Changes between two versions
What changed between the plenary report and the adopted text
From · plenary report· 11 Nov 2025
on the implementation of the EU-UK Trade and Cooperation Agreement
To · adopted text· 27 Nov 2025
Implementation of the EU-UK Trade and Cooperation Agreement
AI:What changed, in short
Changes the reference to the energy market to electricity market and removes the deadline for negotiations.410 Alters the UK's involvement in SPS decision-making from 'involve' to 'inform' and changes SME Committee to SME contact points.69 Updates the reference to the AI Act decision from Commission proposal to Council Decision with a new date.7 Moves paragraph 216 on Erasmus+ without textual change, and expands carbon capture to include utilisation.111314 The other changes are formal: updated title, headers, and decimal separators.1235
8 changes of substance · 6 formal · 1 of wording only
Written by AI from the two texts only · read the changes before relying on it · 4 Sept 2026 · Report a problem
+5 added · −45 removed · 12 changed paragraphs, packaging included.
Part 5 of 8: Paragraphs 228–287
4 unchanged paragraphs
82. Reiterates, in this respect, the importance of the timely implementation of the Financial Stability Board’s recommendations to enhance the resilience of money market funds (MMF), particularly by removing features that can incentivise runs on banks; calls, therefore, on the Commission to come forward swiftly with a revised MMF proposal, in line with the Financial Stability Board’s recommendations;
83. Takes note of the plans announced by the UK authorities to introduce a lighter regulatory regime for some alternative investment funds; stresses that simplification should not disguise a deregulation agenda; supports simplification measures, provided that the policy objectives remain unaffected; calls, therefore, on the UK authorities to cooperate closely with the EU to ensure that this planned reform does not empty Directive 2011/61/EU on alternative investment fund managers of its substance, in particular around delegation rules;
Intellectual property, public procurement and SMEs
84. Stresses that expanding the range of sectors covered under the TCA’s public procurement chapter would be a meaningful step toward strengthening the level playing field; welcomes the UK’s Procurement Act 2023, in particular the benefits it offers through the greater standardisation and streamlining of procurement processes, and highlights the need to ensure fair access to public procurement; calls on the UK Government and the Commission to improve market access for SMEs by reducing the bureaucratic burden and thus create economic opportunities and provide incentives for taking them; highlights, in this regard, the importance of reducing barriers to cross-border trade for SMEs and of supporting fair competition and economic opportunity in cross-border cooperation;
Change 9
Changed:85. Calls on the Commission to fully implement the SME chapter of the TCA by swiftly establishing the SME Committee,contact points, as provided for under the agreement, ensuring the active participation of organisations representing SMEs; considers that the SME Committee should be tasked with identifying barriers to trade, including to investment, that specifically affect SMEs, and proposing targeted solutions to reduce compliance costs and regulatory burdens, including through the exchange of best practices on SME support schemes and digital company registration; stresses the need for increased flexibility regarding business mobility by broadening the list of activities permitted under short-term visa-free arrangements and reducing the costs and complexities of visa processes for SMEs;
52 unchanged paragraphs
86. Calls, furthermore, for sustainability criteria to be considered in public procurement procedures for specific sectors, where appropriate and proportionate; highlights that measures should be adopted to promote the participation of SMEs, including by simplifying procedures, cutting red tape and ensuring the transparent publication of notices and criteria; notes that the EU and the UK should ensure reciprocal and non-discriminatory access to their respective public procurement markets;
The environment
87. Highlights the increasing risk of EU-UK regulatory divergence in environmental policy, potentially causing economic disruption and undermining environmental objectives; recognises the shared geopolitical challenges and environmental ambitions of the EU and the UK; encourages further strategic cooperation and alignment in the fields of environment, nature conservation and biodiversity;
88. Stresses that the island of Ireland is a single ecological unit; recalls that UK environmental policies impact the environment on the entire island of Ireland and therewith also the achievement of the EU’s environmental protection goals; emphasises the need for increased cooperation on environmental issues through the institutions established under the Good Friday Agreement;
89. Recalls previous calls for closer bilateral collaboration in the area of chemicals regulation; recommends seeking input from the UK Government, and the relevant devolved administrations, in the upcoming revision of the REACH Regulation to promote cooperation and regulatory convergence to facilitate safe and legally predictable cross-border trade in chemicals while maintaining a high level of environmental protection;
