According to the Brexit trade agreement (the Trade and Cooperation Agreement (TCA)), trade between the EU and the UK will remain quota and tariff free. ‘Quota free’ means that trade will not be restricted in quantity by the authorities on either side. ‘Tariff free’ means that customs duties will not be collected by the UK authorities on imports from the EU nor by the EU authorities on imports from the UK.
Article ‘GOODS .5: Prohibition of customs duties’ on page 20 of the agreement states that:
Except as otherwise provided for in this Agreement, customs duties on all goods originating in the other Party shall be prohibited.
This free-trade agreement was taken by many people to mean that trade would be unhindered, with no duties being payable. In fact, as many importers and exporters are finding, trade is not as ‘free’ as it was before January 2021. There are four sources of ‘friction’.
Tariffs on goods finished in the UK
This has become a major area of concern for many UK companies. When a good is imported into the UK from outside the EU and then has value added to it by processing, packaging, cleaning, remixing, preserving, refashioning, etc., under ‘rules of origin’ regulations, it can only count as a UK good if sufficient value or weight is added. The proportions vary by product, but generally goods must have approximately 50% UK content (or 80% of the weight of foodstuffs) to qualify for tariff-free access to the EU. For example, for a petrol car, 55% of its value must have been created in either the EU or UK. Thus cars manufactured in the UK which use many parts imported from Japan, China or elsewhere, may not qualify for tariff-free access to the EU.
In other cases, it is simply the question of whether the processing is deemed ‘sufficient’, rather than the imported inputs having a specific weight or value. For example, the grinding of pepper is regarded as a sufficient process and thus ground pepper can be exported from the UK to the EU tariff free. Another example is that of coal briquettes:
The process to transform coal into briquettes (including applying intense pressure) goes beyond the processes listed in ‘insufficient processing’ and so the briquettes can be considered ‘UK originating’ regardless of the originating status of the coal used to produce the briquettes.
In the case of many garments produced in the UK and then sold in retail chains, many of which have branches in both the UK and EU, generally both the weaving and cutting of fabric to make garments, as well as the sewing, must take place in the UK/EU for the garments to be tariff free when exported from the UK to the EU and vice versa.
Precise details of rules of origin are given in the document, The Trade and Cooperation Agreement (TCA): detailed guidance on the rules of origin.
Many UK firms exporting to the EU and EU firms exporting to the UK are finding that their products are now subject to tariffs because of insufficient processing being done in the UK/EU. Indeed, with complex international supply chains, this is a major problem for many importing and exporting companies.
Rules of origin require that firms provide documentation itemising what parts of their goods come from outside the UK/EU. Then it has to be determined whether tariffs will be necessary on the finished product. This is time consuming and is an example of the increase in ‘red tape’ about which many firms are complaining. As the Evening Standard article states:
Exporters have to be able to provide evidence to prove the origin of their products’ ingredients. Next year, they will also have to provide suppliers’ declarations too, and EU officials may demand those retrospectively, so exporters need to have them now.
The increased paperwork and checks add to the costs of trade. Some EU companies are stating that they will no longer export to the UK and some UK companies that they will no longer export to the EU, or will have to set up manufacturing plants or distribution hubs in the EU to handle trade within the EU.
Other companies are adding charges to their products to cover the costs. As the Guardian article states:
“We bought a €47 [£42] shelf from Next for our bathroom,” said Thom Basely, who lives in Marseille. “On the morning it was supposed to be delivered we received an ‘import duty/tax’ demand for over €30, like a ransom note. It came as a complete surprise.”
In evidence given to the Treasury Select Committee (Q640) in May 2018, Sir Jon Thompson, then Chief Executive of HMRC, predicted that leaving the single market would involve approximately 200 million extra customs declarations on each side of the UK/EU border at a cost of £32.50 for each one, giving a total extra cost of approximately £6.5bn on each side of the border for companies trading with Europe. Although this was only an estimate, the extra ‘paperwork’ will represent a substantial cost.
