UPDATE: On January 25, 2024, talks between Canada and the UK broke down — paused by the UK — over issues such as Canadian tariff quotas for UK cheese, rules of origin for UK cars post-Brexit (affecting duty-free rights) and sanitary conditions for Canadian beef in the UK (not about hormones as in some reports but “about carcass washes used in Canadian processing facilities” according to Janyce McGregor of CBC.
The result was that the Canada-UK deal was an incomplete “roll-over” of the Canada-EU trade agreement. See “UK walks away from trade talks with Canada” (CBC)
By Peter Ungphakorn
POSTED JANUARY 1, 2021 | UPDATED JANUARY 26, 2024
On January 1, 2021, Britain left the EU Single Market and customs union. That meant the EU’s free trade agreements with non-EU countries no longer applied to the UK.
The British government has negotiated, at speed, “roll-over” agreements with those non-EU countries in order to reproduce the effects of those agreements as much as possible so that continuity is maximised for UK business.
This article does not look at the contents or depth of the deals. It simply counts how many of the EU’s free trade agreements have been “rolled over” into continuity agreements with the UK, and how many have not been done.
We should bear in mind that:
- some continuity agreements do not replicate the EU’s free trade agreements in full. It may depend on rules of origin, and any sectors, regulations, mutual recognition agreements that are not covered
- trade figures cited are for total trade, not trade affected by the continuity deals
All these agreements are subject to WTO rules: Article 24 of the General Agreement on Tariffs and Trade (GATT, for goods) and, if relevant, Article 5 of the General Agreement on Trade in Services (GATS).
By February 2, 2021, all the UK’s concluded trade agreements had been notified to the World Trade Organization (WTO). That includes the 30 continuity agreements. Also notified is the 2020 Christmas Eve UK-EU post-transition agreement together with the 2019 Withdrawal Agreement, which the is partly incorporated into it.
Other members will ask questions. The deals will be discussed in the Regional Trade Agreements Committee (which means free trade agreements, particularly in goods) and the Services Council if the agreement includes services.
This is for transparency. The WTO and its members do not approve free trade agreements. But if any member believes an agreement violates WTO rules it can challenge the countries in the agreement legally through WTO dispute settlement — for example if the deal on goods does not cover “substantially all the trade” or the one on services does not have “substantial sectoral coverage” .
The following information is taken from the UK government’s website on January 1, 2021.
Summary
Done deals
Number of countries: 60
Number of agreements: 30
Full ratification: with 31 countries
Provisional application: with 21 countries
Bridging mechanism: with 8 countries
Total trade (goods and services) with those countries: £174 billion
Signed, but not fully in effect
3 countries — Canada, Jordan, Mexico
Not done: still talking
3 WTO members—Albania, Ghana, Montenegro
3 countries not WTO members—Algeria, Bosnia and Herzegovina, Serbia
EU customs unions (except Turkey)
2 countries: Andorra (except agricultural products); San Marino (all products) — provided they reciprocate for the UK
Mutual recognition agreements
Signed stand-alone MRAs: 3 countries — Australia, New Zealand, US
Covered in trade agreements: 3 countries — Switzerland, Israel, Japan
Note that the contents of the rolled-over agreements can differ considerably.
For example, the agreement with Japan is detailed and runs to 1,100 pages.
The one with Canada contains a main text of only five pages, essentially incorporating the EU-Canada deal (CETA) into the UK-Canada relationship.
An annex of around 100 pages follows. It is essentially lists of “find and replace” or “find and delete”, so that references to the EU in the CETA text are changed to UK equivalents, dates are changed and some other provisions are tweaked or removed. It’s impossible to read as a stand-alone agreement.
Details
The following tables and text are copied directly from the UK government website, to make a snapshot of the information as it was on January 1, 2021:
Trade agreements that took effect from 1 January 2021
Agreements with the following countries and trading blocs took effect from January 1, 2021. Where the agreement has not yet been ratified, provisional application or bridging mechanisms have been put in place to ensure continuity of trade.