90. Welcomes the UK’s recognition of the CE marking regarding eco-design requirements on energy-related products and restrictions on hazardous substances in electrical and electronic equipment; welcomes the fact that this facilitates continued trade between the UK and the EU, while reducing compliance burdens for manufacturers;
91. Calls for a strengthened role for economic and civil society stakeholders in the implementation, monitoring and advisory processes related to trade and sustainable development commitments under the EU-UK TCA in line with the joint statement of the EU and UK DAGs;
92. Recalls the EU’s and the UK’s TCA commitment to maintaining high levels of environmental protection in the areas of waste prevention, waste management and the circular economy; stresses the need to better plan and coordinate in order to adapt their waste management infrastructures and to ensure sufficient capacity for recycling, repair, remanufacturing, waste treatment in accordance with the waste hierarchy, and to promote solutions to reduce and address residual waste streams;
93. Stresses the importance of close EU-UK coordination on the potential inclusion of the waste sector in the EU ETS, in order to ensure regulatory alignment, prevent carbon leakage, and maintain fair competition across borders;
94. Recognises that offshore industrial activities and large-scale sustainable energy projects, such as offshore wind farms, may conflict with the conservation objectives of Natura 2000 sites and marine protected areas, and may also have adverse impacts on seabeds and fishing grounds; underlines the need for a careful balance of environmental goals, sustainable fisheries and renewable energy generation;
95. Notes that in the UK, biodiversity and climate-related schemes are being phased in to replace direct support for farmers; calls for an EU-UK exchange on sustainable agricultural practices that promote biodiversity and climate change mitigation and that ensure food security and supply chain stability;
Climate
96. Notes that the EU and the UK share common ambitions in the field of climate change mitigation; calls for better alignment of climate policies to provide consistency and to avoid conflicting or overlapping measures, which risk undermining the effectiveness of climate action; encourages the exchange of best practices on climate adaptation and preparedness, particularly regarding the health impacts of rising temperatures on vulnerable groups, such as low-income communities;
97. Notes the shared objective set out in the Common Understanding of 19 May 2025 to establish a formal EU-UK carbon market agreement, linking the UK and EU ETS systems; urges both parties to reach a quick conclusion to avoid double carbon costs for companies; echoes the joint position of the Commission and the UK that such an agreement must be clearly and consistently aligned with the rules and principles of the Windsor Framework;
98. Notes that, without timely alignment of the UK and EU ETS, UK exports to the EU will be subject to CBAM as from January 2026; recalls the commitment by the EU and the UK to create the conditions for goods originating in their respective jurisdictions to benefit from mutual exemptions from their respective CBAM systems; stresses that these exemptions should be operational as soon as legally possible to avoid trade disruption;
99. Underlines the need to strengthen the bilateral partnership between the EU and the UK to enhance cooperation on renewable energy development, energy security, and supply chain resilience; calls for stronger EU-UK dialogue and joint research on carbon neutral energy to address shared challenges and drive innovation in reducing carbon emissions;
100. Notes the EU’s and the UK’s intention to continue technical regulatory exchanges on new energy technologies, including carbon capture, utilisation and storage, hydrogen, and biomethane, as outlined in the Common Understanding of 19 May 2025; encourages EU-UK cooperation to improve SME access to green technologies and climate-resilient infrastructure, ensuring that small businesses can effectively contribute to and benefit from the transition towards green technology;
Food safety
101. Welcomes the intention to work towards a comprehensive EU-UK SPS agreement and stresses that such an agreement must maintain high levels of food safety, animal welfare and consumer and environmental protection; highlights the need to coordinate maximum residue levels (MRLs) for pesticides in order to safeguard human health and facilitate agri-food trade; underlines the importance of concluding a veterinary agreement to ensure animal health, prevent zoonotic disease outbreaks and combat antimicrobial resistance, especially in light of recent outbreaks and resulting trade restrictions;
102. Notes the diverging thresholds and restrictions on per- and polyfluoroalkyl substances (PFAS) between the EU and the UK; calls for closer cooperation between the European Food Safety Authority (EFSA), the European Chemicals Agency (ECHA) and the competent UK authorities on PFAS monitoring and risk assessments; recommends enhancing EU-UK scientific dialogue on limits in food and feed in order to safeguard public health while upholding high standards of food safety;
103. Takes note of the Genetic Technology (Precision Breeding) Act, which entered into force in England on 23 March 2023, revising the rules for the release, marketing and risk assessment of plants and animals developed through gene editing and precision breeding; expresses concern about regulatory divergence uncertainty regarding the legal status and movement of such products between Northern Ireland and the EU; stresses the need to prevent improperly labelled products entering the EU food chain;
