The outcome of the 19 May European Union-United Kingdom summit took the form primarily of declarations of intent that will need to be followed with substantive negotiations. Nevertheless, the summit was a major step towards the EU and UK working together more closely.
The most ambitious part of the EU-UK reset is on security and defence. This makes sense because the EU cannot achieve strategic autonomy without working with the UK to build effective defences and deter Russian aggression. The signing at the summit of a security and defence partnership allows British firms to take part in joint defence procurement projects and the UK to join the new coalitions of the willing emerging across Europe to manage geopolitical challenges.
Once the EU Security Action for Europe (SAFE) instrument for defence spending by EU countries is finalised, agreement will be needed on how the UK will participate, but most critically, UK defence firms will be able to participate in joint procurement projects, boosting overall capacity in Europe and helping fill capability gaps. The EU and UK also agreed on police cooperation on terrorism and serious crimes: important technical work against Russian sabotage, cyber-attacks and assassinations.
The trade outcomes of the summit are as ambitious as they could be given the red lines on both sides. Most importantly, the EU has agreed that the UK can benefit from single-market treatment in electricity and sanitary and phytosanitary (SPS) matters. In these areas, the UK has committed in principle to regulatory alignment and has agreed that the EU Court of Justice will be the ultimate authority for all questions relating to the application of EU law. The UK will also need to be consulted at an early stage on changes in areas where it has committed to align with EU regulation.
Meanwhile, the agreement on fisheries ends the rather arbitrary link between fisheries and energy cooperation that was written into the 2021 EU-UK Brexit deal – the Trade and Cooperation Agreement (TCA). This change opens the door to negotiation of an additional protocol on electricity trade, which allow the UK in effect to rejoin the energy single market.
Further negotiations will be needed on electricity prices and conditions for a level playing field, including state aid and environmental rules beyond those on electricity trading. But the expectation on both sides is that relinking their emissions trading systems — also on the basis of dynamic alignment — will lead to the UK being exempted from the carbon border adjustment mechanism, the EU levy on the carbon content of certain imports, which will enter into force at the beginning of 2026.
The new arrangements on energy create a stable structure for cooperation, and better conditions for investment to facilitate cross-border electricity trade, especially in the North Sea. Although not strictly required, both sides should aim to discuss the design of border carbon measures and reinforce cooperation on carbon diplomacy and green industrial policies.
For full negotiations to start on the trade agreements inked at the summit, the European Commission will need a mandate from EU countries. The parameters for negotiations on the common SPS area and on the linking of emissions trading are already quite detailed, which should facilitate rapid progress.
The summit also saw agreement on some mobility issues, but these need further work: the ‘youth experience scheme’ is rather limited, as is UK participation in the EU Erasmus+ student exchange programme. Use by UK passport holders of e-gates will depend on decisions by individual EU countries. However, the likely result is less hassle for travellers at entry and exit points — and for their pets, thanks to pet passports — a tangible sign of progress for public opinion.
Notwithstanding the progress made, more can be done to improve the trade relationship. The summit outcome explicitly refers to dialogues under the TCA on conditions for entry and temporary stay of businesspeople and on mutual recognition of professional qualifications. More structured regulatory cooperation and additional trade facilitation steps should be developed, such as mutual recognition of conformity assessment.
The work of nailing down further agreements will not be easy for the EU. There will be discomfort about plans to agree on pharmaceuticals, chemicals and other sectors which could be considered UK cherry-picking out of the EU single market. For the UK, political sensitivity around mobility remains high. Nevertheless, the UK and EU are re-establishing the habit of working together. Annual summits, regular high-level dialogues and ministerial-Commissioner meetings will change the working culture over time. That will foster trust and goodwill among allies who, in a world of geopolitical rivalries and trade wars, have rediscovered just how much they have in common.
About the Authors
Ignacio García Bercero is a Non-resident fellow at Bruegel.
Heather Grabbe is a Senior Fellow at Bruegel and a Visiting Professor at University College London and KU Leuven.