Tag: Rules of Origin

It is 10 years since the Brexit referendum. From an electorate of 46,501,251 people, 17,410,742 (37.4%) voted to leave, 16,141,241 (34.7%) voted to remain and 12,949,258 (27.8%) did not vote. The UK left the EU on 31 January 2020 at 11:00 pm, but remained in the single market and customs union during a transition period lasting for a further 11 months until December 31 2020.

To mark the 10th anniversary of the vote a number of articles have been written assessing the effects of Brexit. Here we look at the economic effects, as do the articles linked below. This blog updates the analysis of an earlier one, The costs of Brexit: a clearer picture.

Trade

After the referendum, extensive negotiations took place on the trading arrangements between the UK and EU that would exist once Brexit was finalised.

One possibility was ‘The Norwegian model’, which would have seen the UK join the European Economic Area (EEA), giving it access to the single market, but removing regulation in some key areas, such as fisheries and home affairs. This was ruled out in favour of a bilateral trade agreement. Three main types were available:

  • Swiss model, where the UK would negotiate a series of bilateral agreements with the EU, including selective or general access to the single market.
  • Canadian model, where the UK would form a comprehensive trade agreement with the EU to lower customs tariffs and other barriers to trade.
  • Turkish model, where the UK would form a customs union with the EU. In Turkey’s case the agreement relates principally to manufactured goods.

The agreement reached, the Trade and Cooperation Agreement (TCA) was a version of the Canadian model. The UK would leave the single market and customs union, but there would be tariff-free and quota-free trade in goods between the UK and the EU. However, to ensure that it was EU and UK business that would benefit from these ‘trade preferences’, businesses must show that their products fulfil ‘rules of origin’ requirements.

Rules of origin. Under rules of origin requirements, 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., 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, in the case of a petrol car, 55% of its value must have been created in either the EU or UK.

Meeting rules of origin has created a large amount of paperwork for businesses and this has created a significant barrier to trade. What is more, exporters are required to complete import/export declarations. Also, agri-food goods are subject to strict physical border controls. These barriers have increased the costs of trade and reduced its volume.

Services. Free trade in services is not provided by the TCA. Instead, services exporters face various barriers, such as certain professional qualifications no longer being recognised in EU countries and a loss of ‘passporting’ rights that previously allowed cross-border financial operations with minimal extra permissions.

Brexit impact. Despite new barriers to trade in services, they are generally less significant than the barriers for trade in goods, particularly in a digital age. Indeed, UK services exports have held up well. Although they fell in 2020, they have grown significantly since. According to House of Commons Library Statistics on UK-EU trade (see link below):

In 2025, UK exports of services to the EU were 28% above their 2019 level in real terms. Exports to non-EU countries were 26% above their 2019 level.

UK exports of goods to the EU, however, have fared less well. In 2025 they were 14% below their 2019 level in real terms. This is partly the effect of COVID and the Ukraine war, but exports to non-EU countries were only 8% lower than 2019. According to research by economists John Springford and Anton Spisak for the Centre for European Reform (see link below), Brexit has depressed UK goods exports to the EU by 16%. According to the Office for Budget Responsibility, (see link below) both exports and imports in the long run will be around 15% lower than they would have been if the UK had remained in the EU. What is more, the growth of goods trade (exports plus imports) has fallen well behind the average of the rest of the G7. And according to British Chambers of Commerce research (see link below), 54% of UK exporters think the TCA is making it harder to export and the need for change is urgent.

The new barriers reduce market access, while lower export volumes reduce competition and economies of scale. There is less competition too from imports, with many EU firms no longer exporting to the UK because of the costs. The barriers lead to a misallocation of resources, with highly productive UK firms exporting less, with less productive firms in the UK and EU focusing purely on their domestic markets. The barriers thus impose an impediment to the exploitation of comparative advantage

Investment

Both domestic and foreign direct investment (FDI) in the UK have been adversely affected by Brexit. Bloom et al., in their paper for the NBER (see link below), estimate that by 2025, investment was 12–18% lower than it would have been without Brexit.

In the early years after the referendum, lower capital investment was mainly the result of uncertainty and devoting significant resources to administrative Brexit preparations. Later it was largely the result of the trade barriers themselves. Not surprisingly, firms in the UK with high exposure to EU markets experienced a sharper decline in investment than less-exposed ones.

The end of the single market and customs union reduced the attractiveness of the UK as a hub for FDI relative to competitor countries. And UK firms were encouraged to invest in the EU to create hubs for selling within the EU, thereby allowing them to avoid the trade barriers.

