six months after 31 December 2020 or the term of protection of EUTM has expired in the six months before 31 December 2020, and are still in their further renewal period, a different procedure will follow.
Where the comparable UK trademark expires within six months after 31 December 2020, there will not be enough time for UKIPO to issue the standard renewal reminder in advance of the expiry date and the Office will sent a renewal reminder on the actual date of expiry, or as soon as possi-ble after that date. The reminder will inform the owner that the comparable UK trademark has expired and that there are another six months from receipt of such notice to renew the right. The ‘late’ renewal of comparable UK trademarks will not be subject to an additional renewal fee; only the standard UK renewal fee calculated by reference to the number of classes has to be paid. Where the comparable UK right is not renewed, it will be removed from the register but it may be restored at a later date in accordance with existing UK law. Where an EUTM renewal date falls after 31 December 2020, early payment of the renewal fee at EUIPO, before 31 December 2020, will have no effect in respect of the comparable UK trademark.
Designs registered in the Community design register are replaced with the equivalent UK registered designs - the "re-registered design" in the United Kingdom on 1 January 2021 and are treated as designs that have been filed and registered in the United Kingdom. In this way, almost 700 000 Community designs should be transferred, which will enter into force on 1 January 2021. These rights are subject to the same filing date as the relevant Community designs, which is important because the new registration is not published, and no certificate is issued for it. There are no administrative fees for maintaining protection. Owners of an existing Community design, who do not wish to hold a re-registered design, may notify the UKIPO of their decision at any time after 1 January 2021. Owners of Community designs will be able to invoke the filing date and right of priority in the United Kingdom. According to the agreement, the level of protection in the United Kingdom should correspond to that in the EU.
Like registered Community designs, unregistered Community designs will automatically be con-verted into an equivalent UK right. These new equivalent rights will be called “continuing Commu-nity unregistered designs”. These rights will expire on the same day as it expires in the EU Member States, meaning that the last rights that are created will expire three years from 31 December 2020.
A Community design filed before 1 January 2021 which was not registered or rejected before that date can be the subject of an application for an identical design in the United Kingdom filed by the applicant (or his successor in title) before 30 September 2021. Such design will have the same filing date or priority date as the date of the corresponding Community design. The applicant will have to pay filing fees for the UK design application.
Once a re-registered UK design is created, a separate renewal fee will apply for each re-registered UK design. The fees will need to be paid separately to UKIPO for a re-registered UK design and the EUIPO for existing registered Community design. For the purposes of future renewal, the re-registered design will retain the existing renewal date of the corresponding RCD according to the Withdrawal Agreement. Under existing law, UKIPO sends a renewal reminder to any UK registered design owner whose right is due to expire, and the Office does so six months ahead of the expiry date. This practice will be retained for all re-registered designs with renewal dates that fall more than six months after 31 December 2020.
In cases, where the re-registered design expires in the six months after 31 December 2020 or the term of protection of RCD has expired in the six months before 31 December 2020, and are still in their further renewal period, a different procedure will follow.
Where the re-registered design expires within six months after 31 December 2020, there will not be enough time for UKIPO to issue the standard renewal reminder in advance of the expiry date and the Office will sent a renewal reminder on the actual date of expiry, or as soon as possible after that date. The reminder will inform the owner that the re-registered design has expired and that there are another six months from receipt of such notice to renew the right. The ‘late’ renew-al of re-registered design will not be subject to an additional renewal fee only the standard UK renewal fee has to be paid. Where the re-registered design is not renewed, it will be removed from the register but it may be restored at a later date in accordance with existing UK law. Where an RCD renewal date falls after 31 December 2020, early payment of the renewal fee at EUIPO, before 31 December 2020, will have no effect in respect of the re-registered design.