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Our roadmap to fix the Brexit deal
Since it was established in 2021, the UK Trade and Business Commission (UKTBC) has been working to understand how our new trading relationships are impacting businesses and different sectors of the UK economy. And now we have the solutions.
We have hosted 38 evidence sessions, performed site visits, taken over 80 hours of live testimony from 234 expert witnesses, industry leaders and business owners and received written evidence submissions from over 200 organisations as part of an open consultation.
This report is a product of the extensive work we have undertaken and the valuable insights gained have culminated in the development of 114 actionable recommendations. These recommendations are designed to enhance the UK’s trading relationships, foster business growth, and navigate through the current challenging landscape.
We would like to extend our deepest gratitude to the Commission secretariat for all their support and advice and to our fellow Commissioners for giving so freely of their time and expertise. We would also like to thank all those businesses, trade associations, consumers, pressure groups, and individuals across the UK who have shared their knowledge, views and experiences. Your voices have helped shape our recommendations.
Although the UK’s trading prospects face significant challenges, the UK holds an abundance of talent, creativity, expertise, and world-leading businesses. Through the implementation of the recommendations outlined in this report, we can begin the process to overcome growth barriers and forge a resilient and prosperous future that benefits all citizens across every nation and region of the United Kingdom.
Alignment with EU Standards and Regulations
As the UK moves forward post-Brexit, establishing a clear regulatory framework that provides predictability and stability for businesses and investors is essential.
The UK Government should adopt a general policy of regulatory alignment with EU standards and regulations unless it is not in the UK's interests to do so.
This will enable businesses and investors both domestically and internationally to have confidence in the UK's regulatory foundations and will foster stronger relationships with trading partners, both now and in the future.
Outside of the Customs Union and Single Market, the UK can use its regulatory autonomy to address any future or new EU regulations on a case-by-case basis, enabling us to diverge from the EU approach where it is beneficial for our businesses and sectors, after consulting with affected stakeholders. By adopting this approach, the UK Government can ensure that regulatory coherence is maintained with the EU, thereby facilitating constructive engagement with the EU and other countries seeking to negotiate trade deals with the UK. Many non-EU countries already follow EU regulations.
A policy of regulatory alignment will provide a starting point for negotiations, while still allowing the UK to maintain its own regulatory autonomy. By taking this approach, the UK Government can reassure businesses and investors, both domestically and internationally, that the UK is committed to maintaining strong relationships with its trading partners, while still protecting the interests of UK businesses and sectors.
To mitigate the risks of divergent regulatory frameworks and ensure continued protection for UK consumers, the UK should maintain regulatory alignment with EU food safety standards.
4. The UK should maintain food safety standards aligned with those of the EU by adopting the key principles outlined in EU legislation, such as the General Food Law (Regulation (EC) No. 178/2002) and Regulation EC 852/2004 on the hygiene of foodstuffs.
Separate regulatory frameworks present a challenge for driving innovation in the food and drink industry. Collaborative efforts can contribute to the development of innovative food and drink products, but without them, the UK risks falling behind in the development of innovative food and drink products and processes.
5. The UK Government should seek to deepen collaboration on food and drink innovation with the EU and research to develop a shared understanding of emerging technologies, best practice, and regulatory challenges as applied to novel foods, food additives, and new production technologies.
Ensuring the safety and quality of the UK's food supply, particularly regarding chemical contaminants and residues in food, is crucial for protecting public health, promoting consumer confidence, and facilitating trade with EU partners.
By exchanging information, expertise, and best practice for the management of chemical contaminants and residues in food, the UK can base its approach to food safety on EU standards, bolstering consumer confidence and facilitating trade with EU partners.
6. The UK should strengthen its monitoring and control systems for chemical contaminants and residues in food, at least in line with EU requirements.
7. Maximum residue limits (MRLs) for pesticides, other contaminants, and veterinary drugs should be aligned with the EU, including Regulation (EC) No. 396/2005 and Regulation (EC) No. 470/2009.
8. The UK should enhance its national residue monitoring programmes and risk-based control systems to ensure compliance with EU regulations, incorporating regular testing and reporting of results.