| Agreement | Country | Entry into effect mechanism (1) | Total UK trade with countries, 2019 (£ million) (2) |
| Andean countries | Columbia | Bridging mechanism | 2,876 (total for Andean countries) |
| Andean countries | Ecuador | Full ratification | 2,876 (total for Andean countries) |
| Andean countries | Peru | Bridging mechanism | 2,876 (total for Andean countries) |
| Cameroon | Cameroon | Bridging mechanism | 200 |
| CARIFORUM trade bloc | Antigua and Barbuda | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Barbados | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | St. Kitts and Nevis | Bridging mechanism | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Belize | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Bahamas | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Saint Lucia | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Dominica | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Dominican Republic | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Grenada | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Jamaica | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | St. Vincent and the Grenadines | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | Trinidad and Tobago | Bridging mechanism | 3,046 (total for CARIFORUM trade bloc) |
| CARIFORUM trade bloc | The Republic of Guyana | Provisional application | 3,046 (total for CARIFORUM trade bloc) |
| Central America | Costa Rica | Full ratification | 1,411 (total for Central America) |
| Central America | El Salvador | Full ratification | 1,411 (total for Central America) |
| Central America | Guatemala | Full ratification | 1,411 (total for Central America) |
| Central America | Honduras | Full ratification | 1,411 (total for Central America) |
| Central America | Nicaragua | Full ratification | 1,411 (total for Central America) |
| Central America | Panama | Full ratification | 1,411 (total for Central America) |
| Chile | Chile | Full ratification | 2,171 |
| Côte d’Ivoire | Côte d’Ivoire | Full ratification | 398 |
| Eastern and Southern Africa (ESA) trade bloc | Mauritius | Full ratification | 1,569 (total for Eastern and Southern Africa trade bloc) |
| Eastern and Southern Africa (ESA) trade bloc | Seychelles | Full ratification | 1,569 (total for Eastern and Southern Africa trade bloc) |
| Eastern and Southern Africa (ESA) trade bloc | Zimbabwe | Full ratification | 1,569 (total for Eastern and Southern Africa trade bloc) |
| Egypt | Egypt | Provisional application | 3,503 |
| Faroe Islands | Faroe Islands | Full ratification | 293 |
| Georgia | Georgia | Full ratification | 183 |
| Iceland and Norway | Iceland | Provisional application | 26,747 (total for Iceland and Norway) |
| Iceland and Norway | Norway | Provisional application | 26,747 (total for Iceland and Norway) |
| Israel | Israel | Full ratification | 5,014 |
| Japan | Japan | Full ratification | 14,676 |
| Kenya (3) | Kenya | Bridging mechanism | 1,407 |
| Kosovo | Kosovo | Full ratification | 10 |
| Lebanon | Lebanon | Full ratification | 849 |
| Liechtenstein | Liechtenstein | Full ratification | 159 |
| Moldova | Moldova | Provisional application | 395 |
| Morocco | Morocco | Full ratification | 2,251 |
| North Macedonia | North Macedonia | Provisional application | 1,774 |
| Pacific states | Fiji | Provisional application | 232 (total for Pacific States) |
| Pacific states | Papua New Guinea | Provisional application | 232 (total for Pacific States) |
| Pacific states | Samoa (4) | Bridging mechanism | 232 (total for Pacific States) |
| Pacific states | Solomon Islands (4) | Bridging mechanism | 232 (total for Pacific States) |
| Palestinian Authority | Palestinian Authority | Full ratification | 9 |
| Singapore | Singapore | Provisional application | 17,636 |
| South Korea | South Korea | Full ratification | 11,777 |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | Botswana | Full ratification | 11,875 (total for SACUM trade bloc) |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | Eswatini | Full ratification | 11,875 (total for SACUM trade bloc) |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | Lesotho | Full ratification | 11,875 (total for SACUM trade bloc) |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | Mozambique | Full ratification | 11,875 (total for SACUM trade bloc) |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | Namibia | Full ratification | 11,875 (total for SACUM trade bloc) |
| Southern Africa Customs Union and Mozambique (SACUM) trade bloc | South Africa | Full ratification | 11,875 (total for SACUM trade bloc) |
| Switzerland | Switzerland | Full ratification | 37,063 |
| Tunisia | Tunisia | Full ratification | 561 |
| Turkey | Turkey | Provisional application | 18,559 |
| Ukraine | Ukraine | Full ratification | 1,566 |
| Vietnam | Vietnam | Provisional application | 5,706 |
Notes
1) Provisional application is a method well established in international treaty practice to bring agreements into effect ahead of entry into force. Bridging mechanisms are an alternative means to ensure continuity of trade, where the UK or treaty partners are unable to fully ratify or provisionally apply an agreement. These non-binding mechanisms include Memoranda of Understanding or Exchange of Diplomatic Notes which will ensure continuity of trade.
2) Source of trade statistics: ONS UK total trade: all countries, non-seasonally adjusted April to June 2020.
3) This agreement is open to accession by other members of East African Community.
