Brussels and London are likely to welcome the Brexit reset deal, celebrated with considerable enthusiasm at Lancaster House, with a clear path forward towards a closer relationship now established.
The election of a Labour government was set to cast aside the hostile remnants of the Boris Johnson era, though the emergent challenge from Reform UK may still limit Keir Starmer’s flexibility.
Russia’s invasion of Ukraine has sparked a strong desire for enhanced security and defense cooperation, amplifying the shared sense of purpose crucial for facilitating negotiations.
The Security and Defence Partnership establishes a new dialogue forum aimed at enhancing collaboration on Ukraine, defense procurement (UK defense contractors may gain access to the EU’s €150bn defense fund), mobility of military materials and personnel, space, cybersecurity, and hybrid threats.
This move signals to the US President, before next month’s NATO summit in The Hague, that Europeans are prepared to take on more responsibility for defending the continent.
“This will bolster Europe’s contribution to NATO,” stated a senior EU official. “We are coordinating closely with NATO on this. A strong working relationship with the UK is beneficial as we lead up to the Hague Summit.”
Irish sources indicate that Dublin is comfortable with this interpretation of the deal, as the EU has similar security and defense arrangements with countries like Norway, Japan, and South Korea.
However, much of what was announced remains to be finalized, reflecting a cautious approach on Mr. Starmer’s part.
(From left) Keir Starmer, David Lammy, Kaja Kallas, Ursula von der Leyen, and António Costa at the talks
“Labour’s ambitions were likely modest,” remarked Paul McGrade, a senior counsel with Lexington Communications, a public affairs consultancy. “They didn’t want to alarm eurosceptics too much.”
The EU official concurs.
“No fundamental red lines from the Labour manifesto were crossed,” they said. “We’re not reverting to freedom of movement or rejoining the single market or customs union, but we are building upon previous agreements, such as the Withdrawal Agreement, the [Trade and Cooperation Agreement], and the Windsor Framework, while introducing new areas of collaboration.”
Since the election, Mr. Starmer has skillfully balanced these red lines by indicating that Labour would be open to “dynamic alignment,” which entails the UK adapting to EU rules on food safety and animal health to simplify paperwork when importing EU food and exporting British products to Europe.
Furthermore, there could be a role for the European Court of Justice in settling disputes regarding EU law, contingent on initial evaluation by a joint arbitration panel.
In practice, the agreement was reached relatively swiftly after months of maneuvering post-Labour victory.
Mr. Starmer met Commission President Ursula von der Leyen in October in Brussels, with the only concrete outcome being the announcement of a summit in the first half of this year.
Afterward, Mr. Starmer resumed discussions about his red lines, while EU officials conveyed they were awaiting a proposal from the UK.
“Both sides are poised, but no one wants to make the first move,” an EU diplomat remarked at the end of January. “The October meeting aimed to demonstrate both parties’ seriousness about the reset, but yielded no tangible results apart from the idea of a summit. Nothing has transpired since then.”
Donald Trump’s presidency certainly sharpened perspectives, particularly following the revelation of his administration’s cavalier attitude toward European security.
EU fishing vessels will maintain access to UK waters until 2038 under the new agreement.
Yet, complexities arose as France and other member states insisted that any defense agreement be linked to prolonging EU access to UK fishing waters and an agreement on youth mobility—an issue that encountered obstacles in the Brexit trade agreement (TCA).
Simultaneously, Mr. Starmer’s repeated calls for greater access for UK businesses conflicted with his red lines regarding the single market and customs union.
This scenario guaranteed that discussions would culminate in a last-minute flurry of intense negotiations.
As 27 EU ambassadors remained on alert last night, EU and UK officials continued discussions into the early hours, with diplomats in Brussels expressing concern that London was exaggerating the sense of a deal being concluded.
“The EU’s message is unmistakable,” one EU diplomat stated late yesterday afternoon. “We are looking forward to a successful summit, the so-called ‘reset’ requested by the Brits, but it must mark the inception of a mutually beneficial partnership.
“Numerous topics are up for discussion, with the security and defense partnership being the most prominent. The entirety of the dialogue is a collective package; we will not accept terms solely advantageous to the UK without strong assurances and commitments on other key issues for the EU, such as fisheries, energy, and youth mobility.”
A major contention involved fisheries, a perpetually controversial issue between Brexit Britain and the EU.
Under the TCA, EU fishing vessels secured continued access to UK waters from 2021 until mid-next year, at which point a new arrangement must be established.
As discussions over the reset heated up, Britain proposed extending current arrangements for another ten years.
France—along with Ireland, Belgium, the Netherlands, and others—argued that this timeframe was inadequate and that the EU would lose any leverage at the end of the ten years when trying to negotiate continued access.
Consequently, those nations advocated for a time-limited SPS (sanitary and phytosanitary) agreement, which would be a significant win for Mr. Starmer, to be tied to the fisheries deal.
The UK then offered to prolong the arrangements by an additional two years, extending the deadline to 2038.
France and the others subsequently withdrew their objections.
Taoiseach Micheál Martin stated that the certainty provided for fishermen allows them to ‘make long-term and sustainable decisions.’
