Brexit Countdown – Trade in Goods and Services

by White & Case LLP

White & Case LLP

UK Prime Minister May and the political leaders of the EU-27 have endorsed the draft Withdrawal Agreement that is intended to end the UK’s membership of the EU on 29 March 2019. They have also indicated their support for the Political Declaration on the framework for the future relationship between the UK and the EU-27, including on trade, that will apply after the end of a transition period, at the latest by December 2022.

UK and EU leaders have rejected the possibility of re-negotiating these agreements.

However, they remain subject to approval by the UK and the EU Parliaments. The prospect of their approval by the UK Parliament is uncertain. If the UK Parliament rejects both of these agreements and the acceptability of a "no deal" outcome, there is political speculation in the UK about the possibility of a new referendum on the UK’s withdrawal from the EU. However, in the absence of further intervention by both the UK and the EU, EU-UK trade would revert to WTO rules from 30 March 2019, in what would be a "hard Brexit" scenario.

Elements of the draft Withdrawal Agreement

Transition period – April 2019 to December 2020/2021/2022

The draft Withdrawal Agreement provides for a transition period until 31 December 2020, during which the UK will remain in the EU Single Market and Customs Union and continue to apply all EU trade law under the jurisdiction of the European Court of Justice. This will postpone the impact of Brexit on the UK’s trade with both the EU and third countries for 21 months. Article 132.1 of the draft Withdrawal Agreement permits an extension of the transition period for up to one or two years, ending no later than December 2022.

The transition period is dependent on Parliamentary approval of the Withdrawal Agreement. If it were rejected, there would be no transition period – a "hard Brexit" would ensue on 30 March 2019.

However, assuming the Withdrawal Agreement is approved, during the transition period "Union law shall be applicable to and in the United Kingdom".

This would cover all EU trade law, including customs and trade regulations as well as trade remedies, state aid and public procurement. New EU trade regulations and directives that enter into force would also apply to the UK during the transition period, but the UK would no longer have a voice in their adoption.

The UK and the EU would negotiate their new, long-term trade agreement during the transition period based on the mandate contained in the framework for the EU-UK future relationship that accompanies the Withdrawal Agreement.

During the transition period, the UK would be able to negotiate and ratify trade agreements with third countries, but the agreements cannot enter into force until the transition period ends.

The Irish "backstop"

In order to avoid a hard border between Northern Ireland and the Republic of Ireland, the draft Withdrawal Agreement contains a Protocol with the so-called Irish "backstop" solution applicable if a new EU-UK trade agreement has not been reached by the end of the transition period. The backstop would see the EU and UK becoming part of a "single customs territory". However, this is not the same as the UK remaining in the EU Customs Union.

Customs tariffs would not apply to trade in goods between the EU and the UK, but certain customs formalities would apply. In particular, if the EU and UK cannot agree detailed provisions relating to their bilateral goods trade by 1 July 2020, UK exporters to the EU will have to start presenting to customs a "UK Movement Certificate" to show that the goods are in "free circulation" and that EU tariffs and commercial policy measures have been complied with in respect of the goods being traded.

With respect to product regulations, Northern Ireland would continue to apply EU rules and the UK authorities would be responsible for ensuring that goods exported from mainland UK to Northern Ireland comply with those rules.

The UK would be free to negotiate and enter into trade agreements with third countries as long as it does not apply a tariff which is lower than the EU’s Common External Tariff and does not apply or grant any quotas, tariff-rate quotas or duty suspensions without prior agreement of the EU. It is the potential for the EU unilaterally to influence UK trade post-Brexit, which has proven to be one of the more politically sensitive aspects of the Withdrawal Agreement in the UK.

A detailed White & Case analysis of the effects of Withdrawal Agreement on trade in goods regarding the transitional period and the Irish "backstop" arrangement can be found here.

A new UK-EU trade agreement

The mandate for negotiations on a permanent agreement on trade and economic cooperation is contained in the Political Declaration on the framework for the future EU-UK relationship. The new agreement would end the UK’s transitional membership of the EU Customs Union and Single Market and avoid the Irish "backstop" arrangement by obviating the need for a physical Irish border.

The mandate for negotiations is aspirational and sets out broad principles and objectives. Turning these into operational provisions and a legally-binding trade agreement will be a matter for negotiation during the transition period. In the past, the EU has cited its Comprehensive Economic and Trade Agreement with Canada (CETA) as a potential model for a future UK-EU FTA. The UK (in the "Chequers plan") aimed to go further and make post-Brexit trade with the EU as frictionless as possible through "a free trade area for goods" with a "common rulebook" for most industrial and agri-food products that would eliminate the need for regulatory controls at the border. For services, the UK proposed close regulatory cooperation with the EU and recognition of different regulatory systems that are "equivalent" in effect. Neither of those outcomes seem to have been ruled out entirely in the Political Declaration.

With regard to trade in goods, the UK and the EU envisage a free trade area combining deep regulatory and customs cooperation underpinned by a level playing field for open and fair competition. It should be tariff and quota free across all sectors, with ambitious customs arrangements that, inter alia, avoid the need for checks on rules of origin. The UK and the EU will have regulatory autonomy but will seek to avoid unnecessary regulatory barriers to trade. The UK will consider aligning with EU rules in relevant areas; the extent to which it does so is likely to impact the extent to which the EU will require customs and regulatory checks and controls. UK and the EU will explore cooperation for their respective medicines, chemicals and aviation agencies.

With regard to trade in services and investment, the agreement will be based on host state rules and respect each other’s right to regulate. Sectoral coverage should be substantial, covering all modes of supply and avoiding substantially all discrimination. Unnecessary regulatory requirements should be avoided through disciplines on domestic regulation and a framework for voluntary regulatory cooperation. Assessments to recognise regulatory equivalence will be pursued as a priority for financial services, with the aim of concluding the assessments by June 2020. There will be "transparency and appropriate consultation" on the adoption, suspension and withdrawal of equivalence decisions.