According to the Bloom et al. analysis, the effect of lower investment and less competition has been a fall in UK productivity of around 3% to 4% compared to remaining in the EU. The Office For Budget Responsibility argues that the post-Brexit trading relationship will reduce long-run productivity by 4% relative to remaining in the EU.

Growth in GDP

Lower investment, lower productivity and trade barriers have had a negative impact on economic growth. According to analysis by the National Institute of Economic and Social Research (NIESR) (see link below), by the end of 2023, UK real GDP was some 2–3% lower solely as a result of Brexit – in other words, after having taken into account the effects of COVID-19 and the Russia-Ukraine war. This corresponds to a per capita income loss of approximately £850. The NIESR analysis predicts that this will rise to some 5–6% of GDP, or about £2,300 per capita, by 2035.

Bank of England data, based on surveys of chief financial officers of over 2000 firms (small, medium and large), suggest that the UK economy is some 6% smaller than it would have been without Brexit. The Office for Budget Responsibility estimates that Brexit has caused a long-run reduction in GDP of 4% as a result of a similar percentage reduction in productivity.

The growth of small and medium-sized enterprises (SMEs) has been disproportionately dampened by the compliance costs of trade with the EU. Some SMEs, especially in the food and drink sector, have ceased exporting to the EU altogether.

Labour supply and migration

Halting the right of EU workers to move freely to the UK for work created acute labour shortages in specific sectors such as hospitality, health and social care, logistics, construction and agriculture. However, while immigration from the EU fell dramatically, this was more than offset by increased immigration from non-EU countries. But this was unable to fill shortfalls in some sectors.

The loss of free movement of labour means that UK workers now face restrictions on working in the EU. These include obtaining a work visa, which requires a formal job offer, sponsorship and meeting strict salary thresholds. While business trips for meetings, conferences, trade fairs, etc. are generally exempt, if the work involves remuneration, then normally a work visa will be required. The terms of work visas vary between member states. This has created a considerable barrier for touring bands and other artists. Short-term self-employed or freelance work is highly restricted, with virtually no work permit options available for visiting UK nationals.

Because employing UK nationals now imposes extra administrative and time-consuming burdens on local EU employers, many now prioritize applicants from EU nations who can start immediately.

Articles

Videos

Reports, Research, Analysis and Data

Questions

  1. Summarise the negative effects of Brexit on the UK economy.
  2. Why is it difficult to quantify these effects?
  3. How have UK firms attempted to reduce the costs of exporting to the EU?
  4. Why have goods exports been worse affected by Brexit than services exports?
  5. What difficulties would lie in the way of the UK negotiating a Turkish or Swiss model of trading relations with the EU?
  6. Have there been any economic benefits from Brexit and, if so, what?

The UK signed three trade deals in May – one with the USA, one with India and one with the EU. It is hoped by the government that these trade deals will provide a welcome boost to the UK economy.

The deal with the USA reduced tariffs on UK car exports to the USA from 27.5% to 10%, and on steel and aluminium exports from 25% to 0%. Pharmaceutical exports would also get more favourable treatment and there would be ‘reciprocal market access on beef’ (but with no lowering of food standards). Nevertheless, President Trump’s baseline tariff of 10% on most goods remains, as with other countries. However, a ruling by the US Court of International Trade has found that the Trump’s use of emergency powers to justify the sweeping use of tariffs is wrong. The Trump administration is appealing against the ruling and until the appeal is heard, the tariffs have been reinstated. Also, on May 30, the Trump administration announced that tariffs on steel and aluminium imports would rise from 25% to 50%. It remained to be seen whether this would affect the deal to reduce the rate to zero for British steel and aluminium imports.

The deal with India involves a reduction in tariffs on UK exports – some to zero – and simplified trade rules, faster customs clearance, less paperwork and the freedom for UK businesses to provide telecommunications and construction services. In return, tariffs will be reduced to zero on 99% of Indian exports to the UK. The UK government estimates that deal will result in trade between the two countries increasing by over 30%, with the UK’s GDP expanding by around 0.1 percentage points per year.

UK-EU trade

Perhaps the most significant new trade deal, however, is with the EU. This is a major advance on the current post-Brexit Trade and Cooperation Agreement (TCA). Under the TCA, there are no tariffs or quotas on UK goods exports to the EU or EU goods exports to the UK. However, to ensure that it is EU and UK business that benefits from these ‘trade preferences’, firms must show that their products fulfil ‘rules of origin’ requirements.

Under rules of origin requirements, 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., 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 per cent UK content (or 80 per cent of the weight of foodstuffs) to qualify for tariff-free access to the EU. As a result, many goods exported to the EU with a proportion of imported components face tariffs.

