Switzerland and the EU: what the MRA covers — and where it stops.

The 1999 agreement

The Mutual Recognition Agreement between Switzerland and the EU — signed in 1999 as part of the first bilateral package — is one of the most important and most misunderstood trade agreements in the European context. It regulates mutual recognition of conformity assessment for commercial goods across 21 sectors.

The principle: a conformity assessment carried out in Switzerland by a SAS-accredited body against EU directive requirements is recognised as equivalent by EU authorities. The reverse applies. In MRA categories: one assessment for both markets.

Where the MRA stops

The MRA does not cover every category. Three of the most commercially important categories in bilateral trade are absent: cosmetics, food, REACH chemicals. Anyone assuming the MRA covers the entire bilateral product flow is wrong on fundamentals. For these three, EU requirements apply unfiltered.

The MRA must move with the regulations it rests on. The arrival of MDR fundamentally affected the MRA medical-devices chapter. Its current operational status requires case-by-case clarification. A 1999 agreement does not automatically reflect 2026 regulation.

Common misunderstandings

First: EU conformity is automatically Swiss conformity. For MRA categories: largely true. For cosmetics, food, chemicals: false.

Second: Swiss approval opens the EU market. For MRA categories: largely true. For the exceptions: false. The mirror misunderstanding is as expensive as the original.

Third: language requirements don't apply in Switzerland. Products on the Swiss market must be labelled in the official languages of the cantons where they are sold. In practice for a nationwide product: German, French, Italian. An English-only manual is not enough.

Fourth: once compliant, always compliant. Regulations change. Standards are revised. MRA chapters must be updated. A 2020 conformity is not necessarily a 2026 conformity.