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Raphael Hogarth @Raphael_Hogarth
, 10 tweets, 5 min read Read on Twitter
The UK and the EU have both released slides on "level playing field" provisions in a future trade deal - commitments on things like environmental and social protection, labour rules and tax that prevent either side from engaging in a "race to the bottom". Interesting to compare:
On state aid the two sides are basically in agreement. Same rules, domestic enforcement by the CMA, plus recourse to dispute resolution if there are disagreements.
That said, the UK studiously avoids a discussion of remedies if it is found to be non-compliant. The EU wants a "robust sanctions regime", for state aid and other elements of LPF.
On tax, the story is a little different. The EU slides suggest various provisions in this area, and the UK slides just... don't mention it. Awkward.
The environment. The EU proposes a "tailored approach" which stops the UK from lowering standards in a range of areas (left). The UK seems to be on board: proposes "reciprocal non-regression" (right). New environmental watchdog to enforce all this, accountable to Parliament.
On social rights/labour, I detect very slight divergence of approach? UK proposes non-regression of domestic labour standards (left), but EU ask seems to be a little bit wider, incl non-regression on health and safety (right). UK just notes it's well behaved on this.
Bit of context: left image is EU infringement actions against the UK in recent years. The areas being discussed as part of "level playing field" are highlighted in green. Right image is cases against UK at ECJ, w environment and tax at top. So can see why it's an EU concern.
2 pts of interest. 1st, there's a debate to be had about what "non-regression" or "non-lowering of standards" means. Is it:
(1) go no lower than current EU standard
(2) go no lower than current UK standard (often higher)
(3) if standard goes up in future, it cannot come back down
Second, UK and EU both make lots of how exceptional these provisions are. UK (left) says pointedly that the "degree of market openness" is driving its offer - i.e.,give us unprecedented market access in exchange for unprecedented LPF. EU (right) notes "geographical proximity".
The real dog-fight will be over the process for remedies and sanctions. Who decides whether the UK has lowered its standards or not, and what can the EU do about it? Suspect this will heat up a bit in next phase of talks... /ends
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