Opinion of the European Economic and Social Committee – Looking to the future of EU-UK relations: 2026 TCA Review from a civil society perspective (own-initiative opinion)
Date: 2025-07-16
Institutions: European Economic and Social Committee
Subjects: EAEC, United Kingdom, civil society, cooperation agreement (EU), cooperation policy, revision of an agreement, trade agreement, trade agreement (EU)








C_202505144EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/5144


28.10.2025






Opinion of the European Economic and Social Committee
Looking to the future of EU-UK relations: 2026 TCA Review from a civil society perspective
(own-initiative opinion)
(C/2025/5144)


Rapporteur: 
Tanja BUZEK

Co-rapporteur: 
Peter BYRNE






Advisors


Elena CRASTA (to the rapporteur)
Jonathan PEEL (to the co-rapporteur)




Plenary Assembly decision


23.1.2025




Legal basis


Rule 52(2) of the Rules of Procedure




Section responsible


External Relations




Adopted in section


12.6.2025




Adopted at plenary session


16.7.2025




Plenary session No


598




Outcome of vote
(for/against/abstentions)


147/0/2




1.   Conclusions and recommendations









1.1.



The EU’s special relationship with the UK is unlike that with any other trade and political partner. Like-minded in shared interests, values and perspectives, determined by the geographical proximity as trading partners and bound by strong civil society ties. What is often forgotten, all major European organisations representing businesses, trade unions, consumers and social, youth or environmental interests still have UK affiliates among their membership.












1.2.



Momentum is high to deepen and upgrade this EU-UK partnership, not least due to emerging geopolitical imperatives. The 2026 review of the Trade and Cooperation Agreement (TCA), in combination with the political ‘reset’ following the May EU-UK summit, has the potential to mark a significant step in the evolution of post-Brexit relations. The goal must be a stable, predictable and cooperative partnership, irrespective of prevailing political majorities.












1.3.



Achieving tangible improvements and opportunities for all need to follow now from the EU-UK summit and the TCA review. The European Economic and Social Committee (EESC) welcomes new opportunities arising from the summit, notably for dynamic alignment on rules and standards, certainty and predictability on trade and fisheries, and for re-joining Erasmus+ and the prospect of a future youth experience scheme. This opinion should serve as a compass for EU and UK institutional players in developing the joint roadmap for the future programme of work.












1.4.



Making the EU and the UK Domestic Advisory Groups (DAGs) part of the review and future work process, as they are a crucial source of input on both sides. While the parties’ focus is on ‘implementing a trade agreement’, we as civil society are ‘living it every day’, as businesses, workers, consumers and citizens. The EESC further calls for a dedicated EU-UK Social Dialogue Summit alongside the leaders’ meeting to involve social partners in the deliberations.












1.5.



Enhanced regulatory cooperation on non-tariff barriers provides the biggest opportunity to improve the bilateral trade relations. The closer the two regulatory systems are, the fewer frictions will emerge with considerable gains for all. For its wider trade benefits, we welcome negotiations on an EU-UK Sanitary and Phytosanitary (SPS) agreement and underline the importance of adherence to the Precautionary Principle as a core EU value. Consumer rights enforcement should be in the cooperation agenda and enable market surveillance authorities to jointly protect consumers; a specially established divergence assessment unit should monitor divergence in collaboration with stakeholders and a shared EU-UK portal could provide access to updated regulatory information and clearer guidance, in particular for SMEs in both jurisdictions.












1.6.



Advancing the mutual recognition agenda would reduce border checks and improve bilateral trade flows, which in turn is good for growth and job creation. An enhanced range of agreements should cover professional qualifications, chemical standards, and conformity assessment declarations. They reduce trading costs and support close regulatory alignment. Dual requirements for border crossings should be streamlined as far as possible to avoid any increase in congestion and to minimise potential disruption.












1.7.



Trade in services offers the greatest potential to develop the relationship between the EU and UK post-Brexit. The closer new regulatory frameworks to facilitate cross-border services align, the greater the potential to increase market access. We urge action to address mobility challenges, in particular reform of the UK visa sponsorship scheme for greater mobility and fair competition between EU and UK service providers. Future mobility talks need to uphold mutual high standards on employment rights and encourage a race to the top.












1.8.



