Although there has been little progress in accession negotiations, Turkey has gradually expanded its legislation on EU legislation to remove technical barriers. The results of THE CAB tests notified by Turkey are mutually recognised in the EU (and vice versa). CEPs are usually concluded with candidate countries with which the EU has association agreements (see our presentation on association agreements) and are a step in the accession process. The aim of the EPCA is to bring the technical rules of a candidate country in line with those of the EU in terms of preparation for EU membership. This type of MRA is by nature temporary, as it disappears when the country joins the EU internal market. A traditional MRA is a mutual recognition agreement for «compliance assessment.» However, recent free trade agreements indicate a change in approach and acceptance of «traditional» MMAs. For example, Article 4.6 and Article 7.21, paragraph 4, of the EU-Korea Free Trade Agreement provide for the negotiation of mutual recognition of the assessment of the compliance of goods and services. What kind of mutual recognition agreements has the EU concluded? In the Brexit negotiations, the UK government called for mutual recognition of the rules, including in Theresa May`s florence speech and as an option for future regulation of financial services, but refused by the EU. 5 This article does not address the question of whether mutual recognition in a regional trade agreement falls within the gaTT Article XXIV exemption, although leading scientists believe that most of these recognition agreements are not covered by the exception. See General Trachtman, Joel P., `Toward Open Recognition? Standardization and regional integration in accordance with GATT Article XXIV, 6 Journal of International Economic Law (2003) 459 CrossRefGoogle Scholar; Bartels, Lorand, «The Legality of the EC Mutual Recognition Clause under WTO Law,» 8 Journal of International Economic Law (2005) 691, at 711-714 CrossRefGoogle Scholar.
However, European Commission trade negotiators recently rejected mutual recognition of the compliance assessment by UK testing laboratories. Mutual recognition agreements (MRAs) are agreements between two trading partners aimed at reducing technical barriers to trade. They are one of the themes covered in the trade negotiations between the UK and the EU. The Johnson government has moved away from these approaches. In its proposal for a comprehensive free trade agreement with the EU, the UK proposes an agreement on mutual recognition of compliance assessment that is «consistent» with the provisions of the EU agreement with Canada. A separate agreement on the certification of marine equipment is also proposed as part of the agreement between the EU and the United States. By granting mutual recognition of products covered by free trade agreements with Canada and Korea, but which refuse to give the same treatment to products originating in the United Kingdom, the EU could violate WTO legislation. For example, the European Commission`s recent free trade agreements with Canada and Korea provide for the conclusion of a compliance assessment MMA, without asking their partners to adapt their regulatory requirements to those of the EU.