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Official-Sensitive: Great Britain is practically standing on her knees working on a trade agreement with the US

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I suspect that this publication will make some noise, so that’s why you probably don’t have much time to look through the internal secret documents that contain specific details of the upcoming FTA between the UK and the USA.

Three years, six bilateral meetings of the UK-US Trade and Investment Working Group (TIWG), 12 chapter-level discussions, 451 pages of reports. A detailed analysis and processing of such an amount of material will require a lot of time, knowledge and definitely more than one pair of eyes, so I’m dumping this here.


The fact that the British Parliament was suspended by Her Majesty for five weeks at the request of the Prime Minister right before the next deadline makes this publication the last attempt to effectively counter the scenario of Britain leaving the EU without making a deal with Brussels.
From now on, it is no longer a secret who is pushing the UK government to no-deal Brexit:

USTR were also clear that the UK-EU situation would be determinative: there would be all to play for in a No Deal situation but UK commitment to the Customs Union and Single Market would make a UK-U.S. FTA a non-starter.

Document 6, page 2
Full document

The most notable step towards the signing of the agreement, as expected, will be the UK rejection of EU sanitary and phytosanitary standards, which means that chlorinated chicken from American farmers can get to Britain by Christmas:

• The US are very concerned at the contents of the Chequers statement. They were “deflated” and see harmonisation with the EU SPS regime as the “worst-case scenario” for a UK-US FTA.

• The US see SPS as the biggest ‘sticking point’ on risk (what they see as the ‘global norm’) vs the EU’s hazard-based approach on mainly pesticides, veterinary drugs and pathogen reduction treatments.

• On transparency and equivalence the UK not remaining in the EU but subject to the EU rules will be more of an issue for the US than the UK just being in the EU, as we can no longer be a back door for US products and no longer influence EU rules. An example the US shared would be if they (the US) lodged a complaint against the UK under the terms of the FTA, the UK would not have the autonomy to address the said complaint under the Chequers proposal.

Document 4, page 25
Full document

British citizens will inevitably face a sharp decline in the quality of imported food products. The United States is strongly determined to expand markets thus placing UK in ‘take it or leave it’ position:

[Wine Agreement] The most challenging element was the discussion on traditional terms. The US do not want to accept our continuity approach, even for a no deal text. They described the position, whilst referring to the issues with the EU, as “the disease spreading”. This may require political escalation. The UK will send over the latest Wine Agreement text following this call. We are about 90% agreed.

Document 5, page 51
Full document

Cornering the victim, the US is clearly not going to limit itself to ensuring its own interests solely within the UK:

Another priority for the Administration was dealing with common global problems, particularly China. The US had commenced an investigation on overcapacity of steel and aluminium vis-a-vis China, the outcome of which would be a standard through which to protect other industry (semiconductors, solar panels etc.). An important element of positive agendas with the UK and the EU would be shared action on China. On the Trade in Service Agreement (TISA) the Administration recognised the potential to come back to table, but no decision had been made to date.

Document 2, page 7
Full document

After reading the documents, there should be no doubt who is speaking in these negotiations from a position of strength and who is on the receiving end. The language and the tone in which negotiations are held sometimes give the impression that the second side of the process is not Great Britain, but a third world country:

e) The US is willing to offer the UK 2 spots of the 50 in the Central California tour for ACE 10
f) Anyone who attends must be able to provide something. “Move the needle or you don’t get to come back”

Document 3, page 15
Full document

What can we say about respect for the citizens of the Kingdom if in the new trading space they still have to prove their competence?

…in TTIP the US repeatedly said that they would like to recognise the UK’s professions but they could not trust standards in all EU countries.

Document 3, page 22
Full document

The United Kingdom will also be asked to reconsider their policy towards legal protection of personal data. Cooperation is out of the question while GDPR stands in the way of American corporations like Facebook and Google.

RT also explained that the US has had some specific concerns with how GDPR is being implemented. The EU has acknowledged GDPR has a global impact and other countries are going to have opinions.
RT stated that the US will want to engage with the UK on the best approach around its future international transfers model, but understands there are still internal discussions in the UK on this. The US are proponents of APEC-CBPR model which is based around individual companies rather than whole legal systems [...] The UK and US could work together on an inclusive system [...] A mapping exercise took place mapping CBPR against the EU corporate rules system, and it was discovered that while there were differences, they were not as extensive as one would presume. Some countries have used the same set of information to get both approvals under both systems [...]
It would be useful to understand the impact on companies of unintended consequences of bringing GDPR in to play on hybrid data.

Document 4, page 23
Full document

Based on the content of these documents, we can now imagine what a terrible price Britain will have to pay to conclude a free trade agreement with the United States – from betraying partners and the interests of own citizens to betraying her national policies.


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