Previously, goods could be imported into the UK without paying VAT in the UK on value added up to that point as VAT had already been collected in the EU. Similarly, goods exported to the EU would already have had VAT paid and hence would only be subject to the tax on additional value added. The UK was part of the EU VAT system and did not have to register for VAT in each EU country.
Now, VAT has to be paid on the goods as they are imported or released from a customs warehouse – similar to a customs duty. This is therefore likely to involve additional administration costs – the same as those with non-EU imports.
The UK is a major exporter of services, including legal, financial, accounting, IT and engineering. It has a positive trade in services balance with the EU, unlike its negative trade in goods balance. Yet, the Brexit deal does not include free trade in services. Some of the barriers to other non-EU countries have been reduced for the UK in the TCA, but UK service providers will still face new barriers which will impose costs. For example, some EU countries will limit the time that businesspeople providing services can stay in their countries to six months in any twelve. Some will not recognise UK qualifications, unlike when the UK was a member of the single market.
The financial services supplied by City of London firms are a major source of export revenue, with about 40% of these revenues coming from the EU. Now outside the single market, these firms have lost their ‘passporting rights’. These allowed such firms to sell their services into the EU without the need for additional regulatory clearance. The alternative now is for such firms to be granted ‘equivalence’ by the EU. This has not yet been negotiated and even if it were, does not cover the full range of financial services. It excludes, for example, banking services such as lending and deposit taking.
Leaving the single market has introduced a range of frictions in trade. These are causing severe problems to some importers and exporters in the short term. Some EU goods are now unavailable in the UK or only so at significantly higher prices. Some exporters are finding that the frictions are too great to make their exports profitable. However, it remains to be seen how quickly accounting and logistical systems can adjust to improve trade flows between the UK and the EU.
But some of these frictions, as itemised above, will remain. According to the law of comparative advantage, these restrictions on trade will lead to a loss of GDP. And these losses will not be spread evenly throughout the UK economy: firms and their employees which rely heavily on UK–EU trade will be particularly hard hit.
- EU firms refuse UK deliveries over Brexit tax changes
BBC News, Robert Plummer (5/1/21)
- Brexit trade problems: what’s gone wrong and can it be fixed?
The Conversation, Billy Melo Araujo (14/1/21)
- Brexit: parcels of grief
Turbulent Times, Richard North (8/1/21)
- UK retailers stumped by post-Brexit trade deal with EU
Financial Times, Jonathan Eley and Daniel Thomas (7/1/21)
- Pan-EU food supply chains hit by Brexit trade deal
Financial Times, Peter Foster, Arthur Beesley and Sam Fleming (6/1/21)
- Customers in Europe hit by post-Brexit charges when buying from UK
The Guardian, Jon Henley (7/1/21)
- Brexit: The reality dawns
BBC News, Scotland, Douglas Fraser (8/1/21)
- Post-Brexit customs systems not fit for purpose, say meat exporters
BBC News, Simon Jack (15/1/21)
- Baffling Brexit rules threaten export chaos, Gove is warned
The Observer, Toby Helm (10/1/21)
- Shock Brexit charges are hurting us, say small British businesses
The Observer, Toby Helm and Michael Savage (17/1/21)
- ‘A Brexit nightmare’: the British businesses being pushed to breaking point
The Observer, Toby Helm (24/1/21)
- Debenhams closes online business in Ireland as 50 major UK retailers face EU tariffs
ITV News, Joel Hills (7/1/21)
- The Brexit deal is being celebrated as though it removes all tariffs. It doesn’t
Prospect, Sam Lowe (8/1/21)
- As Marks and Spencer warns of Brexit nightmare, what are these Rules of Origin red tape issues?
Evening Standard, Jim Armitage (9/1/21)
- UK VAT after the transitional period
The Institute of Chartered Accountants in England and Wales (31/12/20)
- The Brexit deal and the services sector
UK in a Changing Europe, Sarah Hall (28/12/20)
- What does the Brexit trade deal mean for financial services?
UK in a Changing Europe, Sarah Hall (27/12/20)
- Explain what is meant by ‘rules of origin’.