Public health
Regulatory divergence
104. Recalls that the UK’s withdrawal from the EU marked a fundamental shift in the shared regulatory landscape that previously underpinned cooperation on public health, pharmaceuticals, and medical research; further expresses concern over the uncertainty created by the UK’s Retained EU Law (Revocation and Reform) Act, which abolishes the supremacy of EU law and may result in diverging interpretations of health regulations;
105. Recalls that the UK Medicines and Healthcare products Regulatory Agency (MHRA) now independently authorises medicines in the UK, potentially leading to differences in authorisation timelines, approval criteria, and post-market surveillance; stresses the need to monitor the impact of such divergence on patient access and safety across borders, and calls for structured EU monitoring to assess and respond to such divergences;
106. Applauds the agreement on the reciprocal exchange of information between the EU Drugs Agency and the UK authorities on drug-related risks and threats; calls, to that end, for the possible operational agreement between the EU Agency and the relevant UK authorities to be concluded as soon as possible;
107. Regrets the different approaches to regulating AI in health taken by the UK and the EU, as divergent approaches may risk undermining cross-border interoperability and cooperation in digital medical services; calls for a structured dialogue to explore convergence in standards and compliance mechanisms for digital medical devices and AI-driven diagnostics;
Health cooperation
108. Stresses the need to improve cooperation to safeguard all aspects of public health and enable patients to access care when clinically justified; recommends that this cooperation prioritise treatments for rare and paediatric diseases and complex treatments, where expertise is available in either party; recognises in this regard the success and further potential of European Reference Networks and calls for the establishment of a framework of cooperation with the respective UK reference networks; calls for the intensification of EU-UK regulatory and research cooperation in the field of public health; supports such cooperation through the participation of the UK in the health cluster within the Horizon Europe programme and possible future involvement in HERA-related initiatives;
109. Notes that Brexit-related regulatory divergence and increased importation costs have significantly hindered British patients’ access to life-saving cancer treatments; highlights that the cost of importing new cancer drugs has nearly quadrupled after Brexit; emphasises that these barriers have led to delays and denials of critical treatments, adversely affecting patient outcomes, including those of children with recurrent cancers; recommends that the UK address these challenges to ensure equitable access to essential medicines;
110. Underlines the importance of facilitating mobility, training, and mutual recognition of qualifications and residencies of health professionals between the EU and UK to address workforce shortages and promote the exchange of best practices and expertise; emphasises the strategic opportunity to strengthen EU-UK cooperation in attracting and retaining world-class talent and fostering scientific excellence; welcomes the EU’s initiatives to make Europe a global research hub, including support for relocating researchers and enhancing career prospects; encourages the development of joint EU-UK programmes and mobility schemes to support health professionals and researchers alike, ensuring Europe remains a leader in medical innovation and scientific freedom;
111. Notes that while the EU-UK TCA includes a Protocol on Social Security Coordination, which retain mechanisms for reciprocal healthcare such as the European Health Insurance Card, the end of the UK’s participation in the Cross-Border Healthcare Directive was not followed up with a comparable arrangement; observes that this has had an uneven impact, particularly in Northern Ireland, where over 1 000 patients per year previously had care in the EU reimbursed under the Directive;
112. Recommends the establishment of a dedicated EU-UK working group on pharmaceuticals and medical devices to facilitate ongoing dialogue, address regulatory divergences and promote alignment in areas such as clinical trials, pharmacovigilance, medical device certification and illicit trade in healthcare-related products;
113. Acknowledges the limited provisions under the TCA for cooperation on health security, and regrets that the UK no longer participates in the EU’s Health Security Committee or the European Centre for Disease Prevention and Control (ECDC); warns that this limits early warning capabilities and coordinated responses to cross-border health threats such as pandemics and antimicrobial resistance; recommends the establishment of a formal and regular dialogue between EU and UK public health authorities and public health institutions to strengthen trust and capacity in emergency preparedness, pandemic response, and cross-border epidemiological surveillance;
114. Welcomes the recent adoption of a Common Understanding on a renewed agenda for EU-UK cooperation through which the Commission and the UK will explore the potential to enable exchange and cooperation on health security, including the detection of, preparedness for, and response to emerging health threats, to prevent and mitigate against future pandemics and health crises, including within the framework of the TCA health security provisions to maximise cooperation on health security;