Also, the TCA does not include free trade in services. 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. Although some of the barriers which apply to other non-EU countries have been reduced for the UK in the TCA, UK service providers still face barriers which impose costs. For example, some EU countries limit the time that businesspeople providing services can stay in their countries to six months in any twelve. Also, since Brexit, UK artists and musicians have faced restrictions when touring and working in the EU. They can only work up to 90 out of every 180 days. This causes problems for longer tours and for musicians and crew who work in multiple bands or orchestras.

Perhaps the greatest barrier to trade under the TCA has been the large range of non-tariff measures (NTMs), such as customs checks, rules-of-origin and other paperwork, meeting various regulations and standards, and sanitary and phytosanitary checks on foodstuffs, plants and animals. Both the OBR and the Bank of England estimate that these post-Brexit trade restrictions are reducing UK GDP by around 4% and will continue to do so unless trade with the EU becomes freer.

The new UK-EU trade deal

The deal struck in mid-May reduces many of the administrative barriers to trade. Perhaps the most significant are the border checks on food, animal and plant shipments to and from the EU. Many of these checks will be scrapped. The new sanitary and phytosanitary (SPS) agreement allows many UK food products to be exported that previously were banned or proved too administratively costly. To achieve this free movement, the UK will generally follow EU standards, or similar standards so as to avoids harming EU trade. UK food exporters have generally welcomed the deal.

British steel exports to the EU will be protected from new EU rules and tariffs. This should save UK steel some £25m per year. Also, the EU has agreed to recognise UK carbon emissions caps, meaning that UK exports to the EU will avoid around £800m of carbon border taxes.

The post-Brexit fishing deal between the UK and EU, which saw a reduction of 25% in EU fishing quotas in UK waters, will be extended for another 12 years. Many UK fishers, however, had hoped for scrapping EU access to UK waters. The deal also allows various sea foods, including certain shellfish, to be exported to the EU for the first time since Brexit.

Other elements of the deal include a new security and defence partnership, the use of e-gates for UK travellers to the EU and an agreement to work towards a young person’s mobility scheme, allowing young people from the UK/EU to work and travel freely in the EU/UK again for a period of time.

The elements of the deal concerned with trade represent freer trade, but not totally free trade. The UK is not rejoining the customs union or single market. Nevertheless, strong supporters of Brexit have criticised the deal as a movement towards greater alignment of standards and thus a dilution of UK sovereignty. Supporters of greater alignment, on the other hand, argue that the deal does not go far enough and that even freer trade and less red tape would bring greater benefits to the UK.

Articles

UK-US trade deal

UK-India trade deal

UK-EU trade deal

Questions

  1. Outline the main elements of (a) the UK-US trade deal, (b) the UK-India trade deal and (c) the UK-EU trade deal. How much is it claimed that each deal will add to UK GDP?
  2. What trade barriers remain in each of the three deals?
  3. What elements are missing from the UK-EU trade deal that campaigners have been pushing for?
  4. Under what circumstances do free trade deals lead to (a) trade creation; (b) trade diversion?
  5. Would you expect the UK-EU trade deal on balance to lead to trade creation or trade diversion? Explain why.

At the time of the 2016 referendum, the clear consensus among economists was that Brexit would impose net economic costs on the UK economy. The size of these costs would depend on the nature of post-Brexit trading relations with the EU. The fewer the new barriers to trade and the closer the alignment with the EU single market, the lower these costs would be.

The Brexit deal in the form of the EU-UK Trade and Cooperation Agreement (see also) applied provisionally from January 2021, after the end of the transition period, and came into force in May 2021. Although this is a free-trade deal in the sense that goods made largely in the UK or EU can be traded tariff-free between the two, the deal does not apply to services (e.g. financial services) or to goods where components made outside the UK or EU account for more than a certain percentage (the ‘rules of origin‘ condition). Also there has been a huge increase in documentation that must be completed to export to or import from the EU.

Even though the nature of the Brexit deal has been clear since it was signed in December 2020, assessing the impact of the extra barriers to trade it has created has been hard given the various shocks that have had a severe impact on the UK (and global) economy. First COVID-19 and the associated lockdowns had a direct effect on output and trade; second the longer-term international supply-chain disruptions have extended the COVID costs beyond the initial lockdowns and acted as a brake on recovery and growth; third the Russian invasion of Ukraine imposed a severe shock to energy and food markets; fourth these factors have created not just a supply shock but also an inflationary shock, which has resulted in central banks seeking to dampen demand by significantly raising interest rates. One worry among analysts was that the negative effects of such shocks might be greater on the UK economy than on other countries.