- If something is imported to the UK from outside the UK and then is refashioned in the UK and exported to the EU but, according to the rules of origin has insufficient value added in the UK, does this mean that such as good will be subject to tariffs twice? Explain.
- Are tariffs exactly the same as customs duties? Is the distinction made in the Guardian article a correct one?
- Is it in the nature of a free-trade deal that it is not the same as a single-market arrangement?
- Find out what arrangement Switzerland has with the EU. How does it differ from the UK/EU trade deal?
- What are the advantages and disadvantages of the Swiss/EU agreement over the UK/EU one?
- Are the frictions in UK–EU trade likely to diminish over time? Explain.
- Find out what barriers to trade in services now exist between the UK and EU. How damaging are they to UK services exports?
At 23:00 on 31 December 2020, the UK withdrew from the European single market. This ended the transition period which followed the UK’s departure from the EU on 31 January 2020. But, with the Trade and Cooperation Agreement (‘the deal’) signed on 30 December, it was agreed that there would be no tariffs or quotas on trade in goods between the UK and the EU.
So what are the new economic relations between the EU and the UK and how will they impact on the UK economy? What new restrictions are there on trade in goods and on the movement of labour and capital? How is trade in services, including financial services, affected? What new agreements, such as on fishing, will replace previous agreements?
What will happen to trade between Northern Ireland and the Republic of Ireland? What will happen to trade between Great Britain and Northern Ireland?
What will happen to regulations over standards of traded products and their production? Will the UK government be able to provide subsidies or other types of support for goods or services exported to the EU? How will disputes about standards and support to companies be resolved?
How will trade with non-EU countries change? If the EU has trade agreements with such countries, do these agreements now apply to trade between the UK and such countries? How free is the UK now to negotiate new trade agreements with non-EU countries? How will the UK’s negotiating strength be affected by its withdrawal from the EU?
Rather than listing the changes here, follow the links below to the articles and assess the nature of the changes and then attempt the questions. The articles represent a balance of views.
What is clear is that these are all big issues and are likely to have a significant impact on the UK economy. Most economists argue that the net effect will be negative on trade and economic growth, but there is huge uncertainty about the magnitude of the effects. Much will depend on how arrangements between the UK and the EU develop over the coming months and years.
- Brexit deal explained: What will be the impact of UK’s agreement with EU?
Sky News, Ed Conway (24/12/20)
- Brexit deal: What is in it?
BBC News, Chris Morris (28/12/20)
- Brexit: What are the key points of the deal?
BBC News, Tom Edgington (30/12/20)
- Brexit trade deal explained: the key parts of the landmark agreement
Financial Times (25/12/20)
- The key details of the Brexit deal summarised, from trade to fishing
The Telegraph, James Crisp and Gordon Rayner (3/1/21)
- Committees, visas and climate change: Brexit experts’ verdicts on the deal details
The Guardian, Lisa O’Carroll (28/12/20)
- The left must stop mourning Brexit – and start seeing its huge potential
The Guardian, Larry Elliott (31/12/20)
- The Guardian view on Britain out of the EU: a treasure island for rentiers
The Guardian, Editorial (27/12/20)
- Brexit Is Finally Done, but It Already Seems Out of Date
New York Times, Mark Landler (30/12/20)
- Towards a modern UK-EU trade relationship
Best for Britain, David Henig (28/12/20)
- Brexit Is a New World Businesses Still Need to Figure Out
Bloomberg, Deirdre Hipwell, Craig Trudell, and Dara Doyle (1/1/21)
UK and EU documents
- Summarise the main features of the Trade and Cooperation Agreement and how the UK’s new relationship with the EU differs from being a member.
- What are the potential economic benefits from being outside the EU?
- What are the economic drawbacks for the UK from having left the EU, albeit with the new Trade and Cooperation Agreement?
- On balance, do you think that the UK will gain or lose economically from having left the EU? Explain your answer.
There have been many analyses of the economic effects of Brexit, both before the referendum and at various times since, including analyses of the effects of the deal negotiated by Theresa May’s government and the EU. But with the prospect of a no-deal Brexit on 31 October under the new Boris Johnson government, attention has turned to the effects of leaving the EU without a deal.