Foodborne disease outbreaks pose a significant threat to public health and can have serious consequences for the food industry. To ensure the safety and protection of public health, coordination with EU institutions and member states on the surveillance and response to foodborne disease outbreaks is essential.
9. The UK should enhance its coordination with EU institutions and member states on the surveillance and response to foodborne disease outbreaks.
10. The UK should actively participate in the European Centre for Disease Prevention and Control (ECDC) surveillance networks and systems, such as the Rapid Alert System for Food and Feed (RASFF) and the European Surveillance System (TESSy). The UK should provide intelligence input to RASFF to facilitate a more effective and timely response to food safety threats.
11. The UK should collaborate closely with EU agencies and partners on epidemiological investigations, traceback efforts, and risk assessments related to foodborne disease outbreaks, ensuring access to EU databases, resources, and expertise.
The UK's departure from the European Union also led to a departure from European agencies related to the manufacture of goods with the potential for divergent regulations to increase costs, reduce competitiveness, and impact product safety and quality for UK consumers. For what are heavily traded and regulated international products, the UK would benefit from revisiting the current arrangements.
17. The UK should maintain regulatory alignment on manufactured products, in particular cars, aircraft, and medical devices with EU standards to facilitate trade and enhance the competitiveness of its manufacturing industries.
18. The UK should seek maximum cooperation in EU agencies related to manufactured goods to promote cooperation and harmonisation in the field of regulation and safety. Including:
European Chemicals Agency (ECHA)
European Union Intellectual Property Office (EUIPO)
European Medicines Agency (EMA)
European Aviation Safety Agency (EASA)
European Union Agency for Railways (ERA)
European Maritime Safety Agency (EMSA)
European Union Agency for the Cooperation of Energy Regulators (ACER)
19. The UK Government should engage in negotiations with the EU to define the terms of the UK's cooperation with these agencies, addressing issues such as financial contributions, access to information and resources, and representation in decision-making processes.
20. Where full accession is not possible, the UK Government should foster collaboration between UK regulatory authorities and the relevant EU agencies to share expertise, data, and best practices related to manufactured goods regulation and safety.
Having previously been a highly regarded participant in bodies such as UNECE and OECD, the UK risks becoming isolated from global regulatory frameworks related to the manufacturing of cars, aircraft, and other products, resulting in a lack of alignment with global standards and best practices, reducing the competitiveness of UK industries and potentially impacting product safety and quality for UK consumers.
21. The UK government should work strategically to maximise the UK’s influence over international standards. This will be essential to promote vital UK interests in the face of intense global competition and ensure that standards for fast-developing technologies such as artificial intelligence reflect UK values and consumer interests.
By being aligned with the EU, the UK can establish a pragmatic, sustainable, and long-term solution to the challenges posed by its system for regulating chemicals. By adopting the EU's risk management decisions, the UK can guarantee robust protection for human health and the environment, while also enabling seamless trade with the EU and other global partners.
22. The UK should adopt EU risk management decisions on chemicals but retain the ability to deviate.
The implementation of the new mark is crucial for maintaining high levels of product safety and quality, ensuring the competitiveness of UK businesses and maintaining consumer confidence in UK products. The UK Government must consider taking steps to remove the current uncertainty about when the regime will change and hence limit the resulting damage to both consumer and investor confidence.
23. The UK government should delay the mandatory use of the new UKCA marking until there is a clear demonstration that the marking offers tangible benefits to UK regulators, businesses and consumers.
24. The UK Government should use the intervening time to fully review the UKCA certification process and ensure that it is cost-effective, efficient and risk-based. This could involve simplifying documentation requirements, focusing on innovative digital solutions or reducing the need for third-party assessments.
25. The UK government should work closely with the EU in order to establish a plan for the mutual recognition of conformity assessment results. This would reduce trade friction considerably for UK businesses trading into the EU.
26. The UK Government should support maintaining the position of BSI within the European standardisation framework.
The UK's commitment to achieving net-zero emissions by 2050 requires a significant reduction in carbon emissions from businesses. The UK's implementation of an Emissions Trading System (ETS) is a step in the right direction, but without full alignment with the EU ETS framework, businesses may face additional costs.