However, the negative effects of Brexit are now becoming clearer and various institutions have attempted to quantify the costs. These costs are largely in terms of lower GDP than otherwise. This results from:

  • reduced levels of trade with the EU, thereby reducing the gains from exploiting comparative advantage;
  • increased costs of trade with the EU;
  • disruptions to supply chains;
  • reduced competition from European firms, with many no longer exporting to the UK because of the costs;
  • reduced inward investment;
  • labour market shortages, particularly in certain areas such a hospitality, construction, social care and agriculture as many European workers have left the UK and fewer come;
  • a reduction in productivity.

Here is a summary of the findings of different organisations.

The Office for Budget Responsibility (OBR)

The OBR has argued that Brexit as negotiated in the Trade and Cooperation Agreement:

will reduce long-run productivity by 4 per cent relative to remaining in the EU. This largely reflects our view that the increase in non-tariff barriers on UK-EU trade acts as an additional impediment to the exploitation of comparative advantage.21

In addition the OBR estimates that:

Both exports and imports will be around 15 per cent lower in the long run than if the UK had remained in the EU.21

Recent evidence supports this. According to the OBR:

UK and aggregate advanced economy goods export volumes fell by around 20 per cent during the initial wave of the pandemic in 2020. But by the fourth quarter of 2021 total advanced economy trade volumes had rebounded to 3 per cent above their pre-pandemic levels while UK exports remain around 12 per cent below.22

This assumption was repeated in the November 2022 Economic and Fiscal Outlook (p.26) 23. What is more, new trade deals will make little difference, either because they are a roll-over from previous EU trade deals with the respective country or have only a very small effect (e.g. the trade deal with Australia).

The Bank of England

The Bank of England, ever since the referendum in 2016, has forecast that Brexit would damage trade, productivity and GDP growth. In recent evidence to the House of Commons Treasury Committee5, Andrew Bailey, the Governor, stated that previous work by the Bank concluded that Brexit would reduce productivity by a bit over 3% and that this was still the Bank’s view.

His colleague, Dr Swati Dhingra, stated that, because of Brexit, there was a ‘much bigger slowdown in trade in the UK compared to the rest of the world’. She continued:

The simple way of thinking about what Brexit has done to the economy is that in the period after the referendum, the biggest depreciation that any of the world’s four major economies have seen overnight contributed to increasing prices [and] reduced wages. …We think that number is about 2.6% below the trend that real wages would have been on. Soon afterwards and before the TCA happened came the effects of the uncertainty that was unleashed, which basically translates into reduced business investment and less certainty of the FDI effects. Those tend to be very long-pay things.

She continued that now we are seeing significantly reduced trade directly as a result of the Brexit trade agreement (TCA).

Her colleague, Dr Catherine Mann, argued that ‘the small firms are the ones that are the most damaged, because the cost of the paperwork and so forth is a barrier’. This does not only affect UK firms exporting to the EU but also EU firms exporting to the UK. Reduced imports from EU firms reduces competition in the UK, which tends to lead to higher prices.

The Institute for Fiscal Studies

The IFS has consistently argued that Brexit, because of increased trade barriers with the EU, has reduced UK trade, productivity and GDP. In a recent interview6, its Director, Paul Johnson, stated that ‘Brexit, without doubt, has made us poorer than we would otherwise have been’. That, plus other convulsions, such as the mini-Budget of October 2022, have reduced foreigners’ confidence in the UK, with the result that investment in the UK and trade with the rest of the world have fallen.

Resolution Foundation

In a major Resolution Foundation report24, the authors argued that the effects of Brexit will take time to materialise fully and will occur in three distinct phases. First, in anticipation of permanent effects, the referendum caused sterling to depreciate and this adversely affected household incomes. What is more, the uncertainty about the future caused business investment to fall (but not inward FDI). Second, the Trade and Cooperation Act, by introducing trade barriers, reduced UK trade with the EU. But trade with the rest of the world also fell suggesting that Brexit is impacting UK trade openness and competitiveness more broadly. Third, there will be structural changes to the UK economy over the long-term which will adversely affect economic growth:

A less-open UK will mean a poorer and less productive one by the end of the decade, with real wages expected to fall by 1.8 per cent, a loss of £470 per worker a year, and labour productivity by 1.3 per cent, as a result of the long-run changes to trade under the TCA. This would be equivalent to losing more than a quarter of the last decade’s productivity growth.

Nuffield Trust

One of the key effects of Brexit has been on the labour market and especially on sectors, such as hospitality, agriculture, construction, health and social care. These sectors are experiencing labour shortages, in part due to EU nationals leaving the UK. In 2021, the Nuffield Trust looked at the supply of workers in health and social care25 and found that, as a result of increased bureaucratic hurdles, the number of EU/EFTA-trained nurses had declined since 2016. In social care, new immigration rules have made it virtually impossible to recruit from the EU. A more recent report looked at the recruitment of doctors in four specific specialties.26 In each case, although the number recruited from the EU/EFTA was still increasing, the rate of increase had slowed significantly. The reason appeared to be Brexit not COVID-19.