There have been two major analyses recently of the likely effects of a no-deal Brexit – one by the International Monetary Fund (IMF) and one by the Office for Budget Responsibility (OBR).
The first was in April by the IMF as part of its 6-monthly World Economic Outlook. In Scenario Box 1.1. ‘A No-Deal Brexit’ on page 28 of Chapter 1, the IMF looked at two possible scenarios.
Scenario A assumes no border disruptions and a relatively small increase in UK sovereign and corporate spreads. Scenario B incorporates significant border disruptions that increase import costs for UK firms and households (and to a lesser extent for the European Union) and a more severe tightening in financial conditions.
Under both scenarios, UK exports to the EU and UK imports from the EU revert to WTO rules. As a result, tariffs are imposed by mid-2020 or earlier. Non-tariff barriers rise at first but are gradually reduced over time. Most free-trade arrangements between the EU and other countries are initially unavailable to the UK (see the blog EU strikes major trade deals) but both scenarios assume that ‘new trade agreements are secured after two years, and on terms similar to those currently in place.’
Both scenarios also assume a reduction in net immigration from the EU of 25 000 per year until 2030. Both assume a rise in corporate and government bond rates, reflecting greater uncertainty, with the effect being greater in Scenario B. Both assume a relaxing of monetary and fiscal policy in response to downward pressures on the economy.
The IMF analysis shows a negative impact on UK GDP, with the economy falling into recession in late 2019 and in 2020. This is the result of higher trade costs and reduced business investment caused by a poorer economic outlook and increased uncertainty. By 2021, even under Scenario A, GDP is approximately 3.5% lower than it would have been if the UK had left the EU with the negotiated deal. For the rest of the EU, GDP is around 0.5% lower, although the effect varies considerably from country to country.
The IMF analysis makes optimistic assumptions, such as the UK being able to negotiate new trade deals with non-EU countries to replace those lost by leaving. More pessimistic assumptions would lead to greater costs.
Building on the analysis of the IMF, the Office for Budget Responsibility considered the effect of a no-deal Brexit on the public finances in its biennial Fiscal risks report, published on 17 July 2019. This argues that, under the relatively benign Scenario A assumptions of the IMF, the lower GDP would result in annual public-sector net borrowing (PSNB) rising. By 2021/22, if the UK had left with the deal negotiated with the EU, PSNB would have been around £18bn. A no-deal Brexit would push this up to around £51bn.
According to the OBR, the contributors to this rise in public-sector net borrowing of around £33bn are:
- A fall in income tax and national insurance receipts of around £16.5bn per year because of lower incomes.
- A fall in corporation tax and expenditure taxes, such as VAT, excise duties and stamp duty of around £22.5bn per year because of lower expenditure.
- A fall in capital taxes, such as inheritance tax and capital gains tax of around £10bn per year because of a fall in asset prices.
- These are offset to a small degree by a rise in customs duties (around £10bn) because of the imposition of tariffs and by lower debt repayments (of around £6bn) because of the Bank of England having to reduce interest rates.
The rise in PSNB would constrain the government’s ability to use fiscal policy to boost the economy and to engage in the large-scale capital projects advocated by Boris Johnson while making the substantial tax cuts he is proposing. A less optimistic set of assumptions would, of course, lead to a bigger rise in PSNB, which would further constrain fiscal policy.
- What are the assumptions of the IMF World Economic Outlook forecasts for the effects of a no-deal Brexit? Do you agree with these assumptions? Explain.
- What are the assumptions of the analysis of a no-deal Brexit on the public finances in the OBR’s Fiscal risks report? Do you agree with these assumptions? Explain.
- What is the difference between forecasts and analyses of outcomes?
- For what reasons might growth over the next few years be higher than in the IMF forecasts under either scenario?
- For what reasons might growth over the next few years be lower than in the IMF forecasts under either scenario?
- For what reasons might public-sector net borrowing (PSNB) over the next few years be lower than in the OBR forecast?
