It seems the Brexit process is likely to founder on the rocks of Sovereignty. Earlier today Boris Johnson said, “the EU was seeking an “automatic right” to retaliate against the UK if its labour and environmental standards diverged from theirs.”

Now it occurred to me to look at how the Canada deal (CETA) with the EU is organized. Some facts: In 2018:

– Canada’s trade in goods with the EU accounted for 10% of its total trade with the world
– the EU accounted for approximately 8% (7.62%) of Canada’s total goods exports
– Canada accounted for 2% of the EU’s total external goods trade
– bilateral trade in goods between the EU and Canada was valued at approximately $90.9 billion
In 2018, the most important category of goods traded between Canada and the EU were:

– machinery (25.6% of EU exports to Canada and 24.3% of its imports)
– chemical and pharmaceutical products (16.2% of EU exports and 9.1% of its imports)
– transport equipment (15.6% of EU exports and 9.1% of its imports)

Looking at the Canadian trade commissioner’s guidance documents makes it clear that regulatory compliance is a big thing. Types of regulation clearly vary across product sectors such as food to chemicals and medical products and medicines. As might be expected there are shipment inspections for foodstuffs. For other product sectors there is European Certification and CE marking where a symbol is affixed to a product by its manufacturer before being placed on the EU market to certify that the product has been assessed and complies with all EU requirements for safety, health and environmental protection.

So here’s the thing. The EU is not demanding that Canadian standards conform to the EU standards. Only that products shipped to the EU are compliant with EU regulatory standards. If they do not comply, they don’t get shipped or accepted. So there is no suggestion that the EU is mandating Canadian internal affairs or interfering in their sovereignty.

Why should the UK be any different? Well of course the UK products are currently compliant – they have already been approved by the regulators. So only new products coming to market need to be certified. So where’s the problem? If the UK decides to lower its standards for chicken, to accommodate US trade, then chicken products are no longer acceptable in the EU. It’s a responsibility upon the UK supplier to obtain recertification when product composition changes, and submit to shipment or periodic or self requested regulatory assessment.

And if UK labour or environmental standards diverge from the EU standards, then the regulatory body should flag the issue and the product no longer ships to the EU. Where’s the problem? If the EU relationship with the UK is the same as with Canada. the EU isn’t trying to change the UK’s standards, merely ensuring that products shipped to the EU are compliant.

Perhaps it’s a matter of trust? Does the UK accept EU regulatory assessment and assessors? But why should the UK relationship with the EU be any different to Canada’s?

Exporting to the EU – A guide for Canadian business