27. The UK Government should engage in negotiations with the EU to establish a formal link between the UK and EU ETS, enabling the mutual recognition and trading of allowances between the two systems. The necessary legislative and regulatory measures should be implemented to enable this linkage, including provisions for ongoing monitoring, review, and dispute resolution.
The UK's transition to a low-carbon economy requires significant carbon reduction efforts from domestic industries. However, imported goods with embedded carbon emissions may be subject to different carbon pricing than domestic goods, leading to trade distortions and potential disadvantages for UK industries. This could hinder the UK's efforts to reduce carbon emissions and contribute to global efforts to combat climate change.
28. The UK Government should design and implement a UK Carbon Border Adjustment Mechanism (CBAM) that aligns with the EU CBAM scheme, ensuring consistency in the treatment of imported goods with embedded carbon emissions and reducing the reporting requirements needed to cooperate with the EU effectively.
29. The UK Government should implement efficient reporting and monitoring systems for the UK CBAM and periodically review and update the UK CBAM in line with the EU scheme to reflect developments in carbon pricing, international trade, and climate policy.
30. The UK should therefore engage in ongoing dialogue and cooperation with the EU and other international partners to monitor the effectiveness of carbon border adjustments and address any emerging challenges or opportunities.
The UK and the EU share a common goal of reaching net-zero emissions by 2050, but without energy cooperation, it may be difficult to achieve this objective. The UK and EU may face different challenges and opportunities in their respective energy sectors, which could create barriers to cooperation and hinder progress towards net-zero targets.
31. The UK Government should maintain Title VIII Energy Provisions and ensure they 'roll over' in the UK's agreements with the EU, facilitating continued cooperation and alignment in energy policy and regulation.
32. The UK Government should collaborate with the EU on the development and implementation of shared energy objectives, such as enhancing energy security, promoting renewable energy, and reducing greenhouse gas emissions.
33. The UK should prioritise North Sea energy cooperation, freeing up electricity trading arrangements.
The UK's commitment to achieving net zero requires collaboration with the EU to achieve shared climate goals. Without effective cooperation on initiatives, research, and investment in low-carbon technologies and energy infrastructure, the UK may struggle to meet its net-zero target, and progress towards global efforts to combat climate change may be hindered.
34. The UK Government should enhance cooperation with the EU in the pursuit of shared net-zero targets, focusing on joint initiatives, research, and investment in low-carbon technologies and energy infrastructure. This should include identifying areas of alignment, such as EU deforestation and corporate reporting requirements, and developing joint strategies to address these issues.
35. To ensure ongoing communication and collaboration on climate and energy policy, the UK should establish mechanisms for cooperation between the UK and EU authorities, facilitating the exchange of best practices and information, allowing both the UK and the EU to learn from each other's experiences and progress towards shared climate goals.
36. The UK should rejoin the European Environment Agency.
Ensuring consistency and alignment with the EU on sustainability and trade policies is critical for maintaining a healthy and mutually beneficial economic relationship. Without consistent and aligned policies, trade between the UK and the EU may be hindered, and companies may face dual burdens in complying with different regulations and standards.
37. The UK Government should ensure that UK measures related to corporate action on trade, such as deforestation and sustainability requirements, are consistent with those required by EU law.
38. The UK Government should establish a sustainable trade dialogue with the EU and other affected countries to seek to minimise the impact of trade-related measures on UK businesses and consumers. Dialogue should focus on identifying areas of alignment between the UK's and the EU's sustainability and trade policies, as well as promoting cooperation and the exchange of best practices in the areas of sustainability and trade.
39. The UK should at least align with evolving EU rules and standards on health and safety protection for workers, environmental quality standards and consumer protection.
40. The UK should maintain airline passenger compensation at least in line with EU Regulation 261/2004 to ensure that passengers are fairly compensated for any disruptions or cancellations.
41. The UK Government should revive UK participation in the Horizon research and innovation programme by negotiating an agreement with the EU that allows UK researchers and businesses to continue their participation in Horizon programmes.
42. The UK Government should rejoin the Erasmus Programme, which provides opportunities for UK students and academics to study, work, and train in EU countries, and vice versa.