4) Samoa and the Solomon Islands have not yet acceded to the Pacific States-UK Interim Economic Partnership Agreement (pending a decision on their accession), however preferences under the agreement will take effect on 1 January 2021 through a Memorandum of Understanding.
Signed trade agreements, not fully in effect
There are some trade agreements the UK has signed which are partially applied or have not fully taken effect.
| Agreement | Information on entry into effect |
| Canada | Expected to enter into effect in early 2021. Preferential tariff rates will be applied from 1 January 2021 |
| Jordan | Expected to enter into effect in early 2021. Trade will take place under WTO terms (Generalised Scheme of Preferences for imports) |
| Mexico (1) | Expected to enter into effect in early 2021. Preferential tariff rates will be applied from 1 January 2021 |
Notes
(1) The UK has committed to apply preferential tariff rates on goods imported into the UK from Mexico from 1 January 2021. In return, Mexico has committed to implement a tariff rebate scheme, so that as soon as the Trade Continuity Agreement enters into force in Mexico, any businesses that have paid tariffs on goods which would attract a preference under the agreement, between 1 January and the agreement coming into force will be able to get a refund.
Trade agreements still in discussion
The following agreements are still under discussion with countries where trading agreements were in place before 1 January 2021.
For these countries:
- the government has put in place the UK global tariff
- trade with other WTO members is taking place on WTO terms
- trade with eligible developing countries is taking place under the UK’s Generalised Scheme of Preferences
| Country or bloc | Status of discussions |
| Albania | Engagement ongoing, agreement will not be in place for 1 January 2021. Trade expected to take place under WTO terms. |
| Algeria (1) | Engagement ongoing, agreement will not be in place for 1 January 2021. Trade expected to take place under WTO terms (Generalised Scheme of Preferences for imports). |
| Bosnia and Herzegovina (1) | Engagement ongoing, agreement will not be in place for 1 January 2021. Trade expected to take place under WTO terms. |
| Ghana | Engagement ongoing, agreement will not be in place for 1 January 2021. Agreement expected to be completed shortly (2). Trade expected to take place under WTO terms (Generalised Scheme of Preferences for imports). |
| Montenegro | Engagement ongoing, agreement will not be in place for 1 January 2021. Trade expected to take place under WTO terms. |
| Serbia (1) | Engagement ongoing, agreement will not be in place for 1 January 2021. Trade expected to take place under WTO terms. |
Notes
(1) Algeria, Bosnia and Herzegovina and Serbia are not members of the World Trade Organisation. UK exports will be subject to partner country national legislation.
(2) On 31 December 2020 the UK and Ghana issued a joint statement. This announced that both sides had reached a consensus on the major elements of a trade agreement. Both sides are committed to making the gap in preferences as short as possible.
Trading with countries in Customs Unions with the EU
Andorra and San Marino are part of customs unions with the EU. The UK has agreed with the EU that all products originating in San Marino and all non-agricultural products (chapters 25-97) originating in Andorra will be treated as originating in the EU under the UK-EU Trade and Cooperation Agreement as long as Andorra and San Marino apply to UK products the same preferences that the EU applies to them. These products will benefit from zero tariffs, where they meet the relevant rules of origin. Trade with Andorra of agricultural products (chapters 01-24) is not in scope of the UK-EU Trade and Cooperation Agreement and will revert to WTO terms.
Mutual recognition agreements
A mutual recognition agreement (MRA) is one in which countries recognise the results of one another’s conformity assessments.
A conformity assessment is a set of processes that confirm whether a product meets the specified legal requirements. This can include testing, inspection, and certification.
The UK has signed MRAs with:
MRA coverage in trade agreements
The UK’s trade agreement with Switzerland incorporates elements of the EU-Switzerland MRA.
The UK’s trade agreement with Israel covers conformity assessment of industrial products. This means that existing arrangements with Israel will continue after 31 December 2020.
The UK-Japan CEPA replicates the effects of the existing EU-Japan MRA.
See also
- FACT CHECK: Which UK geographical indications are in its trade deal with Japan?
- Text of the UK-Japan trade deal: user-friendly chapter by chapter download links
- Grandfathering EU free trade deals for the UK: a look at an actual text
- Text of the UK-South Korea free trade agreement
- What have the UK and Switzerland agreed on trade post-Brexit?
This piece started out as a Twitter thread:
Updates:
January 26, 2024 — adding the update on suspended Canada-UK talks
January 4, 2021 — adding Bloomberg’s map
February 4, 2020 — adding WTO notifications
Image credits:
Woodcut handshake used in montage | Oberholster Venita via Pixabay CC0
Maps: WTO and Bloomberg
Trade β Blog 