Upholding the non-regression and level playing field clauses must remain a key priority for the parties. The DAGs’ compliance monitoring must continue unabated. There should be regular dialogue, exchanges and cooperation around improvements on workers’ and environmental rights to make progress towards this goal, combined with effective enforcement. To strengthen social dialogue, the EESC encourages exploring how to facilitate UK workers’ participation in European Works Councils (EWCs).












1.9.



Climate action and active industrial policy require closer regulatory and policy alignment. The EESC welcomes the Emissions Trading Schemes (ETS) of both parties being linked, and recommends cooperation to allow the necessary investments to support the transition to clean energy and industry.












1.10.



A ‘future-proof TCA’ must incorporate the youth perspective, progressively removing barriers to seizing new opportunities. Brexit must not become a new ‘Berlin wall’ for future generations. Young people on both sides made a strong case for the UK to re-join Erasmus+, which also supports vocational learning and apprenticeships. Such apprenticeships must meet good quality criteria, with decent terms and conditions, and benefit all young people and young workers – not just certain sectors.












1.11.



Safeguarding Northern Ireland’s unique status and trading conditions. The EESC underlines the paramount role and achievement of the 1998 Belfast Agreement (‘The Good Friday Agreement’) in avoiding any return to violence. It welcomes the progress made through the 2023 Windsor Framework, and urges the non-diminution of rights for Northern Ireland to remain core to the Review.












1.12.



Setting an ambitious review beyond a mere scoping exercise. The EESC urges the parties to conclude comprehensive mutually beneficial agreement(s) focussing on determining unfinished arrangements on the areas referenced in the annexes to the TCA. Any additional agreement(s) must be under the overarching architecture of the TCA principles and level playing field commitments, and the monitoring scope of the DAGs.




2.   Background of the own-initiative opinion









2.1.


The TCA sets the current legal framework for bilateral trade relations between the EU and the UK, with a unique status for Northern Ireland. In spite of Brexit, the UK remains a potential partner in various fields, including environment, climate change, youth exchanges, consumer interests and external security and defence.












2.2.


The unique relationship between the EU and the UK is also determined by its ever strong civil society ties. Advanced by its EU-UK Follow-up Committee, the EESC has kept up relations with UK civil society following Brexit and invested in building new relationships, underpinned by the follow-up work on our related opinions. The TCA set up two civil society bodies, both in the EU and the UK – the DAGs, to monitor the implementation of the agreement.












2.3.


Commission President Von der Leyen’s 2024-2029 political guidelines state a clear commitment to strengthening relations with the UK on issues of shared interest, such as energy, security, resilience and people-to-people contacts. The legally required TCA review (after five years) scheduled for 2026 is limited to an assessment of the implementation of the existing provisions, but there should be no constraints to improve the agreement at a fundamental level. The first ever EU-UK summit on 19 May 2025 highlighted the potential for a new strategic framework after challenging years.












2.4.


Looking ahead, the key objective for this own-initiative opinion is to highlight the major challenges faced by business, workers, consumers and citizens, and to flag areas for improving relations, such as regulatory co-operation between the EU and the UK. It should also serve as a compass for EU and UK institutional players in developing the joint roadmap as a follow up to the summit in May 2025.




3.   Trade relations between the EU and the UK following Brexit









3.1.


The trading relationship between the EU and the UK remains highly significant for both parties, for what is the world’s second largest trade relationship. For greater perspective of market proximity, the UK still trades more goods and services with Germany, the Netherlands, France and Ireland than with the US and China altogether (1). However, the UK’s customs union trade intensity with the EU is expected to decline by 15 % due to Brexit (2).












3.2.


The EU benefits from its integrated single market coupled with a network of preferential trade agreements with various countries, providing access to an attractive market of 448 million people. The UK has sought new trade agreements outside the EU (India, New Zealand) and joined the Trans-Pacific Partnership agreement (CPTPP); however, it faces challenges in replicating the volume of the EU’s preferential agreements, due to the reduced attractiveness of a 68 million-person market outside of the EU customs union. Consequently, the EU’s trade options are more positive.












3.3.


Global trade is reconfiguring along geopolitical lines, with economies like China and the US shifting trade patterns and increasing uncertainties and challenges to a rules-based order. The EU and UK must navigate these changes and should acknowledge that both were a stronger trading body before Brexit, and that a closer alignment in trade would benefit both.












3.4.