- For what reasons might PSNB over the next few years be higher than in the OBR forecast?
On 21st February 2019, the Department for International Trade (DIT) published a document outlining the UK’s progress in negotiating new free trade agreements (FTAs) with a number of non-EU countries. It advises UK firms that FTAs with Turkey and Japan will not be finalised before the official exit day from the European Union – 29th March 2019. Many business groups expressed concern at this news.
The EU has successfully negotiated a number of FTAs. These deals enable all 28 states in the European Union Custom Union (EU-CU), including the UK, to trade at preferential (i.e. lower) tariffs with over 70 non-EU countries. These include Canada, South Korea, Mexico, Israel, Norway, South Africa and Turkey. Research by the CBI estimates that UK exports to these countries were approximately £41bn in 2017 – approximately 13 per cent of all UK exports. In July 2018, the EU signed its largest ever FTA – with Japan. This deal covers 635 million people.
If the UK leaves the European Union without a deal on the 29th March, then it immediately loses membership of the EU-CU. Preferential tariffs will no longer apply to trade between the UK and the non-EU countries which signed the FTAs. Without any new arrangements in place, tariffs and quotas will revert to the non-preferential (i.e. higher) rates outlined in registered schedules with the World Trade Organization.
Given the economic significance of this trade, the UK government has spent the past two years trying to negotiate new FTAs to replace those previously agreed by the EU. For example, on February 11th, the government announced that it had signed a ‘continuity agreement’ with Switzerland covering trade worth £32bn per year. Deals have also been finalised with Chile, Israel, and the Faroe Islands that replicate the terms of the EU agreements. However, government officials informed 30 business groups in early February that it was highly unlikely that most of the new replacement FTAs would be concluded in time for March 29th.
The document published by the DIT on the 21st February confirms this position and describes the current status of most of the new FTAs as:
For both Japan and Turkey, the outlook is more negative. The guidance states:
We will not transition this agreement for exit day.
The head of EU negotiations at the CBI commented that:
We are really concerned that firms could be blindsided by this.
The government stated that it would significantly increase the resources devoted to the trade negotiations and expected to sign more deals over the next couple of weeks.
If the UK leaves the EU on the 29th March with a deal, then it remains in the EU-CU during the 21-month transition period. Trade will still be covered by the 40 existing EU deals. This gives UK officials until the end of December 2020 to conclude a new set of FTAs.
- Using a demand and supply diagram, illustrate the impact of tariffs on imported goods.
- The EU is perhaps the most famous example of a customs union. Find out some other examples.
- Discuss some of the potential disadvantages of free trade.
- Discuss some of the advantages and disadvantages of the UK remaining in the European Union Custom Union.
- What is a ‘registered schedule’ at the World Trade Organization?
An agreement in principle was reached on September 30 between the USA, Canada and Mexico over a new trade deal to replace the North American Free Trade Agreement (NAFTA). President Trump had described NAFTA as ‘the worst trade deal maybe ever signed anywhere, but certainly ever signed in this country.’ The new deal, named the United States-Mexico-Canada Agreement, or USMCA, is the result of 14 months of negotiations, which have often been fractious. A provisional bilateral agreement was made between the USA and Mexico in August. At the same time, President Trump threatened a trade war with Canada if it did not reach a trade agreement with the USA (and Mexico). The new USMCA must be ratified by lawmakers in all three countries before it can come into force. This could take a few months.
So is USMCA a radical departure from NAFTA? Does the USA stand to gain substantially, as President Trump claims? In fact, USMCA is little different from NAFTA. It could best be described as a relatively modest reworking of NAFTA. So what are the changes?
The first change affects the car industry. From 2020, 75% of the components of any vehicle crossing between the USA and Canada or Mexico must be made within one or more of the three countries to qualify for tariff-free treatment. The aim is to boost production within the region. But the main change here is merely an increase in the proportion from the current 62.5%.
A more significant change affecting the car industry concerns wages. Between 40% and 45% of a vehicle’s components must be made by workers earning at least US$16 per hour. This is some three times more than the average wage currently earned by Mexican car workers. Although it will benefit such workers, it will reduce Mexico’s competitive advantage and could hence lead to some diversion of production away from Mexico. Also, it could push up the price of cars.