115. Urges the Commission to suspend cooperation, in line with the provisions of the TCA, in cases where UK regulatory standards for medicine quality, pharmacovigilance or manufacturing are no longer deemed equivalent to EU standards, as outlined in Directive 2001/83/EC;
116. Points out the unresolved situation with regard to the rental agreement for the former premises of the European Medicines Agency following its move to Amsterdam and calls for the issue to be raised with the UK;
Supply chains
117. Underlines the increased complexity of cross-border supply chains for medicines post-Brexit, particularly for products that previously moved freely between the EU and the UK; regrets that customs checks and regulatory processes have caused delays, shortages and increased costs, affecting medicine availability in the UK, particularly in Northern Ireland, and in smaller Member States that have historically relied on UK-based supply chains, such as Malta, Cyprus and Ireland;
118. Stresses that the possible extension of derogations from certain obligations concerning certain medicinal products for human use made available in the UK in respect of Northern Ireland, as well as in Cyprus, Ireland and Malta set under Directive (EU) 2022/642 amending Directives 2001/20/EC and 2001/83/EC must be based on evidence of ongoing necessity and risk of patient harm in affected Member States, and not be for administrative convenience;
119. Urges the EU and the UK to explore cooperative mechanisms, such as a mutual recognition agreement on good manufacturing practice based on equivalent standards to ensure continued access to, in particular, critical medicines, counter shortages and remove barriers related to batch testing, pharmacovigilance data sharing, and supply logistics to minimise disruptions to patient care and ensure patient safety;
International cooperation and development
120. Stresses the imperative for both parties to jointly reinforce their engagement and cooperation in global health governance and international development programmes, including but not limited to the World Health Organization; underlines the importance of coordinated action in this regard to enable a stronger, more equitable, and more effective international response to cross-border health emergencies;
Consumer protection
121. Stresses that consumers in the EU and the UK face several risks stemming from unsafe and illicit products, and from manipulative selling techniques online; highlights, in this regard, the related challenges arising from e-commerce to which consumers are exposed; considers that closer cooperation and the exchange of important information between the EU’s and the UK’s consumer enforcement bodies are vital to tackling these challenges;
122. Stresses that EU-UK cooperation must uphold a high level of consumer protection, with a particular focus on product safety, e-commerce and cross-border digital services; calls for enhanced collaboration to tackle the presence of unsafe products and unfair commercial practices; underlines the need for regulatory convergence on product safety and digital consumer rights to ensure a consistent and high level of consumer protection, thereby supporting consumer confidence and trust in cross-border commerce; demands that EU-UK cooperation commit the two parties to dialogue and information exchange in areas of shared concern, including product safety, digital consumer rights and unfair commercial practices; highlights that the EU and the UK must cooperate to prevent regulatory divergence that would negatively affect consumer confidence or cross-border trade;
123. Regrets that the TCA does not include a cooperation arrangement related to the enforcement of consumer protection laws, and calls on the Commission to explore the possibility of establishing an arrangement between the EU Consumer Protection Cooperation Network and the UK’s Competition and Markets Authority; stresses that such an arrangement would enable authorities to intervene more efficiently by exchanging information related to investigations and exploring joint actions; highlights that such cooperation should be considered under the Consumer Protection Cooperation Regulation, as this enables cooperation with non-EU countries to protect consumers’ interests; welcomes the agreement to resume discussions on regular information exchange between the EU’s Safety Gate system and the UK’s market surveillance and product safety database, in line with Article 96(4) of the TCA;
124. Calls for the EU to facilitate the accession of the UK to the Lugano Convention to enable mutual recognition and enforcement of judgments between the UK and the Member States;
125. Welcomes the administrative arrangement signed on 30 April 2024 between the Commission and Ofcom, the UK’s regulator for broadcasting, telecommunications and postal services, with the aim of overseeing how large online platforms assess and manage risks, including the protection of minors, age-appropriate design, and platform transparency; expresses the hope that this marks the beginning of closer cooperation in addressing these and other common challenges;
Energy
