UK Parliament Warns of Weakened Market Access Post-Brexit

If the UK cannot remain a member of the European Aviation Safety Agency (EASA) when it exits the European Union, the resulting need for a bilateral aviation safety agreement will weaken the UK aerospace sector’s access to the EU market, a UK parliamentary committee noted. The remark reflects long-standing concerns by the industry that Brexit will hamper OEMs’ supply chains.

Even if the future UK-EU BASA seeks to minimize certification requirements where possible, it “would represent a deterioration of market access to the EU market for the UK aerospace sector, as two sets of approvals would be required for the placing of products on the market,” the European Scrutiny Committee asserted. “The UK would cease to participate in wide-ranging intra-EU mutual recognition arrangements [that] apply in the field of aviation safety...even if the UK were to replicate EU law in this area.”

The assessment comes as the committee mulls over a statement by UK aviation minister Liz Sugg that the government intends to enter into an understanding with China to ensure that, after its exit from the EU or after a post-exit implementation period, the UK would consider a bilateral agreement with China. The country’s manufacturers would support such a draft agreement, she noted.

The EU and China reached agreement on a BASA earlier this year. The UK will no longer be part of the agreement if it leaves the EU and EASA, hence the need to negotiate a similar aviation safety arrangement bilaterally with Beijing.  

However, the UK securing a “best-in-class BASA” would likely not occur in the immediate aftermath of EU exit because it will take time for the UK to adapt and develop a fully functional independent aviation safety regime, the committee concluded. It pointed also to “asymmetries” in the EU-China BASA, which, it said, reflects the “relative maturity” of the EU and Chinese aviation safety regimes. The EU-China BASA does not feature full reciprocal recognition of European and Chinese certifications, limiting the certification role of the Civil Aviation Authority of China in validating EASA certificates.

If the UK can’t obtain its ongoing participation in EASA after Brexit, it also will have to conclude a BASA with the U.S., Canada, and Brazil to replace the current EU-negotiated agreements. The British government has said it is working closely with the three countries on a replacement BASA.