The Reset in the UK-EU trading relationship  – Evolution not revolution

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On 19 May 2025, the Prime Minister Keir Starmer will meet with the President of the European Commission Ursula von der Leyen and António Costa, the President of the European Council for the first EU-UK summit since the UK’s withdrawal from the EU.

The summit will be an important moment for the UK Government as it seeks to “reset” relations with the EU.  What is less clear is what might come from the summit in terms of proposals to take the trading relationship forward and build on the blocks set out by the Trade and Cooperation Agreement which currently underpins the relationship.

What does the UK Government want?

Writing in the Daily Telegraph at the start of February 2025, Nick Thomas-Symonds, the UK Minister for European Union relations set out the UK Government’s aims for a reset with the EU in relation to the trading relationship:

“For this Government, our reset with the EU means the UK being safer, more secure and increasingly prosperous. It does not mean hitting rewind. We are not undoing Brexit. There is no opacity over the outcome of the referendum in 2016. Yet, five years on, we can see some of the negative impacts of the current deal emerging here at home, as well as in Europe.

Trade is a clear example. Despite the EU being our largest trading partner, with trade in 2023 worth over £800 billion, research by Aston University found that, compared to a counterfactual scenario without Brexit, between 2021 and 2023, exports to the EU were down 27 per cent and imported goods down 32 per cent…

… To raise living standards, we need to build export and investment opportunities, reducing barriers to trade. This is of mutual benefit: the chancellor and the president of the European Commission are both pressing the need for cooperation to drive innovation, boost growth and reduce consumer costs.”

To inform what the UK might be looking for and ruling out, it is best to look back to the Labour Party manifesto ahead of the General Election.  The manifesto ruled out returning to the EU Single Market, the Customs Union and any reintroduction of freedom of movement.  Instead, it suggested making Brexit work and resetting the relationship. 

In terms of specifics the manifesto stated:

“Instead, Labour will work to improve the UK’s trade and investment relationship with the EU, by tearing down unnecessary barriers to trade. We will seek to negotiate a veterinary agreement to prevent unnecessary border checks and help tackle the cost of food; help our touring artists; and secure a mutual recognition agreement for professional qualifications to help open up markets for UK service exporters.”

The manifesto also committed to seeking “an ambitious new UK-EU security pact to strengthen co-operation on the threats we face”. Given the ongoing Russian aggression in Ukraine and the increasingly isolationist approach of the new US administration under President Trump, agreement towards negotiating a security pact is likely to be one of the easier wins at the summit. 

In a recent blog for the UK in a Changing Europe, Professor Simon Usherwood (Senior Fellow, UK in a Changing Europe and Professor of Politics and International Studies, The Open University) questioned whether the UK knew what it wanted from its relationship with Europe, even following EU exit. 

On the position of the current UK Government, Professor Usherwood wrote:

“Even the arrival of a Labour government in 2024, with its red lines, has struggled to say what it does want, rather than what it doesn’t. All the talk of a ‘reset’ and an ‘ambitious new relationship‘ might have produced some more friendly personal relationships in Brussels and member states, but on the eve of a UK-EU summit the absence of a strong vision for this relationship is rather conspicuous.”

What does the European Union want?

The European Council (the representatives of Heads of State and Government of EU Member States) has published its Agenda Highlights.  According to the document:

“The summit will be an opportunity to demonstrate a common stance in working together for peace and security in Europe and to establish a new strategic partnership.”

The agenda for the summit includes discussion on strengthening cooperation on global issues and the full implementation of the Withdrawal Agreement and the Windsor framework (formerly the Ireland and Northern Ireland Protocol) which govern the UK’s departure from the EU.

The agenda also includes discussing “further exploiting the trade and cooperation agreement”.  Under this item, the European Council is proposing the following:

“Discussions at the summit will revolve around how to further explore the potential of the agreement, notably in the areas of:

  • security and defence
  • sanitary and phytosanitary measures
  • internal security and criminal matters
  • emission trading systems
  • people-to-people contacts, including migration and youth mobility

Special attention will also be given to access to waters for fisheries and energy cooperation.”

The Scottish perspective?

The Scottish Government published its priorities for developing the Trade and Cooperation Agreement in a letter to the Scottish Parliament Constitution, Europe, External Affairs and Culture Committee on 10 June 2024.  The letter set out the following priorities:

  • A comprehensive sanitary and phytosanitary agreement.
  • Full participation in relevant EU programmes – including Erasmus+, Creative Europe, and European Territorial Cooperation.
  • Professional mobility in sectors across the economy, including improved arrangements for creative professionals and mutual recognition of professional qualifications.
  • Maximised opportunities for young people to live, work, study and learn in the EU.
  • Greater cooperation on security and law enforcement.
  • Closer energy cooperation, to support shared priorities on energy security and the transition to net zero.
  • Minimised technical barriers to trade.