The TCA governs EU-UK trade now, maintaining tariff-free and quota-free exchanges but without the benefits of EU membership. Both sides are implementing tools that reshape how both goods and people move across borders, with significant operational and economic impacts expected. The UK has introduced its Border Target Operating Model (BTOM) that includes risk-based controls for imported goods. The EU has prepared its Entry/Exit System (EES) for non-EU nationals, and the UK its Electronic Travel Authorisation (ETA) equivalent.












3.5.


Dual requirements for the EES and the ETA bear the risk of increased congestion at key EU-UK crossing points, both rail and port. Equally, they move the parties further apart from a common feature system and add new thresholds to the relationship.












3.6.


The TCA review should be accompanied by easily accessible cost-benefit-analyses for both parties, ideally for them to engage jointly and to underpin political arguments with examining the benefit of keeping parallel track. Beyond the negotiation safeguards, to show what the direct economic – and long-term civic – benefit would be for both parties.




4.   Recalibrating a strategic partnership









4.1.


Momentum is high to recalibrate and reboot the bilateral relationship, especially to streamline trading relations, secure an ambitious security pact, smooth out ongoing issues on citizen rights and trigger closer cooperation in other areas.












4.2.


Following the 2024 election, the UK has called for a ‘reset’ and has jointly agreed with the EU that they will strengthen cooperation in areas including the economy, energy, security and resilience. A first-ever bilateral EU-UK Summit on 19 May in London marks a significant step in the evolution of post-Brexit relations and towards a clear framework for strategic cooperation. This development, combined with the review of the TCA in 2026 and emerging geopolitical needs, provide the opportunity to deepen and upgrade the EU-UK partnership. Given the impact some of the future decisions will have on the world of work, the EESC recommends that a dedicated EU-UK Social Dialogue Summit be convened alongside the leaders’ meeting to ensure social partners are involved in the deliberations.












4.3.


As the TCA allows for largely tariff-free trade between the EU and the UK, enhanced cooperation on non-tariff barriers provides the biggest opportunity to improve bilateral trade relations. Moving beyond the immediate turbulence of withdrawal, there is a case for a pragmatic realignment of interests rooted in mutual economic benefit and shared geopolitical priorities. While both sides have held firm to key principles (sovereignty for the UK, single market integrity for the EU and preserving an overall level playing field), changes to the existing agreement will have to reflect a renewed spirit of cooperation.












4.4.


The TCA contains the most innovative labour and environmental clauses the EU has ever negotiated in its trade agreements: the non-regression and level playing field clauses. The DAGs have a special standing in these. The EESC calls for upholding mutual high standards on workers’ and environmental rights in the UK and the EU and encourages fostering a race to the top by building on these clauses. The closer the two regulatory systems are, the fewer frictions there will be with considerable gains for all and a diminished risk of litigation under the TCA.












4.5.


An updated TCA could offer each side tangible political wins. For the EU, it preserves the foundational rules of the single market and reinforces the credibility of its external trade policy. For the UK, the agreement allows for enhanced market access and reduced trade friction. Both sides benefit from greater predictability, economic stability and an improved capacity to address shared challenges – whether in research, security or climate policy. Both parties’ relations with other significant trade partners like the US must not undermine the TCA’s core principles and stability.












4.6.


The geopolitical environment has changed dramatically since the Brexit Referendum and the conclusion of both the Withdrawal Agreement and the TCA. This underscores the critical importance for all our citizens of an optimal EU-UK cooperation and largest possible degree of alignment.












4.7.


This review offers the opportunity for a mature political settlement – one that recognises the value of constructive engagement without requiring full political integration. In a global context shaped by economic uncertainty, war on the European continent and rising geopolitical tensions, a revised TCA would signal that the UK and the EU remain committed to working together where interests align.












4.8.


The TCA review must not fall short of the views of organised civil society, as we are the ones on the ground to flag where the TCA has failed or requires improvement. A closer involvement of civil society throughout and beyond this process can help shape the future of EU-UK relations in a less politicised way. The EESC believes the DAGs established by the TCA are the key for ensuring that worker, business and civil society interests are represented in a balanced way.




5.   Specific comments


Trade in Goods









5.1.


Businesses need to be able to navigate customs checks quickly and without undue paperwork.












5.2.