A new UK Board of Trade
Effective trade is crucial to the success of the UK, and in order to achieve the best possible outcomes, a consensus must be reached across nations, regions, businesses and interest groups in the UK.
To ensure this happens, the UK Government should establish an independent agency, modelled after the highly regarded Swedish Board of Trade, which will be accountable to the Secretary of State for Business and Trade.
This new agency should replace the existing Board of Trade and be responsible for a range of tasks including analysing the UK's trading performance, conducting impact assessments of new trade deals, and overseeing the implementation of existing agreements to identify areas where they can be improved. The agency should also monitor how UK nations and regions are affected by international trade agreements and conduct horizon scans to identify emerging issues of importance.
Like the OBR, the UK Board of Trade should be fully independent of government, with its own staff and governance structure. Board members should reflect the breadth of trade policy stakeholders.
By embracing this approach, the UK can elevate its trade policy to new heights of professionalism, guaranteeing that all stakeholders are included and the UK secures optimal outcomes.
Specifically, the new UK Board of Trade should:
53. The UK Board of Trade should advise the UK Government on how the UK can minimise the trade barriers arising from our regulatory choices and identify areas where the UK can gain economic advantage from actively aligning or diverging from the regulations of our major markets.
54. The UK Board of Trade should ensure trade costs are considered as a formal part of the regulatory process, and inform, assist and consult UK companies on trade and regulatory issues.
55. The UK Board of Trade should conduct an annual survey of UK stakeholder experience of UK trade policy and provide an entry point into government for UK companies.
56. The UK Board of Trade should collaborate with relevant parliamentary committees to analyse and assess the costs and benefits of different trade policy options and provide evidence-based recommendations to the UK Government.
57. The UK Board of Trade should assess the impact of trade policy options on various policy areas such as climate change, employment, and agriculture, to enable the UK Government to make informed decisions that align with its wider policy objectives.
58. The UK Board of Trade should produce a comprehensive annual trade report, modelled on the US and EU trade reports, and which assesses the UK’s trade policy developments.
59. The UK Board of Trade board should consist of board members, including representatives from major UK business organisations, trade unions, devolved governments, SMEs, and senior experts in trade and regulation.
60. The composition of temporary members should be tailored to the nature of any trade deals under negotiation. By including a diverse range of stakeholders and experts, the UK Board of Trade can ensure that trade policy is informed by a broad spectrum of perspectives and expertise, leading to better outcomes for the UK.
61. The UK Board of Trade should conduct impact assessments of trade agreements to ensure they are consistent with domestic policy objectives and do not have unintended consequences. Such assessments should be evidence-based, considering the potential social, economic, and environmental impacts of the proposed trade agreements.
Create a UK visa system fit for purpose
The UK is currently experiencing shortages of labour in numerous sectors, including hospitality, agriculture, and healthcare.
Labour mobility, encompassing a spectrum from independent contractors to highly skilled professionals, plays a pivotal role in the prosperity of the UK economy. Given the UK's stature as a leading services-based economy, addressing this issue should be a central priority for economic growth alongside training up UK workers.
To help tackle these challenges, implementing a youth mobility scheme or a cultural worker programme should be explored.
65. The UK should participate in the EU 'List of Travellers' Scheme to facilitate visa-free school visits for EU schools, making it easier for EU students to visit the UK for educational purposes.
66. The UK Government should prioritise a comprehensive review of the implementation and uptake of the Seasonal Worker Visa Scheme to determine areas for improvement.
67. The UK should develop a Visa Waiver Agreement with the EU for those working in the cultural sector on a temporary basis.
68. The UK should negotiate bilateral cultural agreements for work permits with individual EU Member States.
69. The UK should reduce the cost of ATA Carnets and work towards a cultural exemption for musical instruments and equipment.
70. The UK Government should review and relax its business visitor rules to enable corporations to bring in highly skilled workers for short-term projects. This will support the growth of businesses that rely on international talent and enhance the UK's capability.
71. The UK Government should consider extending the maximum permissible stay under business visas to enable businesses to pursue longer-term projects and improve business continuity.
