Joël Reland / May 2026
Image: Shutterstock
With the next UK-EU summit set, most likely, for this summer, it is time to start asking what topics will be on the agenda.
After all, both sides will want to pull some rabbits out of the hat, by announcing new plans for closer cooperation. Were the summit to simply to be a ‘stocktaking’ exercise, reviewing progress in implementing last year’s Common Understanding, it would send an unfortunate signal that the much-vaunted ‘reset’ in relations is rapidly running out of steam.
That signal would be especially damning for the UK government, which has in recent months pinned its colours with increasing fervour to the EU mast. In early April, the Prime Minister stated that “our long-term national interest requires closer partnership with our allies in Europe and with the European Union” and promised that the next summit will “be more ambitious. Closer economic cooperation. Closer security cooperation.”
The problem for Keir Starmer is that there are precious few options available to him to deliver closer economic cooperation while his red lines of no customs union, single market or free movement remain. Indeed, most of the UK’s key economic asks were accepted by the EU ahead of last year’s summit, and are currently under negotiation.
One exception is a mutual recognition agreement (MRA) on conformity assessments, which the UK proposed last year, but which the Commission dismissed. Could it be one of the major announcements this time around?
It is first worth explaining the problem which an MRA would solve. Any manufactured good sold on the EU market needs to undergo a ‘conformity assessment’ to prove that it meets the necessary regulatory requirements for circulation. This is denoted with a ‘CE’ mark.
The problem for the UK is that its ‘notified bodies’, which carry out conformity assessments, no longer have the right to administer CE marks. They can only administer ‘UKCA’ marks, which denote conformity with UK regulatory standards.
That means any British manufacturer seeking to sell into the EU must obtain a CE mark from an EU-based body – in addition to their UKCA mark – adding administrative time and cost to exports. Indeed, it is manufactured goods which have faced some of the heaviest ‘non-tariff’ barriers to trade from Brexit.
The problem is made worse by the fact that the impact is ‘asymmetrical’: EU firms do not face the same obstacle in the other direction. That is because the Rishi Sunak government opted to keep accepting ‘CE’-marked goods on the GB market in perpetuity. (Goods sold in Northern Ireland require a CE mark under the Windsor Framework.)
There was a clear economic rationale to this: many EU-based firms may find it too burdensome to obtain a UKCA mark purely for the sake of servicing the GB market – risking a major curtailing of EU goods imports and wreaking havoc with British supply chains. But the result is that EU manufacturers face fewer regulatory barriers to the GB market than vice-versa, harming the competitiveness of GB firms.
An MRA would address the problem by allowing UK-based bodies (and EU-based ones) to administer both UKCA and CE marks. That would reduce admin costs for British firms, who could have both assessments done by the same, domestic body.
Which, in turn, explains why the Commission was not keen on the UK’s MRA proposal. It would make UK firms more competitive against EU ones while offering no obvious benefit in return. It would also take business away from EU-based notified bodies currently carrying out conformity assessments for UK firms.
Is there any reason to think, a year after rejecting the MRA proposal, attitudes may have shifted within the Commission? One possible cause for optimism is that the Council has recently authorised the Commission to begin negotiations on an MRA on conformity assessments with South Korea, highlighting the ‘empirical evidence… that MRAs boost exports, increase the number of exporting firms, and expand product portfolios to partner markets’.
But the South Korean case is very different to the UK one. First, there are more obvious benefits to the EU from a Korean MRA. It is a leading market in advanced manufacturing sectors where the EU is urgently seeking to diversify supply chains away from China. The UK is not.
Second, South Korea is – obviously – a far more distant market than the UK, meaning there is very little risk of EU manufacturers getting their goods certified in Korea rather than the EU. Indeed, the EU has MRAs (of varying breadth in terms of product coverage) with a range of more distant markets including Australia, Canada, Japan and New Zealand.
So the Korean model is probably not one the UK can hope to follow. But there is one other way it could hope to break the impasse. There is one country on the EU’s border, and highly integrated into its goods market, which has an MRA on conformity assessments: Switzerland.
The difference with the Swiss deal is that it has harmonised most of its technical regulations with the EU, and as a result Swiss and EU conformity assessments are treated interchangeably for about two thirds of EU-Swiss industrial goods trade (by value). Replicated for the UK, it would allow British goods to serve the EU market with just a UKCA mark, whereas under a Korean-style MRA, a UK good would still need the UKCA and the CE.
This type of deal chimes with the Prime Minister and Chancellor’s stated ambition for greater regulatory alignment with the single market. And there would be a genuine benefit for a range of manufacturing sectors which have faced some of the biggest economic hits from Brexit.
The problem is whether the EU will grant the UK such a concession – as it would go a long way to providing unfettered access to the single market for goods – without demanding free movement of people (or another major compromise) in return.
Almost ten years after negotiations began on the future UK-EU relationship, the problem of cherry picking remains pervasive.
