Written submission from Hleb Buziuk (EUT0005)
Written evidence submitted by Hleb Buziuk to the Business and Trade Committee inquiry, UK trade with the EU.
● I submit as an independent public policy and governance researcher, not on behalf of a business, trade association or political organisation. The inquiry asks about the reset, regulatory alignment, future frameworks, economic security and stakeholder engagement.
● Key message 1: the reset is credible as a work programme, but not yet as a trader-visible outcome. The test is whether SPS, ETS, mobility and border files become fewer practical steps for firms, not only further communiqués [2][3][4].
● Key message 2: targeted economic benefits are plausible without rejoining the single market or customs union, but they are likely to be concentrated in agri-food, carbon-exposed goods, border-facing SMEs and selected services rather than spread evenly across the economy [2][3][5][6][7].
● Key message 3: cross-government success should be judged by named owners, simpler processes and clearer guidance. Announcements alone will not reduce duplicate data entry, late guidance or uncertainty for smaller firms [4][5][8][9].
Key findings
● SPS should be judged as a trader-journey reform. A legal agreement that does not remove repeated certificates, checks or data entries may under-deliver for the firms most exposed to border friction [2][3][4].
● Services need named deliverables. Dedicated dialogues on temporary business travel and professional qualifications are welcome, but firms need sector-by-sector outcomes, not only open-ended discussion [2][8][10].
● Alignment choices should be treated as institutional packages. Sectoral access may bring rule uptake, decision-shaping without a vote, dispute-resolution design and financial contributions; these should be explicit before commitments are made [2][11].
● Experience signal: recent business survey evidence reports paperwork, low awareness of incoming rule changes and mobility friction; this is directional evidence from respondents, not a prevalence measure [8][9].
Recommendations
● By autumn 2026, the Department for Business and Trade and Cabinet Office should publish one cross-government implementation grid for SPS, ETS, electricity, mobility and border digitalisation.
● For any alignment proposal, Government should publish the sector test: duplicated compliance cost, SME exposure, EU market dependence, pace of rule change, enforcement capacity, scrutiny route and interaction with other FTAs.
● The Committee should ask for before-and-after process maps for agri-food movements and carbon-reporting obligations, with three trader-facing metrics.
● Services should have a first-round deliverables list covering temporary business travel and professional qualifications.
What is new vs official sources
● The key near-term opportunity is not a grand institutional model; it is whether a small set of technical files become usable trader processes [2][3][4].
● ETS linkage is a timing and transition problem as well as an end-state negotiation: interim costs may arrive before linkage is operational [3][12].
● Gap + test: public trade baselines exist, but public assumptions for sector and regional valuation of the current reset package are still too thin for precise benefit claims. Government should publish assumptions, not only conclusions [3][6][14].
Section 7 sets proportionate evidence strengthening, and section 9 gives hearing questions.
Hleb Buziuk is an independent public policy and governance researcher. This submission is neutral, evidence-led and focused on implementation. It does not argue for a party-political position or for one sectoral interest. It does not include personal data or individual cases.
This submission separates three kinds of evidence. Official texts and statistics are used for status, scope and baseline exposure. Academic and analytical work is used for causal reasoning and what may work for whom. Business surveys and stakeholder evidence are used for reported friction, design issues and implementation risks.
Stakeholder evidence is testimony. It is useful for understanding burdens and design failures, but it is not treated as prevalence or outcome evidence unless a denominator is published. Survey findings are described as respondent signals, not as claims about all businesses.
No headline claim relies only on a committee report narrative. Where business evidence is used, it is paired where possible with official texts, statistics, audit evidence or analytical work.
The reset sits in a UK-wide policy space. Trade, border systems, carbon pricing, professional mobility, energy and defence involve several departments and some devolved or GB-NI interfaces. That matters because the same agreement can have different delivery burdens across territories, supply chains and firm sizes [2][4][14]. The Committee should therefore test the reset as a delivery programme, not just as a diplomatic framework.
The Common Understanding created a broad programme covering SPS, ETS, electricity, mobility, security and other cooperation. The Council mandate on SPS and ETS moved two major economic files into formal negotiation [2][3]. The delivery risk is that a broad reset becomes a set of loosely connected announcements. The NAO’s border work shows that complex border change requires realistic timetables, integrated planning and attention to user burden [4]. The Trade Strategy also points toward cross-government trade delivery, digital trade and resilience [5].
● The design parameter is a single implementation grid: owner, statutory step, EU dependency, devolved interface, business guidance date and user metric.
● Dependencies include EU mandates, UK legislative routes, operational readiness and business guidance.
● Failure modes include high-level agreement without process change, late guidance, and unclear departmental ownership.