72. The UK Government should conduct a review of the visa costs and paperwork facing UK businesses and seek to make the system more accessible to businesses of all sizes. This will promote a more favourable business environment for international trade.
73. The UK Government should examine the possibility of relaxing Mode 4 restrictions with major trade partners where this can assist negotiations for deeper Free Trade Agreements. This will promote greater cooperation and foster deeper trade relationships.
75. The UK Government should prioritise targeted skills development programmes in the UK to address labour shortages in specific sectors, such as healthcare and hospitality. These programmes should focus on training workers with the skills necessary to fill these roles, and should be tailored to the needs of individual sectors. This should include vocational and further education, which could be further boosted by exchange options.
Improving the TCA
While broad in scope, the Trade and Cooperation Agreement between the UK and EU does not provide sufficient depth for many businesses who have faced costs which have limited trade. In aggregate, this is costing the UK economicall
Building on the existing framework, the UK and EU should seek to reduce areas of friction and explore opportunities for increased cooperation. This needs to be driven jointly at a political level, which can incorporate the review of implementation scheduled for 2026, as well as the detailed recommendations listed elsewhere in this report, in particular in Sections 1-3.
There are interests and sensitivities for both the UK and EU, but there should be a path to delivering improvements to benefit business and stakeholders on both sides.
76. The UK government and EU should task officials with developing a roadmap of TCA improvements to be delivered over a multi-year period, which should then be agreed and overseen by Ministers.
77. Where possible, the UK Government should seek to ensure the UK’s participation in EU agencies as part of the 2026 TCA review, in line with the recommendations listed in Section 1.3 of this report.
78. The UK and EU should extend the current rules of origin grace period for electric vehicles.
79. The UK should align its rules of origin with the pan-Euro-Mediterranean preferential rules of origin to facilitate participation in regional supply chains. This will allow for diagonal cumulation of origin, which can help to reduce the administrative burden on businesses and promote cross-border trade.
80. The UK should prepare for the renegotiation of the fisheries chapter of the TCA, by focusing on improved quota shares for the UK's fishing fleet, improved control over UK waters and the reduction of non-tariff barriers, such as shellfish water quality.
81. The UK and EU should work together to develop a common approach to the digital economy, including by promoting cross-border data flows and standards for digital products and services.
82. The UK should review cabotage arrangements as outlined in the TCA to allow for greater flexibility in EU travel for UK-based operators and vice versa.
83. The UK Government should seek to include a new mobility chapter as part of the 2026 TCA review with the EU in line with the recommendations listed in Section 3 of this report.
Leveraging the UK’s existing global trade relations
The UK holds a vast network of embassies and trade agreements that offer invaluable assistance to domestic companies. However, in an era of increasing protectionism, it is crucial for the UK government to not only strengthen existing agreements and establish new ones but also emphasise the importance of effective implementation.
Recognising the significance of the UK's soft power and world-renowned universities is vital and warrants appropriate attention. By prioritising these aspects, the UK government can ensure that UK companies receive the necessary support and resources to thrive on the global stage.
Instead of exclusively focusing on its own trade deals as the ultimate objective, the government should adopt a facilitator role to promote the success of UK companies. By creating an enabling environment that nurtures business growth, the UK government can enhance the competitiveness of the UK in the global market, thus contributing to the country's overall economic prosperity.
84. To achieve this, the UK Government should seek deepening of existing relationships with key trading partners, development of new partnerships, and utilising diplomatic and trade promotion support to facilitate economic cooperation.
85. The UK should prioritise promoting its soft power assets, including its world-renowned universities and research institutions, to attract foreign investment and talent to the UK.
86. The UK should seek to establish a trade forum as part of the European Political Community.
87. The UK should initiate and maintain regular dialogues with individual EU Member States on specific areas of mutual interest such as trade, security, and other forms of cooperation.
88. The UK should ensure the effective implementation of existing FTAs and seek to deepen these agreements where possible.
89. The UK should work to strengthen its transatlantic dialogue with the US and seek agreements on digital trade and financial services regulatory cooperation.
90. The UK should explore the scope for mutually beneficial agreements with countries where none are currently in place, such as Indonesia, Thailand, and Brazil. These agreements need not necessarily follow the FTA model and should be backed up by stronger diplomatic and trade promotion support.