Ivalua

Research by Coleman Parkes for Ivalua18 shows that 80% of firms found Brexit to have been the biggest cause of supply-chain disruptions in the 12 months to August 2022, with 83% fearing the biggest disruptions from Brexit are yet to come. Brexit was found to have had a bigger effect on supply chains than the war in Ukraine, rising energy costs and COVID-19.

Centre for European Reform

Modelling conducted by John Springford27 used a ‘doppelgängers’ method to show the effects of Brexit on the UK economy. Each doppelgänger is ‘a basket of countries whose economic performance closely matches the UK’s before the Brexit referendum and the end of the transition period’. Comparing the UK’s performance with the doppelgänger can show the difference between leaving and not leaving the UK. Doppelgängers were estimated for GDP, investment (gross fixed capital formation), total services trade (exports plus imports) and total goods trade (ditto).

The results are sobering. In the final quarter of 2021, UK GDP is 5.2 per cent smaller than the modelled, doppelgänger UK; investment is 13.7 per cent lower; and goods trade, 13.6 per cent lower.

Economic and Social Research Institute (ESRI) (Ireland)

Similar results for UK trade have been obtained by Janez Kren and Martina Lawless in research conducted for the ESRI.28 They used product-level trade flows between the EU and all other countries in the world as a comparison group. This showed a 16% reduction in UK exports to the EU and a 20% reduction in UK imports from the EU relative to the scenario in which Brexit had not occurred.

British Chambers of Commerce (BCC) survey

According to a BCC survey of 1168 businesses33, 92% of which are SMEs, more than three quarters (77%) for which the Brexit deal is applicable say it is not helping them increase sales or grow their business and 56% say they have difficulties in adapting to the new rules for trading goods. The survey shows that UK firms are facing significant challenges in trying to trade with EU countries under the terms of the Trade and Cooperation Agreement. What is more, 80% of firms had seen the cost of importing increase; 53% had seen their sales margins decrease; and almost 70% of manufacturers had experienced shortages of goods and services from the EU.

Academic studies

Research at the Centre for Business Prosperity, Aston University, by Jun Du, Emine Beyza Satoglu and Oleksandr Shepotylo20, 29 found that UK exports to the EU ‘fell by an average of 22.9% in the first 15 months after the introduction of the EU-UK Trade and Cooperation Agreement’. The negative effect on UK exports persisted and deepened from January 2021 to March 2022. The research involved comparing actual trade with an ‘alternative UK economy’ model based on the UK having remained in the EU. What is more, the researchers found that there had been a reduction of 42% in the number of product varieties exported to the EU, with a large number of exporters simply ceasing to export to the EU and with many of the remaining exporters streamlining their product ranges.

Research at the LSE’s Centre for Economic Performance by Jan David Bakker, Nikhil Datta, Richard Davies and Josh De Lyon31 found that leaving the EU added an average of £210 to UK household food bills over the two years to the end of 2021. This amounted to a total cost to consumers of £5.8 billion. This confirmed the findings of previous research30 that the increase in UK-EU trade barriers led to food prices in the UK being 6% higher than they would have been.

Finally, a report from the Migration Observatory at the University of Oxford32 examined the effects of the ending of the free movement of labour from the EU to the UK. Visas are now required, but ‘low-wage occupations that used to rely heavily on EU workers are now ineligible for work visas, with some limited exceptions for social care and seasonal workers’. Many industries are facing labour shortages. Reasons include other factors, such as low pay and unattractive working conditions, and workers leaving the workforce during the pandemic and afterwards. But the end of free movement appears to have exacerbated these existing problems.

References

    Videos

  1. The Brexit effect: how leaving the EU hit the UK
  2. Financial Times film (18/10/22)

  3. What impact is Brexit having on the UK economy?
  4. Brexit and the UK economy, Ros Atkins (29/10/22)

  5. Why Brexit is damaging the UK economy both now and in the future
  6. Economics Help on YouTube, Tejvan Pettinger (5/12/22)

  7. Why the Costs of Brexit keep growing for the UK economy
  8. Economics Help on YouTube, Tejvan Pettinger (17/10/22)

  9. Treasury Committee (see also)
  10. Parliament TV (25/11/22) (see 15:03:00 to 15:08:12) (Click here for a transcript: see Q637 to Q641)