Alongside the Scottish Government’s perspective, the Scottish Parliament’s Constitution, Europe, External Affairs and Culture Committee has undertaken an inquiry into the Review of the UK EU Trade and Cooperation Agreement.  The inquiry was split over two phases with phase one focusing on trade in goods and phase two focusing on trade in services

The Committee published the UK-EU Trade and Cooperation Agreement: Barriers to trade in goods and opportunities to improve the UK-EU trading relationship report on 10 September 2024. The report made the following recommendations:

  • That the new UK Government should negotiate improvements to the trading relationship to better facilitate UK-EU trade.  
  • Non-tariff barriers have placed “considerable administrative, resource and cost pressures on businesses”, and “harmed exports”. Key amongst these barriers include the requirements for customs formalities and regulatory checks for all exports from the UK to the EU.  
  • There is a need for the UK to seek closer regulatory alignment with the EU.  
  • The UK Government should seek a veterinary agreement with the EU to significantly reduce border checks and the administrative burden on exports of agri-foods.   
  • The UK Government should seek a mutual recognition agreement with the EU on conformity assessments, and the linkage of the respective UK and EU emissions trading schemes.  

 More recently, the Committee has undertaken a second inquiry focused on issues around trade in services, youth mobility and touring artists and creative professionals. The Committee published its inquiry report UK-EU Trade and Cooperation Agreement: trade in services, youth mobility, and touring artists; and opportunities to improve the UK-EU trading relationship on 16 May 2025.

The devil will be in the detail

What is less clear ahead of the summit, is what the outcomes might look like in relation to developing the trading relationship, either by amending the TCA or finalising a new agreement such as on mobility. A Centre for European Reform blog has suggested that there will be a ‘common understanding’ in the form of a road map that will set out areas for future work. These high-level commitments would then require negotiation of the specifics with the devil being in the detail

For example, a key UK ask is that a sanitary and phytosanitary (SPS) agreement could be reached.  However, during its visit to Brussels in November 2024, the Constitution, Europe, External Affairs and Culture Committee heard from EU officials that any SPS agreement would require the UK to align with EU rules in the animal and plant health sphere.  On an SPS agreement, the Centre for European Reform wrote:

“Aligning with the EU on SPS means that the UK will continue to demand that US farm exports follow European standards. The UK may not want to choose between the US and the EU, but when push comes to shove, the economic relationship with the EU will always be more significant. And that in turn means there will never be a full-blown Free Trade Agreement between the US and the UK, since the Americans’ number one demand for such a deal is that the British should remove the regulatory barriers that keep out US farm goods. However, one major beneficiary of an SPS deal would be Northern Ireland: the closer UK regulations come to those of the EU, the less is the need for border controls on goods crossing the Irish Sea from Great Britain to Northern Ireland.”

Scotland’s food and drink industry would also welcome an SPS agreement which would make  it easier to trade with the EU once again.

An EU ask is for a youth mobility agreement.  Recent media reports have suggested that the UK Government position is shifting towards agreeing to negotiate such an agreement, however, here again compromise will be needed as the Centre for European Reform highlights:

“EU demands have been ambitious, wanting young people to be able to work, study or travel in the UK for as long as they can fund themselves, and it wants EU students to be charged the same tuition fees as British students pay at British universities. This is politically difficult for the UK and in particular for the Home Office; youngsters entering the UK would push up the net immigration figures, which are politically toxic. So the British have made a much more limited counter-offer, with time limits and caps on numbers. Negotiators will have to pare back their demands to bridge what remains a considerable gap. The UK has not demanded numerical quotas of its other partners in youth mobility agreements, whilst the EU’s demand that its students should pay no more than British students is unrealistic.” 

An area for potential disagreement is fisheries.  The EU (mainly promoted by France) may see an opportunity to revisit the fisheries element of the TCA given the current arrangements are due to expire in 2026.  As set out in a previous SPICe briefing, the Trade and Cooperation Agreement saw both sides agree upon a transitional arrangement, whereby the UK share of the Total Allowable Catch (TAC) would gradually increase from the levels previously applied under the Common Fisheries Policy over a six-year period.

Annex 35 of the TCA contains a list of shared stocks and it specifies the percentage of the TAC that shall be shared between the EU and the UK annually between 2021 and 2026. TACs in place at the end of this period would continue to apply beyond 2026 unless the parties agree otherwise. Some EU member states see the review of the TCA as an opportunity to re-visit how TAC’s might be shared after 2026 and may also try to link the fisheries issue to other areas of potential cooperation.  According to the UK in a Changing Europe:

“The EU has linked the consolidation of upcoming deadlines, particularly on fish, to the negotiation of new areas of cooperation, and might even time-limit new sectoral agreements to strengthen its hand in future talks.”

Whilst the summit on 19 May might take forward the UK-EU reset in terms of the trade relationship, it is likely to only set out high level areas upon which both sides agree further negotiation is required.  In terms of resetting the relationship, it is more likely to mark the beginning than the end of the process. 

Iain McIver, SPICe Research