91. The UK should make the resolution of market access cases a priority for its embassies around the world.
92. The UK should join global efforts to guarantee free trade in critical raw materials.
93. The UK Government should convene a trade policy dialogue of similar “middle powers” of global trade seeking to protect global trade rules.
94. The UK should reinvigorate the development of its soft power capabilities, including cultural and diplomatic outreach, to support its trade and investment strengths. This should include promoting the role of institutions such as the British Council and BBC in shaping global perceptions of the UK.
95. The UK should improve visa treatment for universities to ensure the UK has access to the best talent and expertise from around the world.
96. The UK should maintain its generous trading scheme for developing countries and consider allowing full cumulation between countries in the African Continental Free Trade Agreement.
Parliamentary oversight
To ensure democratic accountability and alignment of trade policy with domestic priorities, elected representatives, including MPs and devolved assemblies, should be involved in meaningful discussions and voting on trade policy decisions.
The UK Government should increase parliamentary scrutiny of trade policy by providing regular reports to Parliament on the progress of trade negotiations and opportunities for parliamentary committees to scrutinise specific trade agreements.
This approach will ensure that trade policy decisions are subject to proper scrutiny and reflect the views of elected representatives and their constituents.
97. The UK Government should hold a parliamentary debate on the objectives for new Free Trade Agreement negotiations on the basis of a mandate and outline impact assessment.
98. The UK Government should subject completed new Free Trade Agreements and the independent impact assessments surrounding them to parliamentary scrutiny and approval well ahead of ratification and implementation.
99. The UK Government should hold an annual debate on the country's trade strategy and performance, based on the UK Board of Trade's annual report.
An integrated government
Active trade policy must not only support the economy, but also other key objectives such as the transition to a net-zero economy, skills development, and supporting small businesses. Achieving this requires a coordinated and integrated government approach, as no single department can address all of these objectives alone.
Stakeholders have highlighted that government departments often fail to communicate and collaborate effectively, a problem that has become more acute during recent times of economic uncertainty. To successfully support UK policy objectives through trade, the government must ensure that all departments work together in a cohesive and efficient manner.
100. The UK Government should develop a trade strategy including policy trade-offs and agreement priorities.
101. The UK government should establish a dedicated learning programme for ongoing negotiations with the EU. This programme should provide comprehensive training on modern negotiating practices and the broader trade context.
102. The UK government should implement a secondment programme between government officials and stakeholders, businesses, and civil society.
103. The UK should implement a single window system for the entry of trade data, including digitising import and export processes, to streamline border and customs processes.
104. The UK should deliver on its public commitments by implementing a border operating model for trade from the EU, which takes a modern risk-based approach to imports (this will be facilitated by veterinary equivalence, see recommendation 14).
105. The UK should reinvigorate trusted trader programmes to facilitate trade and reduce administrative burdens for businesses.
106. The UK should improve facilities and processes at Dover to reduce waiting times for lorry drivers, which will enhance the UK's attractiveness as a trading partner and reduce costs for businesses.
107. The UK should enhance engagement with devolved governments and city-region mayors to align priorities on trade policy.
108. The UK should actively seek to attract inward investment for new production facilities across the country.
109. The UK Board of Trade should ensure that trade deal impact assessments and reports on UK trade policy performance provide strong regional breakdowns to understand the impact on different regions.
110. The UK should build capacity in public sector organisations across the country to enable constructive engagement with the UK Government on trade policy.
111. The UK should seek particular provisions in trade agreements to allow Northern Ireland to take full advantage of new export opportunities by allowing for all-Ireland input to count as originating from the UK.
112. The UK should ensure stable funding and support schemes are in place to assist SMEs who want to start exporting, with the option for scale-up assistance such as support with trade fairs.
113. The UK should provide targeted market access assistance to smaller companies, particularly those lacking resources to overcome issues, designating one commercial officer in embassies as the lead for SMEs.
114. The UK should develop content for SME chapters in trade agreements, focusing on the real issues faced by SMEs in areas such as visas and consignment costs, and by bringing in thresholds which mean that SMEs can avoid certain measures.