  11. UK economy made worse by ‘own goals’ like Brexit and Truss mini-budget, IFS economist says
  12. Sky News, Paul Johnson (IFS) (18/11/22)

    Articles

  13. Brexit and the economy: the hit has been ‘substantially negative’
  14. Financial Times, Chris Giles (30/11/22)

  15. ‘What have we done?’: six years on, UK counts the cost of Brexit
  16. The Observer, Toby Helm, Robin McKie, James Tapper & Phillip Inman (25/6/22)

  17. Brexit did hurt the City’s exports – the numbers don’t lie
  18. Financial News, David Wighton (9/11/22)

  19. Brits are starting to think again about Brexit as the economy slides into recession
  20. CNBC, Elliot Smith (23/11/22)

  21. Brexit has cracked Britain’s economic foundations
  22. CNN, Hanna Ziady (24/12/22)

  23. Mark Carney: ‘Doubling down on inequality was a surprising choice’
  24. Financial Times, Edward Luce (14/10/22)

  25. Brexit: Progress on trade deals slower than promised
  26. BBC News, Ione Wells & Brian Wheeler (2/12/22)

  27. How Brexit costs this retailer £1m a month in sales
  28. BusinessLive, Tom Pegden (22/11/22)

  29. Brexit Is Hurting The UK Economy, Bank Of England Official Says
  30. HuffPost, Graeme Demianyk (16/11/22)

  31. Brexit and drop in workforce harming economic recovery, says Bank governor
  32. The Guardian, Richard Partington (16/11/22)

  33. Brexit a major cause of UK’s return to austerity, says senior economist
  34. The Guardian, Anna Isaac (14/11/22)

  35. 80% of UK businesses say Brexit caused the biggest supply chain disruption in the last 12 months
  36. Ivalua (28/11/22)

  37. Brexit added £210 to household food bills, new research finds
  38. Sky News, Faye Brown (1/12/22)

  39. Brexit changes caused 22.9% slump in UK-EU exports into Q1 2022 – research
  40. Expertfile (8/12/22)

    Research and analysis

  41. Brexit analysis
  42. OBR (26/5/22)

  43. The latest evidence on the impact of Brexit on UK trade
  44. OBR (March 2022)

  45. Economic and fiscal outlook – November 2022 (PDF)
  46. OBR (17/11/22)

  47. The Big Brexit (PDF)
  48. Resolution Foundation, Swati Dhingra, Emily Fry, Sophie Hale & Ningyuan Jia (June 2022)

  49. Going it alone: health and Brexit in the UK
  50. Nuffield Trust, Mark Dayan, Martha McCarey, Tamara Hervey, Nick Fahy, Scott L Greer, Holly Jarman, Ellen Stewart and Dan Bristow (20/12/21)

  51. Has Brexit affected the UK’s medical workforce?
  52. Nuffield Trust, Martha McCarey and Mark Dayan (27/11/22)

  53. What can we know about the cost of Brexit so far?
  54. Centre for European Reform, John Springford (9/6/22)

  55. Brexit reduced overall EU-UK goods trade flows by almost one-fifth
  56. Economic and Social Research Institute (Ireland), Janez Kren and Martina Lawless (19/10/22)

  57. Post-Brexit UK Trade – An Update (PDF)
  58. Centre for Business Prosperity, Aston University, Jun Du, Emine Beyza Satoglu and Oleksandr Shepotylo (November 2022)

  59. Post-Brexit imports, supply chains, and the effect on consumer prices (PDF)
  60. UK in a Changing Europe, Jan David Bakker, Nikhil Datta, Josh De Lyon, Luisa Opitz and Dilan Yang (25/4/22)

  61. Non-tariff barriers and consumer prices: evidence from Brexit
  62. Centre for Economic Performance, LSE, Jan David Bakker, Nikhil Datta, Richard Davies and Josh De Lyon (December 2022)

  63. How is the End of Free Movement Affecting the Low-wage Labour Force in the UK?
  64. Migration Observatory, University of Oxford, Madeleine Sumption, Chris Forde, Gabriella Alberti and Peter William Walsh (15/8/22)

  65. The Trade and Cooperation Agreement: Two Years On – Proposals For Reform by UK Business
  66. British Chambers of Commerce (21/12/22)

  67. The Detriments of Brexit
  68. Yorkshire Bylines (June 2022) (see also)

Questions

  1. Summarise the negative effects of Brexit on the UK economy.
  2. Why is it difficult to quantify these effects?
  3. Explain the ‘doppelgängers’ method of estimating the costs of Brexit? How reliable is this method likely to be?
  4. How have UK firms attempted to reduce the costs of exporting to the EU?
  5. Is Brexit the sole cause of a shortage of labour in many sectors in the UK?

