The reception of the agreement in the House of Commons ranged from cold to hostile, and the vote was delayed by more than a month. Prime Minister May has received a motion of no confidence within her own party, but the EU has refused to accept further changes. The most important elements of the draft agreement are: Complementary certificates of protection are governed by EU law, but are requested and granted as individual national rights. The withdrawal agreement confirms that N. SCS applications expired at the end of the transition period are granted and that they enjoy the same level of protection as existing CPS. These relate in particular to citizens – Sweden and other EU citizens residing in the UK and the British here in Sweden. These provisions mean that their situation will not change much and Swedes, who currently live in the UK, can live, work, study and retire there will continue to be able to live, work, study and retire. The agreement covers all issues that affect citizens in their daily lives, namely social security and living benefits, such as social security, health care and medical care, pensions, unemployment insurance, student scholarships and various forms of family benefits. Recognition of training certificates and other professional qualifications is also covered. During the transitional period, the UK and the EU-27 will seek to conclude the agreement that will strengthen their trade relations after the end of the transition period. On the basis of the revised political declaration, the EU and the United Kingdom appear to be aiming for a comprehensive but “classic” free trade agreement for goods, services and investment. The political statement is thin in detail, but trade in goods will be based on a free trade agreement that will at least guarantee that there will be no tariffs or quotas, as well as some degree of regulatory alignment with the EU. However, as a result of the free trade agreement, customs controls are required, requiring each party to prove that the goods originate from their respective customs territory, in order to obtain duty-free treatment.
This means that the UK and the EU-27 must now agree on detailed rules of origin. This is probably a complex and tedious process. At least companies need to think about the rules of origin they want for different products and start putting pressure on them as soon as the UK and eu start negotiating the new free trade agreement. It is encouraging to note that the scope of the future trade regime appears to encompass services, including financial services and investment (although the agreement is in turn very detailed) and that it provides assurance that the agreement on future relations will offer a liberalisation of trade in services well beyond the obligations of the United Kingdom and the WTO.