● Equity risk: larger firms can absorb uncertainty better than smaller traders, which can turn a neutral process delay into a competitive burden [7][8].
SPS appears to be one of the clearest near-term files where a deal could reduce visible trader friction. The Common Understanding envisages most relevant movements between Great Britain and the EU taking place without the certificates or controls currently required within scope, and the Council mandate describes burden reduction through alignment [2][3]. That benefit depends on scope, exceptions, database access, GB-NI articulation and whether border data are reused rather than re-keyed.
● Border reform should be measured by whether it delivers fewer documents, fewer duplicate data fields, lower error rates and more predictable release times [4][5].
● Business survey evidence reports customs procedures, documentation and low awareness of upcoming changes as continuing barriers. These are respondent signals, not prevalence evidence for all firms [8][9].
● Firm-level evidence indicates that smaller firms were more exposed to trade-cost increases after the change in UK-EU trading terms, so distribution matters [7].
● Trade-off: dynamic alignment may reduce checks in selected sectors, but it also requires transparent scrutiny, exception rules and future rule-tracking capacity [2][11].
Comparator models should be used as tests, not slogans. EEA participation is built around the four freedoms and broad single-market rule incorporation, while the current reset appears more file-by-file [2][11]. A customs union, single-market return, sectoral single markets or greater divergence would each alter obligations, mobility, budget, dispute resolution and compatibility with other FTAs.
● The most practical Committee test is: what benefit is bought, what obligation is accepted, who scrutinises later rule change, and how fast can the arrangement be implemented?
● Dynamic alignment should not be described only as a “lever”. It needs scope, update process, parliamentary scrutiny, derogation criteria, review points and FTA compatibility checks [2][11].
● Trade-off: broad frameworks may offer larger access gains, but also bring bigger political and institutional conditions. Narrower files may be quicker but risk leaving services and cross-border supply chains under-addressed.
● Equity risk: firms and regulators with less spare capacity may struggle most with frequent rule tracking.
The security and defence partnership provides a structured framework for dialogue and cooperation across defence industry, military mobility, cyber, resilience and support for Ukraine [13]. The Trade Strategy also frames trade as part of resilience and economic security [5]. These gains should not be overstated as short-term trade growth. Their practical relevance is more likely to lie in supply-chain resilience, procurement clarity, critical infrastructure cooperation and better preparedness for economic coercion risks.
● The design parameter is route selection: what belongs at EU level, what belongs bilaterally with member states, and what belongs through NATO partners.
● Dependencies include procurement rules, industrial-base capacity, value-for-money tests and safeguards for sensitive capability.
● Failure mode: broad security language without industrial delivery routes or measurable procurement access.
● Equity risk: defence and security opportunities can concentrate in firms already able to navigate complex procurement.
Business readiness is not only a communications issue. It is a delivery condition. BCC survey evidence reports low awareness of some incoming trade changes and continuing concerns about paperwork, mobility and professional qualifications [8][9]. Deloitte’s written evidence to the inquiry also emphasises that the details of how agreements will work remain under live negotiation, while businesses need clarity and predictability [10].
● Services should be protected from being crowded out by a goods-heavy reset. Temporary business travel, sponsorship requirements and professional qualifications need named sectors, named authorities and first-round milestones [2][10].
● Guidance should be plain English, timed before implementation and tested with smaller firms and intermediaries.
● The Committee should distinguish engagement events from useful engagement: whether firms know what will change, by when, and what action they must take.
● Equity risk: smaller firms, new exporters and firms outside large trade-association networks may be least able to track policy change.
Committee levers
Delivery actions
Trade-offs and safeguards
● Alignment form: use static alignment, dynamic alignment, mutual recognition or flexibility only after stating the market-access benefit, regulatory obligation, scrutiny route and implementation cost.
● Sequencing: prioritise files with visible 18-month delivery potential, while keeping broader frameworks under comparative review.
● Scrutiny: where future EU rule change is relevant, publish the UK scrutiny route before final commitment.
● Burden: monitor who bears ongoing compliance work, especially SMEs and intermediaries.
Indicators
● Agri-food trader burden: documents required, duplicated data fields, release-time variability and groupage viability [2][3][4].
● ETS and CBAM exposure: sectors covered, reporting obligations, cost timing and any interim burden before linkage [3][12].
● Business readiness: awareness of rule changes, use of digital border tools and unresolved mobility or professional-qualification barriers [8][9][10].
Learning questions
● Learning question: what are Government’s sector and regional impact assumptions for the SPS, ETS and electricity package?
● Learning question: what baseline and target metrics will be used for border data reuse, trader onboarding and error reduction?
● Learning question: which professions and member states account for the most material mobility and professional-qualification friction?