The UK left the EU on 31 January 2020 and entered an 11-month transition phase during which previous arrangements largely applied. On 30 December 2020, the UK and the EU signed the Trade and Cooperation Agreement (TCA) (see also), which set out the details of the post-Brexit trading arrangements between the UK and the EU after the ending of the transition period on 31 December 2020. The new arrangements have been implemented in stages so as to minimise disruption.

A major change was implemented on 1 January 2022, when full customs controls came into effect on imports into the UK from the EU. Later in the year a range of safety and security measures will be introduced, such as physical checks on live animals.

Not surprisingly, the anniversary of the TCA has been marked by many articles on Brexit: assessing its effects so far and looking into the future. Most of the articles see Brexit as having imposed net costs on the UK and the EU. They reflect the views of economists generally. As the first FT article linked below states, “The debate among economists on Brexit has rarely been about whether there would be a hit to growth and living standards, but rather how big a hit”.

The trade and GDP costs of Brexit

The Office for Budget Responsibility in October 2021 attempted to measure these costs in terms of the loss in trade and GDP. In October 2021, it stated:

Since our first post-EU referendum Economic and Fiscal Outlook in November 2016, our forecasts have assumed that total UK imports and exports will eventually both be 15 per cent lower than had we stayed in the EU. This reduction in trade intensity drives the 4 per cent reduction in long-run potential productivity we assume will eventually result from our departure from the EU.
 
…the evidence so far suggests that both import and export intensity have been reduced by Brexit, with developments still consistent with our initial assumption of a 15 per cent reduction in each.

This analysis is supported by evidence from John Springford, deputy director of the Centre for European Reform think-tank. He compares the UK’s actual performance with a ‘doppelgänger’ UK, which is an imaginary UK that has not left the EU. The doppelgänger used “is a subset of countries selected from a larger group of 22 advanced economies by an algorithm. The algorithm finds the countries that, when combined, create a doppelgänger UK that has the smallest possible deviation from the real UK data until December 2019, before the pandemic struck.” According to Springford, the shortfall in trade in October 2021 was 15.7 per cent – very much in line with the OBR’s forecasts.

Explanations of the costs

Why, then, have have been and will continue to be net economic costs from Brexit?

The main reason is that the UK has moved from being in the EU Single Market, a system of virtually friction-free trade and factor movements, to a trade agreement (the TCA) which, while being tariff and quota free for goods produced in the UK and the EU, involves considerable frictions. These frictions include greatly increased paperwork, which adds to the cost of trade. This has affected small businesses particularly, for whom the increased administrative costs generally represent a larger proportion of total costs than for large businesses.

Although EU tariffs are not imposed on goods wholly originating in the UK, they are imposed on many goods that are not. Under ‘rules of origin’ regulations, an item can only count as a British good if sufficient value or weight is added. If insufficient value is added, then customs charges are imposed. Similar rules apply from 1 January 2022 on goods imported into the Great Britain from the EU which are only partially made in the EU. The issue of rules of origin was examined in the blog A free-trade deal? Not really. Goods being moved between Great Britain and the EU are checked at ports and can only be released into the market if they have a valid customs declaration and have received customs clearance. This involves considerable paperwork for businesses. As the article below from Internet Retailing states:

UK and EU importers need to be able to state the origin of the goods they trade between the UK and EU. For some goods, exporters need to hold supplier declarations to show where they were made and where materials came from. From January 1, those issuing statements of origin for goods exported to the EU will need to hold the supplier declarations at the time that they export their goods, whereas up till now the those declarations could be supplied later.

Brexit has had considerable effects on the labour market. Many EU citizens returned to their home countries both before and after Brexit, creating labour shortages in many sectors. Also, it has become more difficult for UK citizens to work in the EU, with work permits required in most cases. This has had a major effect on some UK workers. For example, British touring musicians and performers find it difficult to tour, given the lack of an EU-wide visa waiver, ‘cabotage’ rules that ban large UK tour vehicles from making more than two stops before returning to the UK and new paperwork needed to take certain musical instruments into the EU.

Another issue concerns investment. Will greater restrictions in trade between the EU and the UK reduce inward investment to the UK, with international companies preferring to locate factories producing for Europe in the EU rather than the UK as the EU market is bigger than the UK market? So far, fears have not been realised as inward investment has held up well, partly because of the rapid bounce-back from the pandemic and the successful roll-out of the vaccine. Nevertheless, the UK’s dominance as a recipient of inward investment to Europe has been replaced by a three-way dominance of the UK, France and Germany, with France being the biggest recipient of the three in 2019 and 2020. It will be some years before the extent to which Brexit has damaged inward investment to the UK, if at all, becomes clear.