Tariffs and quotas: The TCA allows for tariff-free and quota-free trade between the EU and the UK, provided goods meet the agreed rules of origin and other administrative requirements introduced because of the UK no longer being part of the EU internal market. There is an overriding need to reduce frictions in the implementation of these administrative requirements in any revised agreement, providing there is sufficient regulatory alignment on the UK side to allow for trade between the EU and the UK that is as seamless as possible.












5.3.


Non-tariff barriers: Despite the absence of tariffs, non-tariff barriers (such as customs checks) and regulatory divergences have contributed to a significant decline in the bilateral trade flows. The more the UK and the EU converge in their regulatory regimes, the greater the potential to significantly reduce these non-tariff barriers.












5.4.


Conformity assessments: The lack of mutual recognition between the two systems adds a layer of complexity in conformity declarations. An agreement in this area would avoid needless re-testing for all products certified to EU standards entering the UK market, reducing the costs of compliance.





Trade in services









5.5.


Trade in services offers the greatest potential to develop the relationship between the EU and UK post-Brexit.












5.6.


Market access: The TCA does not provide the same level of access for services as it does for goods. The loss of passporting rights has particularly impacted the financial services sector, requiring new regulatory frameworks to facilitate cross-border services. In this area, too, the more these frameworks align, the greater the potential to increase market access.












5.7.


E-commerce: Existing VAT registration thresholds in the UK constitute a non-tariff barrier that makes it hard for EU SMEs to sell through e-commerce directly to UK consumers.












5.8.


Professional qualifications: There is no longer an automatic mutual recognition, creating obstacles for professionals seeking to work across EU-UK borders. This must be addressed as a matter of priority in any reviewed agreement.












5.9.


Financial services: The 2023 Memorandum of Understanding established a framework for a structured regulatory cooperation in financial services that are currently not within the TCA scope. This possibility for strengthening cooperation is not being fully used. Cooperation work should be intensified, notably the insurance sector.












5.10.


Mobility of service providers: The current UK visa sponsorship scheme for employers increases the cost to hire EU contract services suppliers by UK based entities. We urge reform for greater mobility and fair competition between EU and UK providers.












5.11.


Transport services: While the operational impact of the new border management tools may vary across transport modes, EU-UK border crossing points and seaports are particularly vulnerable to passenger congestion and operational challenges. Passenger and carrier mass awareness campaigns, testing and flexibility measures, and staff training and resourcing need to ensure preparedness for new tools.





Regulatory cooperation and standards









5.12.


As the TCA allows for largely tariff-free EU-UK trade, enhanced cooperation on non-tariff barriers is the biggest opportunity to improve bilateral trade relations. While the EU and the UK pursue their own regulatory agendas, divergence can pose a threat to the free flow of goods and services. As such, regulatory cooperation is essential for avoiding unintended consequences.












5.13.


Divergence: Differences in regulatory standards have led to increased compliance costs for businesses, particularly in sectors such as chemicals and pharmaceuticals.












5.14.


Level Playing Field: The TCA includes provisions to prevent unfair competitive advantages by ensuring both parties maintain common standards in areas like labour rights and environmental protection. It is crucial to monitor and enforce these provisions, as the TCA also requires non-regression from the level of protection in force at the time the UK left the EU.












5.15.


Consumer rights: The TCA encourages cooperation on a range of topics but not on consumer rights enforcement, which should be included in the review. There is a need to fully operationalise the Technical Barriers to Trade provisions in the TCA and enable market surveillance authorities to jointly protect consumers.





Sanitary and phytosanitary (SPS) measures









5.16.


Increased checks and certification: the EU now considers the UK a third country, requiring SPS checks on agri-food products to mitigate biosecurity risks. This change has led to additional documentation and inspections, causing delays and increased costs for exporters. The EESC welcomes the EU-UK Summit agreement to negotiate an agri-food deal aimed at significantly reducing SPS-related certificates and controls for movements of animals, animal products, plants, and plant products, and encourages a swift conclusion. Adherence to the precautionary principle remains a core EU value, and this is reflected in the agreement’s requirement for timely dynamic alignment of UK regulations with EU rules.












5.17.


Veterinary staff shortages: The rise in SPS certification requirements has increased the demand for veterinarians. However, the UK’s capacity to meet such demands is uncertain, partly due to the lack of mutual recognition of veterinary qualifications. This hinders trade flows from the EU to the UK and significantly delays deliveries of EU consignments in the UK.












5.18.


