A free trade agreement between the United States and United Kingdom could be coming, but it is likely to take a while.
Both President Trump and British Prime Minister Theresa May have expressed enthusiasm for bilateral trade talks, but plenty of obstacles stand in their way.
Still, it is possible the two countries could use the intervening time to lay the groundwork for trade talks.
Regulatory issues could pose another obstacle, as the two countries would have to agree to rules on food safety and investor-state settlement disputes. The latter issue has sparked fears in England that a deal with the United States could lead to the dismantling of their government healthcare system.
“And that’s only two of a significant number of hot-button issues that would have to be resolved,” said William Reinsch, a trade expert at the Stimson Center.
British media outlets are already expressing anxiety over the possibility that a U.S.-U.K. trade deal would be contingent on London accepting food safety rules that would allow for the import of U.S. beef with growth hormones, chlorine-washed chicken and genetically modified foods that are now banned.
“People who think it will be easy are really saying [a U.S.-U.K. deal] will be easier than TTIP, which is true, but it will still be difficult,” Reinsch said.
The Transatlantic Trade and Investment Partnership (TTIP) is an agreement that the Obama administration was trying to complete with the 28-member European Union. Talks stalled last year, particularly over how to work out differences on regulations.
Talks finalizing the exit from the EU — or Brexit — will also affect the parameters of a possible U.S.-U.K. trade deal.
“First and foremost, what happens with ‘Brexit’ will determine free trade negotiations with the United States,” said Chad Bown, a senior fellow at the Peterson Institute for International Economics.
The biggest question is whether Britain will remain linked to EU regulatory standards or will set up its own framework and separate set of rules.
If Britain is tasked with building a regulatory framework from scratch, it “will take a tremendous amount of time,” Bown said.
The U.S. and the U.K. trade in many complex products such as automobiles, aircrafts, electronics, oil, pharmaceuticals and others, which could get caught up in disputes over regulatory harmony.
Simon Lester, a trade analyst at the Cato Institute, suggested treading lightly on regulatory barriers to speed trade talks along.
Instead of trying to harmonize U.S. and U.K. regulations, trade officials should select a few prominent sectors — such as automobiles, pharmaceuticals or financial services — to address now, and then build a framework to negotiate other areas down the road, he said.
He said the two nations could exclude issues like labor protections, special dispute procedures for foreign investors and other topics that could be covered by the World Trade Organization to avoid the pitfalls of other trade agreements.
“There will not be the sensitivities that arise in relation to trade with certain developing countries, and some of the more controversial trade agreement provisions may therefore not be necessary,” Lester is expected to tell the House Foreign Relations Committee on Wednesday.
“It would be disappointing to have the U.S-U.K. trade negotiations turn into a three- to five-year slog, bogged down by disagreements over governance rules, as we have seen with other trade negotiations,” he will say.
Myron Brilliant, executive vice president and head of international affairs for the U.S. Chamber of Commerce, said the two countries could use trade talks to improve inefficiencies in areas such as digital trade, biotechnology, pharmaceuticals and advanced manufacturing.
“There are a lot of opportunities for exploring cooperation and ensuring that we take full advantage of that,” Brilliant said.
Tariff reductions are still very much in the mix. Lester suggests eliminating as many as politically possible within a short timeframe, with the goal of eventually reaching zero on products that cross the Atlantic.
But Bown said that while the two nations could sign a deal on tariffs, it is “not meaningful because it’s not tackling really complicated nontariff barriers.”
“There is a lot of trade between the countries and a lot of really good reasons to want to do a deal, but it’s hard to imagine anything of substance any time soon,” he said.
Lester pointed out that the U.K. has limited resources in trade negotiating after being part of the EU for more than 40 years. The European Commission led trade talks around the world for members of the bloc.
He suspects London will have to hire hundreds of trade experts and set up trade institutions from scratch, as well as decide on its own framework for trade agreements, which could slow down efforts to negotiate new deals.
“So how does a trade negotiation unfold in that context?” Lester said.
“It could be very different than what we have seen before. Or it could end up being pretty normal.”