126. Highlights, against the backdrop of Russia’s war of aggression against Ukraine and in the context of volatile global energy markets, the importance of strengthening cooperation on energy and on security of supply between the EU and the UK; encourages the EU and the UK to work together to end Russian energy dependence by halting imports of all Russian fossil fuels at the earliest opportunity, including oil, gas, liquefied natural gas (LNG), nuclear fuels, and other nuclear materials; notes that both the EU and the UK are continuing to make progress towards their shared goal of ending all energy ties with Russia; welcomes the establishment of the new EU-UK Working Group on Security of Supply under the TCA, as recommended by the Partnership Council of 17 March 2024 and later implemented by the Specialised Committee on Energy; hopes that the new EU-UK Working Group on Security of Supply can meet regularly and develop concrete solutions and joint actions in this crucial area of bilateral cooperation;
127. Emphasises the importance of integration between EU and UK energy markets, which can improve security of supply, stimulate clean energy production, and lower energy costs for both parties; believes that high levels of physical interconnection capacity need to be complemented by more integrated wholesale energy markets that can facilitate energy security and trading between the EU and the UK; finds that, despite closer cooperation between regulators and transmission system operators, little progress has been made in terms of developing the new electricity trading arrangements envisaged under Article 312 of the TCA; recalls that the UK no longer avails of EU single market tools for market coupling for electricity trading, such as EU Single Day-Ahead Coupling, leading to inefficient trading over interconnectors that raises wholesale costs and ultimately feeds through to higher consumer bills, as well as hindering investment in multipurpose interconnectors;
Change 10
Changed:128. Welcomes the recent EU and UK commitment and political agreement to extend EU-UK energy cooperation on a continuous basis and to explore the parameters for the UK’s potential participation in the internal electricity market, including dynamic alignment and contributions to the costs associated with this policy area as set out in the EU-UK Common Understanding; calls for immediate negotiations on market alignment and for their timely conclusion, and emphasises the need for swift and decisive progress; highlights that such participation would lower energy prices and benefit consumers and businesses; stresses that such a deal would have to be found before 30 June 2026, when the current arrangements expire; stresses that, especially in the light of the changing geopolitical context and global trade uncertainty, areas of clear mutual interest include clean energy cooperation in the North Seas, linking the respective EU and UK emissions trading systems to avoid friction from their respective CBAM, improving electricity trading arrangements and closer coordination in infrastructure planning, thereby enhancing energy security and industrial competitiveness across Europe; calls for both parties to cooperate closely to ensure that a workable framework can be established in a timely manner, so as to limit legal uncertainty; calls for concrete joint efforts by the EU and the UK towards greater cooperation on nuclear energy, a low-carbon and affordable source of electricity, which is vital to reach climate neutrality and maintain the competitiveness of European industries; recalls that structured cooperation between the EU and the UK in areas such as electricity interconnectors and offshore renewable infrastructure may intersect with EU funding programmes, including regional and energy initiatives; emphasises that any UK participation in such frameworks requires appropriate governance, compliance with EU rules, and appropriate financial contributions reflecting the EU’s investment; calls on the Commission to provide Parliament with full information on any financial contribution to be provided by the UK in these areas;
129. Welcomes the joint position of the Commission and the UK, as expressed at the recent EU-UK Summit, that linking carbon markets would help address trade-related and level playing field concerns, in accordance with Article 392(6) of the TCA, and would exempt UK-based firms from the CBAM, reduce trade frictions and foster alignment on carbon pricing, thereby reinforcing shared decarbonisation objectives and contributing to the achievement of climate neutrality targets;
130. Acknowledges that the operation of different CBAMs in the EU and in the UK could lead to additional unwanted costs for future cross-border trade in renewable electricity, with negative impacts for industries and households, and particular risks for the integrity of the Single Electricity Market in the island of Ireland; believes that the most efficient and straightforward solution would be for the UK to link directly to the EU Emissions Trading System (ETS), as proposed in the Common Understanding; maintains that full ETS linkage should avoid unwanted costs and remove unnecessary policy barriers to cooperation, especially in the North Seas; calls, nevertheless, for interim measures, if necessary, to ensure that EU and UK CBAMs do not impose any additional burdens on cross-border electricity trade as of 2026, when negotiations on electricity market participation and ETS linkage might still be ongoing; highlights that any participation of the UK in mechanisms or systems related to the EU ETS must be accompanied by a fair and proportionate financial contribution covering the EU’s administrative and programme-related costs; insists that EU financial and climate interests must be fully safeguarded in any future arrangements;