As we talk to companies about the implications, two questions keep coming up:

  1. How will the implementation challenges of a last-minute deal be addressed? Whether questions around rules of origin to qualify for zero-tariff trade, importing into Northern Ireland, or how customs systems will cope when freight traffic returns to something close to normal volumes after the immediate changeover, businesses want to understand how the UK and EU will help them respond to the immediate challenges of the new rules, and how businesses can engage with the government to government cooperation committees foreseen by the deal.

2. How will ‘managing divergence’ work in the future, and how can business make its voice heard? The deal gives the UK the freedom to diverge from evolving EU rules and standards, but at the potential cost of tariffs and limited market access if it diverges ‘significantly’ enough to ‘materially’ affect trade or investment. How will this work in terms of major new EU regulatory or tax changes such as the Green New Deal? Will shared strategic ambition – to cut emissions and provide global leadership – mean flexibility in how each side achieves similar goals? Or will the EU approach potential UK regulatory competition more defensively? How will arbitration – if the two sides can’t settle differences amicably – work?

Lexington can help you position your business strategically on these issues, engage the government in Westminster, the UK devolved administrations, and in the key EU capitals, and work through the operational implications. Our trade and regulatory team brings insight and experience from the political and regulatory angles to help you take advantage of the next phase – implementation of the trade deal and beyond.

For more information, get in touch with Paul McGrade (