New UK Free Trade Agreements

The EU has agreed that the UK can negotiate and ratify trade agreements during the transition period but those agreements cannot enter into force until the transition period ends.

About 40 FTAs in which the UK participates by virtue of its EU membership will cease to apply to the UK as soon as it leaves the EU. These account for over 15% of UK exports. Some are of considerable commercial value, particularly the FTAs with Switzerland, Singapore, Canada, and South Korea. The UK and the EU have agreed that during the transition period the UK will continue to be bound by the obligations of these FTAs. The other FTA parties will no longer be obliged legally to provide preferential access to the UK once it ceases to be an EU member state. The UK Government claims to be confident that they will agree to do so, since in practice the FTAs would continue functioning exactly as they do today, but that cannot be taken for granted. Long-term, the UK must agree new FTAs with these countries if it wants to keep preferential access to their markets.

UK negotiations on FTAs with other countries, such as the United States, can therefore begin from 30 March 2019. Most countries are likely to want to know the terms of the new UK-EU trade agreement before they are willing to strike deals with the UK. Recent interventions by President Trump are illustrative of the challenges the UK may face in that regard.

After March 2019, the UK will be able to apply to join existing trade and investment agreements, such as the Trans-Pacific Partnership (TPP).

UK Obligations in the World Trade Organisation (WTO)

The UK will become an independent Member of the WTO as soon as it withdraws from the EU in March 2019. Most of its WTO obligations will remain unchanged, but its government procurement obligations and parts of its market access schedules need to be re-negotiated.

The UK must accede to the WTO Government Procurement Agreement (GPA) before it leaves the EU or it could lose preferential access to the procurement markets of its main trading partners. The timeline for doing this is tight because of the GPA accession procedures. The UK has now agreed with other GPA Parties on improved access to its public procurement market and a formal decision approving its GPA accession is expected before the end of 2018. The UK must then pass domestic legislation confirming what is in its GPA schedule and notify the WTO that it has ratified the GPA at least 30 days before its withdrawal from the EU.

It is equally important, although less urgent, for the UK to secure approval ("certification") of its Most- Favoured-Nation (MFN) market access obligations. The UK is proposing to adopt, as closely as possible, the MFN schedules that it already applies as an EU member state.

It is not anticipated that most WTO member countries will find fault with leaving unchanged the UK’s MFN tariff schedule for manufactured goods and its schedule of specific commitments on market access for services, although some are expected to demand additional concessions before being willing to agree to certify the UK schedules.

Reaching agreement on the UK’s MFN schedule for agricultural products is more complicated. The UK cannot duplicate the EU schedule because it includes over 100 tariff rate quotas that affect imports of certain meat and dairy products, cereals, fruits and vegetables that have been set on an EU-wide basis. The UK and the EU have proposed using historical market shares to split the quotas between them. That is a recognised WTO methodology, but several countries have objected to its use in this case, on the grounds that splitting the conditions. The UK has now agreed to enter full negotiations with all relevant trading partners to allocate the quotas. The negotiations are likely to be drawn out because a solution must satisfy the UK and the EU as well as the third countries involved.

Business can expect day-to-day trade with the UK to continue uninterrupted while negotiations to certify its MFN market access schedules take place. There is no time limit for that process, which could take years to complete and which could result in the UK needing to lower its MFN duties. In the meantime, the UK’s proposed ("uncertified") market access schedules will be included in UK legislation and will have full legal effect under WTO rules.

Legislative Preparations for Brexit

The UK is preparing new legislation to implement UK trade policy after the European Communities Act 1972 is repealed in March 2019. UK trade law will remain fully aligned with EU law and the Union Customs Code during the transition period. The status quo should effectively continue until December 2020 at least, assuming that the Withdrawal Agreement is approved by both parties. Thereafter, in the UK the current, unified framework of EU trade law will be replaced by an interface between UK and EU trade law underpinned by WTO law. For business, managing this change will be complex, and additional uncertainty could result from negotiation of the terms of the new UK-EU trade agreement in areas such as the introduction of customs controls and trade facilitation practices, the treatment of product regulations and standards, and rules of origin.

From 30 March 2019, the European Union (Withdrawal) Act will convert EU Regulations into UK law and will preserve existing UK trade laws that derive from EU Directives in a new category of "retained EU law".

In some areas, additional legislation is needed since the Withdrawal Act cannot be used to impose or increase taxation, including customs and excise duties and VAT. The Trade Bill (Trade Act 2018) and the Customs Bill (Taxation (Cross-Border Trade) Act 2018) are awaiting approval in Parliament. They will create the authority for the UK Government to: (i) set and collect customs duties; (ii) implement trade and customs regulations, including ensuring that the Customs and Excise Management Act 1979 continues to have effect; (iii) implement UK trade agreements with countries that already have FTAs with the EU; (iv) implement UK legal obligations in the WTO; and (v) establish the UK Trade Remedies Authority and impose trade remedy measures consistently with WTO rules. Additional legislation will be needed at a later stage to implement the results of negotiations with the EU and with other FTA partners.

Business will also have to deal with issues of devolution where legislation involves powers which have been granted to Northern Ireland, Wales and Scotland. The bottom line will be a proliferation of new law in the UK, governing trade with the EU and trade with other third countries in goods and services.

Click here to download PDF.

Our Brexit countdown illustrates the key dates and milestones on the road to Brexit.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© White & Case LLP | Attorney Advertising

Written by:

White & Case LLP

White & Case LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.