As of spring 2025, the United Kingdom has been operating outside the European Union for five years. The initial transition period concluded on December 31, 2020, and subsequent years have seen the full implementation of new trade agreements and regulatory frameworks. However, there are still issues surrounding trade dynamics, regulatory standards, and economic policies, which continue to affect both the UK and Ireland.
Progress to Date
The EU-UK Trade and Cooperation Agreement (TCA), which came into effect in 2021, established the foundation for the post-Brexit relationship. While it provides for zero tariffs and zero quotas on goods that meet the appropriate rules of origin, non-tariff barriers have emerged due to divergent regulatory standards and customs procedures. These changes have necessitated adjustments for businesses engaged in cross-border trade.
The Irish Border Question
The Protocol on Ireland/Northern Ireland, a component of the Withdrawal Agreement, was designed to prevent a hard border on the island of Ireland. It allows Northern Ireland to remain within the EU’s Single Market for goods, resulting in customs checks on goods moving between Great Britain and Northern Ireland. This arrangement has led to political and logistical challenges, with ongoing discussions aimed at streamlining processes and addressing concerns from various stakeholders.
The Windsor Framework, introduced in 2023 as an amendment to the Northern Ireland Protocol, sought to ease trade barriers between Great Britain and Northern Ireland. While it introduced measures to simplify labelling rules and reduce checks for certain goods, recent developments indicate that significant issues remain. The Horticultural Trades Association (HTA) has highlighted that the framework has not provided a viable solution for Northern Ireland consumers wishing to buy plants from online retailers in Great Britain. Currently, every individual parcel still requires an official plant certificate, making it financially and logistically prohibitive for many businesses. As a result, unless businesses are willing to invest in Northern Ireland-based distribution centres, the trade in plants and horticultural products remains heavily restricted. This ongoing challenge underscores the complexities of implementing the Windsor Framework effectively.
Key Considerations for Irish Businesses
Trade Diversification: In response to the complexities of trading with Great Britain, many Irish businesses have sought to diversify their markets. Notably, trade with Northern Ireland has increased, as it remains aligned with EU trade rules, offering a more straightforward trading environment. Additionally, there has been a concerted effort to strengthen trade relationships with other EU member states and international markets.
Regulatory Compliance: The divergence in standards between the UK and the EU has required Irish businesses to stay vigilant and adaptable. Ensuring compliance with both EU and UK regulations is essential for companies that continue to operate in both markets. This includes adjustments in areas such as product certifications, customs documentation, and supply chain logistics.
Economic Impact: The economic ramifications of Brexit are multifaceted. While some sectors have experienced challenges due to increased trade barriers, others have found opportunities in the shifting landscape. For instance, certain industries have benefited from reduced competition in the UK market, while others have capitalized on the demand for alternative supply chains within the EU.
Recent Developments
Trade Statistics: Recent data indicates a €6 billion decline in trade between Great Britain and Ireland in 2024, with total trade decreasing from €38 billion in 2023 to €32 billion in 2024. This decline is attributed to factors such as decreased chemical exports from Ireland to the UK and reduced gas and lubricant exports from the UK to Ireland. Conversely, trade between Ireland and Northern Ireland has seen growth, underscoring the importance of the all-island economy.
Regulatory Changes: As of January 31, 2025, the UK has implemented the third phase of its post-Brexit border controls, introducing additional safety and security declarations for imports from the EU. These measures have implications for Irish exporters, necessitating enhanced customs procedures and compliance efforts.
Political Dynamics: In early 2025, the EU and UK held their inaugural summit under the EU-UK Trade and Cooperation Agreement framework. These high-level discussions aim to address ongoing issues, including trade facilitation, regulatory alignment, and the implementation of the Northern Ireland Protocol. Additionally, the UK government is seeking a new agri-food deal with the EU, which could help reduce checks and controls on plants and food products being sent from Great Britain to Northern Ireland.
Looking Ahead
The full impact of Brexit continues to unfold, with both challenges and opportunities emerging for Irish businesses. Staying informed about regulatory changes, engaging in strategic market diversification, and maintaining robust compliance frameworks are essential steps for businesses navigating the post-Brexit landscape. Ongoing dialogue between the EU and the UK will play a crucial role in shaping the future economic relationship and addressing any arising issues.
As of spring 2025, there are still unresolved issues, particularly regarding trade barriers between Great Britain and Northern Ireland, as highlighted by the ongoing challenges faced by the horticultural sector. The effectiveness of the Windsor Framework remains under scrutiny, and businesses continue to adapt to the evolving regulatory environment while awaiting further policy developments.
For comprehensive and up-to-date information, businesses are encouraged to consult official sources such as the European Commission’s dedicated Brexit page and the Irish government’s Brexit resources.
Sources:
Windsor Framework ‘didn’t solve plant sales problem’ – BBC
Irish figures show €6bn drop in trade with Great Britain – The Guardian
Britain implements delayed third phase of post-Brexit border rules – Reuters
Brexit, Bridges, and Barriers: Where Next for EU-UK Relations? – Carnegie
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