It is reported that Friedrich Merz, the new German Chancellor, enthusiastic about a security and defense agreement and eager to leave his mark, urged French President Emmanuel Macron to relent during meetings in Kyiv the weekend prior and at the European Political Community (EPC) in Tirana, Albania, on Friday.
According to one diplomat, other factors may be influential by the time the 2038 fisheries deadline approaches, providing the EU with leverage, while in the meantime, the EU fishing industry enjoys a prolonged period of stability.
However, the Irish Fish Producers Organisation expressed discontent.
“The deal primarily extends the existing, unbalanced EU fishing quota and access arrangements for another 12 years, until June 2038,” remarked Chief Executive Aodh O’Donnell.
“This poses a serious threat to our coastal communities. Ireland incurred the steepest costs in 2020 from the TCA, with 40% of the total value of quotas transferred to the UK coming from Ireland.
“It appears that other EU coastal states, like France, resisted relinquishing long-established fishing rights, and their governments have supported them. As a result, the Irish fishing industry feels neglected yet again, and our government has failed to safeguard our interests.”
Taoiseach Micheál Martin emphasized that the assurance for fishermen enables them to “make long-term and sustainable decisions.”
In summary, the defense and security aspects of the reset are the most robust, while many other elements remain to be negotiated.
While an SPS agreement would eliminate checks and controls, goods entering Northern Ireland from Britain will still encounter customs challenges.
Currently, the deal only obligates both sides to “work towards” an EU-UK SPS area that would generally cover “the vast majority of movements of animals, animal products, plants, and plant products between Great Britain and the European Union…without the certificates or controls currently required.”
The joint declaration states that “the continuation of the Windsor Framework will ensure Northern Ireland retains its unique dual access to both the European Union Single Market and the United Kingdom internal market.”
A source close to the negotiations commended Mr. Starmer’s emphasis on the importance of the Northern Ireland issue in forming an SPS agreement, with Ireland, Poland, and other member states also encouraging the Commission to be inventive.
“Starmer, particularly in recent days but especially within the last 24 hours, has kept Northern Ireland at the forefront,” noted the source. “We have not witnessed such tangible interest in Northern Ireland from a UK Prime Minister since Tony Blair.”
Irish officials assert that the commitment to a detailed SPS agreement is favorable for reducing friction along the Irish Sea border, as well as facilitating the substantial agrifood trade between Ireland and the UK.
One official pointed out that even though an SPS agreement will tremendously diminish checks and controls, goods entering Northern Ireland from Britain will still face customs hurdles.
Iceland also expressed strong support for re-engaging with the EU’s internal energy market, which would enhance the efficient trading of electricity and renewable energy, and both sides would aim to align on a joint Emissions Trading System (ETS).
Once finalized, these agreements will require the UK to remain dynamically aligned with EU rules on energy and emissions, with a similar role for the ECJ as in the SPS agreement.
Negotiating these aspirations will take time.
Concerning SPS, both parties will need to conduct audits to evaluate where the UK has maintained alignment with EU regulations and where divergences exist.
“Certain components will need to be meticulously revisited,” commented a source close to the discussions. “But dynamic alignment remains dynamic alignment.”
It is likely that both audits will have to proceed concurrently and may necessitate a timeline or roadmap. Additionally, both parties might need to agree on addendums to the Brexit Withdrawal Agreement and the 2005 Constitution Act to allow the UK to become what Brexiteers derogatorily refer to as a “rule taker.”
The UK government is keeping such nuanced details under wraps. Keir Starmer lauded the deal today as granting the UK “unprecedented” access to the EU single market for food and fisheries products (unprecedented, if we ignore Britain’s prior membership in the EU).
He also highlighted the potential for UK tourists to utilize passport eGates for EU entry without queuing, although this must be formally negotiated and implemented by each EU member state (the joint statement refers to “the potential use of eGates where appropriate”).
The Youth Mobility scheme has been rebranded as the Youth Experience scheme and will require additional development.
Some analysts believe the agreement was designed to afford the Labour government much-needed fiscal credibility, with Mr. Starmer emphasizing that the SPS deal could yield an additional €10bn per year by 2040.
“I believe there was an urgent, short-term necessity for the UK government to convince their fiscal watchdog that the global economic outlook is not as grim,” stated Mr. McGrade of Lexington Communications, “and thus, please provide us with improved growth forecasts in the autumn.”
For the industry, the perceived lack of ambition in the reset, beyond SPS, is disheartening.
Steffen Hoffman, managing director of Bosch Ireland and UK, informed RTÉ News that the greatest burden of Brexit is not customs duties or regulatory disparity, but red tape.
“Before Brexit, we had approximately 50 import transactions annually,” he remarked. “Now, we face 10,000. Each transaction entails a process, requiring documentation and significant administrative efforts. We have to establish an entire department to manage these tasks, diverting our capacity away from innovation and R&D.”
He acknowledged that the option of the UK rejoining the EU customs union—termed a “first prize” option—remains a red line for Mr. Starmer.
“We do not fully understand why this has to be regarded as a red line. Therefore, today’s reset represents a favorable progression. But does it warrant the label ‘ambitious’? I am uncertain.”