● Learning question: what is the departmental ownership and parliamentary scrutiny route for any future dynamic alignment decision?
The proposed policy logic is as follows: clearer 18-month priorities would give the Committee a basis for tracking visible files; SPS plus GB-NI articulation should reduce border steps [2][3][4]; ETS linkage could reduce some CBAM-related uncertainty [3][12]; border data reuse should reduce duplicate entries [4][5]; mobility and professional-qualification deliverables should support services trade [2][10]; cross-government ownership should improve readiness [5][8]; and defence or economic-security cooperation should strengthen resilience [5][13].
Design parameters to specify are: SPS scope and exceptions; ETS and CBAM transition rules; border data reuse and trader onboarding; dynamic alignment governance and scrutiny; and mobility or professional-qualification coverage.
Key dependencies are EU mandates, UK legislative routes, devolved and GB-NI interfaces, regulator capacity, digital system readiness and timely guidance.
Ethics guardrails: avoid individual cases, do not overstate survey testimony, and describe firm burden without stigmatising smaller businesses.
For ministers
For officials and regulators
For business witnesses
References
[2] UK Government (2025) UK-EU Summit: Common Understanding. https://www.gov.uk/government/publications/ukeu-summit-key-documentation/uk-eu-summit-common-understanding-html
[3] Council of the European Union (2025) EU-UK relations: Council greenlights negotiations on agri-food deal and linking emissions trading systems. https://www.consilium.europa.eu/en/press/press-releases/2025/11/13/eu-uk-relations-council-greenlights-negotiations-on-agri-food-deal-and-linking-emissions-trading-systems/
[4] National Audit Office (2024) The UK border: Implementing an effective trade border. https://www.nao.org.uk/reports/the-uk-border-implementing-an-effective-trade-border/
[5] Department for Business and Trade (2025) UK Trade Strategy. https://www.gov.uk/government/publications/uk-trade-strategy/the-uks-trade-strategy
[6] Office for National Statistics (2026) UK total trade: all countries, seasonally adjusted. https://www.ons.gov.uk/economy/nationalaccounts/balanceofpayments/datasets/uktotaltradeallcountriesseasonallyadjusted
[7] Centre for Economic Performance, LSE (2024) Deep integration and trade: UK firms in the wake of Brexit. https://cep.lse.ac.uk/_new/publications/abstract.asp?index=11304
[8] British Chambers of Commerce (2024) Brexit at Four: Trade Reset Must Deliver. https://www.britishchambers.org.uk/news/2024/12/brexit-at-four-trade-reset-must-deliver/
[9] British Chambers of Commerce (2024) Customs Procedures Still Holding Back UK Exports. https://www.britishchambers.org.uk/news/2024/11/customs-procedures-still-holding-back-uk-exports/
[10] Deloitte (n.d.) Written submission from Deloitte (UKT0046). https://committees.parliament.uk/writtenevidence/147892/html/
[11] European Free Trade Association (n.d.) Q&A about the EEA Agreement. https://www.efta.int/eea-relations-eu/qa-about-eea-agreement
[12] UK in a Changing Europe (2025) Linking emissions trading schemes: key challenges. https://media.ukandeu.ac.uk/wp-content/uploads/2025/09/UKICE-ETS-insight.pdf
[13] UK Government (2025) Security and defence partnership between the European Union and the United Kingdom. https://www.gov.uk/government/publications/uk-eu-security-and-defence-partnership/security-and-defence-partnership-between-the-european-union-and-the-united-kingdom-of-great-britain-and-northern-ireland
[14] Office for National Statistics (2025) International trade in UK nations, regions and cities: 2023. https://www.ons.gov.uk/businessindustryandtrade/internationaltrade/bulletins/internationaltradeinuknationsregionsandcities/2023
Annex A. Claim checks
Claim | Anchors and evidence type | Limits and conditions | Dependency | Strengthening evidence |
SPS is a clear near-term goods opportunity. | [2][3], official texts | Benefit depends on scope, exceptions and operating model. | Border readiness and GB-NI articulation. | Before-and-after process map. |
Border digitisation matters only if it removes duplicate work. | [4][5], audit and strategy | Does not prove all firms face the same burden. | Data reuse and trader onboarding. | Error-rate and release-time metrics. |
ETS linkage is a transition issue as well as an agreement. | [3][12], official text and analysis | Strongest for exposed sectors, not whole economy. | Timing of linkage and exemption rules. | Interim cost and reporting assessment. |
Services need named deliverables. | [2][10], official text and stakeholder evidence | Stakeholder evidence is interest-bearing and sector-specific. | Sector and profession prioritisation. | List of first-round sectors and dates. |