Agri-food standards: standards in the EU and the UK on food consumption are very similar. In dealing with third trade partners, the EU and the UK should avoid any risk to compromise mutual standards and principles as secured in the TCA.





Workers’ rights









5.19.


The review of the TCA must continue to provide a good deal for workers on both sides.












5.20.


The EESC welcomes the introduction of the Employment Rights Bill in the UK, upholding mutual high standards. However, clarifications are needed on the status of proposals for employment tribunal fees, changes to collective consultation rights (TUPE), rolled-up holiday pay and for recording working hours.












5.21.


Thousands of workers in the UK risk losing or have lost access to transnational information and consultations to which they have been entitled, in many cases, for more than 20 years. There is no legal obligation to keep UK representatives on EWCs, but the TCA review needs to urgently address the practical consequences. Workers’ presence depends on the goodwill of management and matters that have an impact on the UK and one Member State are no longer considered transnational, with no information sharing or consultation to take place. There is no guarantee that UK activities will be within the scope of future EWCs. Taking into account the above negative impact on EWCs, the EESC encourages exploring how to facilitate UK workers’ participation in EWCs in order to strengthen social dialogue.












5.22.


The EESC also highlights the importance of preventing disruption to the lives of workers around the Campo de Gibraltar and ensuring that the rights of both EU and UK workers are protected.





Opportunities for all









5.23.


The end of free movement has complicated business travel, workers’ employability, and researchers, students and youth exchanges.












5.24.


Temporary assignments: new rules affect sectors reliant on short-term mobility and hamper the ability of EU nationals other than Irish nationals to work and stay in the UK.












5.25.


Occupational opportunities: the UK has already re-joined the Horizon and Copernicus programmes. There is a strong case for the UK to also re-join Erasmus+, which also supports vocational learning and apprenticeships. Apprenticeships should meet specific criteria on quality, with decent terms and conditions. We urge new pathways for workers, researchers, students and apprentices to improve their employability.












5.26.


Youth exchanges: it is essential that opportunities created by Erasmus+ benefit young people and workers, not just certain sectors. The EESC calls for progressively removing barriers for young workers to seize new opportunities.












5.27.


Non-discrimination: A limited number of provisions in the TCA, including social security coordination, account for the concerns of people with disabilities. A person with additional needs certainly cannot move and travel without guaranteed assistance. There is need to explore the interoperability of the EU and UK systems of mutual recognition of disability status.





Regulatory divergence









5.28.


There will be inevitable legislative divergence between the EU and the UK, via either inertia or legislative action from either side. Consequently, the EU Commission should set up a specially tasked divergence assessment unit to monitor divergence in collaboration with all stakeholders.












5.29.


Access to updated regulatory information, clearer guidance, and direct contact with the customs authorities: A shared portal so that in particular SMEs in both jurisdictions can see the advice being offered, this will also be useful in terms of building co-operation, communication and trust.












5.30.


Animal welfare standards: As like-minded partners, the EU and the UK have a unique opportunity to cooperate on animal welfare and plant health and contribute to fighting shared challenges such as the rise of antimicrobial resistance, the spread of zoonotic diseases and biodiversity loss.












5.31.


While the TCA acknowledges the link between animal welfare and sustainable food production, differences in regulatory approaches have emerged. The EU has implemented stricter standards in areas like pesticides, while the UK has introduced higher animal welfare standards. This divergence complicates compliance for businesses operating across both markets.












5.32.


Chemical testing: The absence of mutual recognition for chemical testing data may result in duplicated efforts, increasing costs and potentially leading to more animal testing in the UK.





Northern Ireland









5.33.


The Protocol has created unique trading conditions and the commitment to non-diminution of rights, which must continue to be upheld.












5.34.


The 2023 Windsor Framework paving the way for restoration of power-sharing in Northern Ireland aimed to address some political and economic challenges, but its implementation and effectiveness remain contentious with some sections of the community.






Brussels, 16 July 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  
            https://www.gov.uk/government/statistics/trade-and-investment-core-statistics-book/trade-and-investment-core-statistics-book.

(2)  For more information, please see online the Annex to this opinion: https://www.eesc.europa.eu/sites/default/files/2025-05/Annex-to-REX-600-Opinion.pdf.


ELI: http://data.europa.eu/eli/C/2025/5144/oj
ISSN 1977-091X (electronic edition)