1. Why, under WTO rules—specifically Article 6.1 of the Agreement on Technical Barriers to Trade (TBT)—is the EU reluctant to recognise UK-based conformity assessment, despite granting similar arrangements to non-member states? Is this not low-hanging legal fruit?
In theory, yes. But in practice, perhaps less so. The UK’s shift from insider to outsider status changes the political calculus, even if the legal framework appears unchanged. The same arguments were made by the EU against the US when the UK was still a supportive member state. Legal consistency has its limits when filtered through geopolitics and sovereignty anxieties.
2. So… what should observers realistically expect from the May summit?
Not sweeping breakthroughs, but rather a constructive agenda. The most favourable outcome would be a joint roadmap: a document setting out priority areas such as trade in food and agricultural products (including SPS standards), electricity market integration, CBAM-ETS alignment, and youth or professional mobility schemes. Such a text wouldn’t rewrite the terms of trade, but it could inject structure and momentum into currently scattered dialogues.
France reportedly favours a package approach—seeking progress on fisheries in return for concessions elsewhere—while other EU member states bring their own priorities. Looming deadlines in June 2026 on fisheries and energy will require some kind of political choreography in the interim. An outline of a UK-EU defence cooperation agreement is widely expected, and announcements on electricity trading could follow. Industry groups are pressing for signals on carbon pricing coordination, especially as CBAM takes hold. A technical working group on SPS could pave the way for dynamic alignment—an outcome with more political weight than its name suggests.
Still, the atmosphere is cautious. The main driver of this summit is, arguably, not trade at all, but defence—particularly UK access to EU procurement frameworks in the context of Ukraine. Against this backdrop, wider economic and geopolitical turbulence – much created by Trump – complicates things.
3. How has the US-UK “trade deal” played in the EU? Has the UK undercut the EU by striking a deal with Washington first?
No. Few in Brussels are genuinely surprised. The UK has been transparent about its intentions—not to confront the United States, but to remain broadly aligned with it, even in an era of transactional diplomacy. The mini-deal itself does not obviously disadvantage the EU, nor does it break from what the UK has signalled it would pursue.
Indeed, the EU is likely to see elements of the deal as reassuring. Earlier fears that the US would press for sweeping concessions—particularly on agriculture and services—have not materialised. Instead, what London secured appears modest, and may even help Brussels by demonstrating that Washington is prepared to negotiate with a lighter touch than initially expected.
There is, however, a potential legal concern. By offering the US preferential tariff treatment in exchange for improved access, Britain may be straining its commitments under the World Trade Organization’s principle of non-discrimination. Such arrangements are typically justified under Article XXIV of the GATT—but that requires a full free trade agreement or a clearly laid out plan toward one. Whether this mini-deal qualifies is uncertain. Preferential terms in the UK-US deal may undercut EU carmakers in the American market. But, unless a trading partner lodges a formal complaint, it is unlikely to escalate and Brussels is unlikely to cry foul just yet. Yet with the US itself bulldozing WTO norms, so there isn’t clear logic in singling out Britain.
Where the deal may have more concrete effects is in Northern Ireland. The Windsor Framework delicately balances tariff regimes between Great Britain, Northern Ireland and the EU single market. If the new UK-US arrangement introduces diverging rates or treatment, particularly for goods transiting through the UK, it could upset that balance. Brussels will be watching closely. The framework resolved some of the most immediate frictions, but it did not erase the structural complexity of post-Brexit trade within the UK’s own borders.
In short, the deal is unlikely to sour relations in Brussels. But it does highlight the ongoing tension between Britain’s post-Brexit global ambitions and the need to manage delicate institutional arrangements at home and with its nearest neighbour. As ever, the devil will be in the details—and in the enforcement.
4. What would be the best policy move the needle for the UK’s EU Reset?
The answer depends on the metric. To lift GDP, a broad youth mobility scheme could deliver immediate economic dividends. To boost GDP per capita and regional welfare, a sanitary and phytosanitary (SPS) deal would help—agri-food exports have been among the hardest hit post-Brexit, with pain felt unevenly across the UK.But the biggest looming cost lies in regulatory divergence, especially in electricity and carbon pricing. CBAM, once fully operational, will exacerbate the economic drag of decoupling.
The deeper question is strategic: how close does the UK want to get to the EU’s single market in goods? The decline in exports has hurt growth. A credible ambition to align more closely—signalled at the highest political level—would be both economically sound and diplomatically catalytic. But it would require political courage that has so far been in short supply.
5. Taking politics into account, what would you advise the labour government?
Be bigger and bolder. The government’s approach—cautious, piecemeal, and overly tactical—is falling short. The youth mobility reversal was surprising to see- a broadly supported, low-cost initiative abandoned without explanation. Getting closer to the single market won’t happen by tinkering around the edges. On issues like SPS alignment, real progress means openly acknowledging the benefits of cooperation with the EU—and having the political courage to pursue it. Voters are more open to this than the government appears to be, and public opinion has already moved strongly against Brexit. The US deal may have been a temporary success, but ambition will have to return to the EU relationship if the UK wants to truly reverse Brexit’s drag on the economy.