The agreement has also strengthened various standards inadequately covered in NAFTA. According to The Conversation article:
The new agreement includes stronger protections for patents and trademarks in areas such as biotech, financial services and domain names – all of which have advanced considerably over the past quarter century. It also contains new provisions governing the expansion of digital trade and investment in innovative products and services.
Separately, negotiators agreed to update labor and environmental standards, which were not central to the 1994 accord and are now typical in modern trade agreements. Examples include enforcing a minimum wage for autoworkers, stricter environmental standards for Mexican trucks and lots of new rules on fishing to protect marine life.
Another area where the USMCA agreement has made changes concerns trade in dairy products. This particularly affects Canada, which has agreed to allow more US dairy products tariff-free into Canada (see the CNN article at the end of the list of articles below). New higher quotas will give US dairy farmers access to 3.6% of Canada’s dairy market. They will still pay tariffs on dairy exports to Canada that exceed the quotas, ranging from 200% to 300%.
The other significant change for consumers in Mexico and Canada is a rise in the value of duty-free imports they can bring in from the USA, including online transactions. As the first BBC article listed below states:
The new agreement raises duty-free shopping limits to $100 to enter Mexico and C$150 ($115) to enter Canada without facing import duties – well above the $50 previously allowed in Mexico and C$20 permitted by Canada. That’s good news for online shoppers in Mexico and Canada – as well as shipping firms and e-commerce companies, especially giants like Amazon.
Despite these changes, USMCA is very similar to NAFTA. It is still a preferential trade deal between the three countries, but certainly not a completely free trade deal – but nor was NAFTA.
And for the time being, US tariffs on Mexican and Canadian steel and aluminium imports remain in place. Perhaps, with the conclusion of the USMCA agreement, the Trump administration will now, as promised, consider lifting these tariffs.
- USMCA, the new trade deal between the US, Canada, and Mexico, explained
Vox, Jen Kirby (2/10/18)
- USMCA: What Donald Trump’s Nafta replacement trade deal means and how it will work
Independent, Mythili Sampathkumar (2/10/18)
- USMCA trade deal: Who gets what from ‘new Nafta’?
BBC News, Jessica Murphy & Natalie Sherman (1/10/18)
- Can Trump really cut the US trade deficit?
BBC News, Andrew Walker (2/10/18)
- How is ‘new NAFTA’ different? A trade expert explains
The Conversation, Amanda M. Countryman (2/10/18)
- Was NAFTA ‘worst trade deal ever’? Few agree
PolitiFact, Jon Greenberg (29/9/18)
- NAFTA out, USMCA in: What’s in the Canada, Mexico, US trade deal?
Aljazeera, Heather Gies (2/10/18)
- Mexico boosted by US-Canada agreement on revamped Nafta deal
Financial Times, Jude Webber (3/10/18)
- Nafta Is Dead. Long Live Nafta.
- Trump Clears Deck for China Trade War With New Nafta Deal
Bloomberg, Rich Miller, Andrew Mayeda and Jenny Leonard (2/10/18)
- Fact check: Is Trump right that the new trade deal is “biggest” ever?
CBS News (2/10/18)
- Commentary: What Trump’s new trade pact signals about China
Reuters, Andres Martinez (4/10/18)
- Canada opened its dairy market. But by how much?
CNN, Katie Lobosco (2/10/18)
- What have been the chief gains and losses for the USA from USMCA?
- What have been the chief gains and losses for Mexico from USMCA?
- What have been the chief gains and losses for Canada from USMCA?
- What are the economic gains from free trade?
- Why might a group of countries prefer a preferential trade deal with various restrictions on trade rather than a completely free trade deal between them?
- Distinguish between trade creation and trade diversion.
- In what areas, if any, might USMCA result in trade diversion?
- If the imposition of tariffs results in a net loss from a decline in trade, why might it be in the interests of a country such as the USA to impose tariffs?