The TCA applies to goods, not services. One of the major concerns has been the implications of Brexit for financial services and the City of London. Before Brexit, financial institutions based in the UK had ‘passporting rights’. These allowed them to offer financial services across EU borders and to set up branches in EU countries easily. With the ending of the transition period in December 2020, these passporting rights have ceased. The EU has granted temporary ‘equivalence’ to such institutions until June 2022, but then it comes to an end and there is no prospect of deal on financial services in the near future. Indeed, the EU is actively trying to encourage more financial activity to move from the UK to the EU. Several financial institutions have already relocated all or part of their business from London to the EU.

The articles below examine these costs and many give examples of specific firms and how Brexit has impacted on them. As you will see, there are quite a lot of articles and you might just want to select a few. Or if this blog is being used for classes, the articles could be assigned to different students and used as the basis for discussion.

The future

Whilst the additional costs in terms of trade restrictions and paperwork are clear, it is too soon to know how well firms will be able to overcome them. Many of those who support Brexit argue that the UK now has freedom to impose lighter UK regulations on firms and that this could encourage economic growth. Other supporters of Brexit, however, argue that Brexit gives the UK government the opportunity to impose tougher environmental, safety and employment protection regulations. Again, it is too soon to know what direction the current and future governments will move.

Then there is the question of trade deals with non-EU countries. How many will there be? When will they be signed? What will their terms be? So far, the deals signed have largely been just a roll-over of the deals the UK previously had with these countries as a member of the EU. The one exception is the deal with Australia. But the gains from that are tiny – an estimated gain of between 0.02 and 0.08 per cent of GDP from 2035 (compared with the estimated 4 per cent loss from leaving the EU’s Single Market). Also there are fears by the UK agricultural sector that cheaper food from Australia, produced under lower standards, could undercut UK farmers, especially after the end of a 15-year transitional period. So far, a trade deal with the USA seems a long way off.

Then there are uncertainties about the Northern Ireland Protocol, under which there is an effective border between Great Britain and the EU down the Irish Sea, with free trade across the Northern Ireland–Republic of Ireland border. Will it be rewritten? Will the UK renege on its treaty commitments to impose checks on goods flowing between Northern Ireland and Great Britain?

Difficulties with the Northern Ireland Protocol, highlight another uncertainty and that is the political relationships between the UK and the EU, which have come under considerable strain with various post-Brexit disputes. Could these difficulties damage trade further and, if so, by how much?

What is clear is that there is considerable uncertainty about the future, a future that for some time is likely to be affected by the pandemic and its aftermath in both the UK and the EU. As the OBR states:

It is too early to reach definitive conclusions because:

  • The terms of the TCA are yet to be implemented in full, meaning trade barriers will rise further as more of the deal comes into force. For example, the introduction of full checks on UK imports has recently been delayed until 2022.
  • The full effect of the referendum outcome and higher trade barriers will probably take several years to come through, with businesses needing considerable time to adjust.
  • The pandemic has delivered a large shock to UK and global trade volumes over the past 18 months, making it difficult to disentangle the separate effect of leaving the EU.
  • Finally, trade data tend to be relatively volatile and are revised frequently, rendering any initial conclusions subject to change as the data are revised.

Analysis

Articles

Survey

Questions

  1. Summarise the reasons why the volume of trade between the UK and the EU is likely to be below the level it would have been if the UK had remained in the Single Market.
  2. How can economists disentangle the effects of Brexit from the effects of Covid? How is the ‘doppelgänger UK’ model used for this purpose?
  3. Are there any economic advantages of the UK’s exit from the EU? If so, what are they and how significant are they?
  4. The OBR forecasts that there will be a long-term reduction of 15 per cent in both UK imports from the EU and UK exports to the EU. What might cause this figure to be (a) greater than 15 per cent; (b) less than 15 per cent?

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.

Documentation

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.

VAT

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.

Services

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.

Conclusions

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.

Articles

Official documents

Questions

  1. Explain what is meant by ‘rules of origin’.
  2. 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.
  3. Are tariffs exactly the same as customs duties? Is the distinction made in the Guardian article a correct one?
  4. Is it in the nature of a free-trade deal that it is not the same as a single-market arrangement?
  5. Find out what arrangement Switzerland has with the EU. How does it differ from the UK/EU trade deal?
  6. What are the advantages and disadvantages of the Swiss/EU agreement over the UK/EU one?
  7. Are the frictions in UK–EU trade likely to diminish over time? Explain.
  8. Find out what barriers to trade in services now exist between the UK and EU. How damaging are they to UK services exports?