The progress of the UK’s negotiations on EU withdrawal (June to September 2018) Contents

2Withdrawal Agreement and remaining issues


12.Chapters in the draft Withdrawal Agreement on citizens’ rights, the financial settlement, and a 21-month transition/implementation period have all been agreed in principle.22 The parts that have not been agreed include the European Commission’s mechanism for maintaining a frictionless border on the island of Ireland, the governance arrangements for the Withdrawal Agreement, and a range of other separation issues, including data protection, geographical indications23 and ongoing police and judicial cooperation in criminal matters, amongst other matters.24 If negotiators fail to finalise the Withdrawal Agreement, the chapters that have been agreed will fall and the UK will withdraw from the European Union without an overarching deal. The Government has started to publish technical notices in tranches that advise businesses, individuals and public institutions on what to do if the UK leaves the European Union without a Withdrawal Agreement.25

The backstop

13.The Government and the European Union have agreed that a ‘backstop’ option is necessary to guarantee the continuation of an open border for trade on the island of Ireland. It would enter into force if no other solution is found that would avoid a “hard border, including any physical infrastructure or related checks and controls”,26 or if a solution is not ready to be implemented by the end of the transition/implementation period in December 2020.27 The need for a backstop was agreed by both sides in the December 2017 Joint Report and is therefore fundamental to any Withdrawal Agreement.28 On 30 April 2018, Michel Barnier said, “To be clear: without a backstop, there can be no Withdrawal Agreement. This is an EU issue, not only an Irish issue.”29 However, the two sides have different and not easily reconcilable views on the scope of the backstop.

14.The European Commission has proposed a backstop that would apply to Northern Ireland only. However, this would entail checks on goods moving between Great Britain and Northern Ireland if Great Britain was part of a separate customs regime from Northern Ireland; an outcome that the Government and this Committee has rejected explicitly and consistently. On 28 February 2018, the European Commission published its backstop proposal as a Protocol in the draft Withdrawal Agreement.30 It described a “common regulatory area”, which constitutes “an area without internal borders in which the free movement of goods is ensured and North-South cooperation protected”. Under this proposal, Northern Ireland would be considered “part of the customs territory” of the European Union and would be required to follow European Union law across a range of regulatory areas, including goods, agriculture and fisheries, the Single Electricity Market, certain environmental standards and state aid.

15.The Prime Minister rejected the European Commission’s proposal because it would “undermine the UK common market and threaten the constitutional integrity of the UK by creating a customs and regulatory border down the Irish Sea”. She told the House of Commons that “no UK Prime Minister could ever agree to it”.31 On 20 July 2018, the Prime Minister described the European Commission’s proposals as “unworkable” and called for it to “evolve” its position to break the impasse.32 In our May 2018 report on the progress of the negotiations, we agreed with the Government that the European Commission’s proposal would undermine the constitutional integrity of the United Kingdom “by effectively drawing an economic border in the Irish Sea”. We supported the Government’s rejection of this because “whatever solution is reached to resolve issues around the Northern Ireland/Republic of Ireland land border it must involve the whole of the UK.”33

16.The Government believes that the backstop should apply to the whole of the UK. On 7 June 2018, the Government published its proposal for the backstop option.34 It described a Temporary Customs Arrangement, under which the whole of the UK would remain part of the EU’s customs territory for “a time limited period”. It also stated that an alternative option would be to create a new joint customs territory comprising the customs territories of the UK and the European Union, but it did not set out what this would entail. The Government’s proposal explained how it could eliminate checks that relate to VAT, excise and tariffs, and it also set out the extent to which the UK could exercise an independent trade policy under its backstop proposal. While the European Commission has said that it has “no objection in principle” to a UK-wide backstop, it has “doubts that this can be done without putting at risk the integrity of our Customs Union, our Common Commercial Policy, our regulatory policy, and our fiscal revenue.”35 Michel Barnier gave a press conference shortly after the UK’s document was published. While he cautiously welcomed the document’s publication, he raised three questions about the UK’s backstop proposal:

i)Is it a workable solution to avoid a hard border?

ii)Does it respect the integrity of the Single Market and Customs Union?

iii)Is it an all-weather backstop (i.e. will it last as long as is necessary, unless and until a viable alternative solution is in place)?36

17.It is not clear how the Government’s proposal could serve as a credible backstop if it were time-limited, as it is unclear what would happen if alternative solutions were not found by any deadline that was imposed. The Government’s technical notice stated, “There are a range of options for how a time limit could be delivered, which the UK will propose and discuss with the EU”. Furthermore, it suggested that the Government would agree to the inclusion of a backstop in the Withdrawal Agreement on the condition that a “permanent end state settlement”—including permanent end state customs arrangements—were included in the Political Declaration that will be agreed alongside the Withdrawal Agreement:

Such a temporary arrangement could only be provided for in law if a Withdrawal Agreement is agreed between the UK and the EU. This Withdrawal Agreement will be accompanied by, and refer to, an agreed future partnership framework, which would set out the new customs end state arrangement.37

18.The Government’s technical notice acknowledged that it was an incomplete backstop proposal, as it did not cover how checks that relate to regulations would be eliminated. A recent Institute for Government report on the Northern Ireland/Republic of Ireland border said that “customs checks account for less than half of the border formalities” and that regulatory checks are “more onerous”.38 The table below, published by the European Commission, sets out the range of checks that apply at the EU’s external border.39

19.On 18 July 2018, the Prime Minister said in evidence to the Liaison Committee that the Government would not publish details on the extent to which the UK would align with EU regulations under the backstop, before the Withdrawal Agreement was complete. She said, “People will see what the final details of those are when the final Withdrawal Agreement is able to be put to Parliament.”40

20.The White Paper on the future EU-UK relationship did not expand on the Government’s backstop proposal, except to say that it “will never have to be used”.41 However, Professor Michael Dougan, Professor of European Law and Jean Monnet Chair in EU Law at the University of Liverpool, suggested that this was not possible to guarantee as, even if workable customs arrangements are agreed in the context of the future EU-UK relationship, it could still be necessary to implement the agreed backstop option if the preferred customs arrangements were found to be insufficient in the long-term. He said:

if UK trade policy so diverges from EU trade policy that the [customs] system simply is no longer sustainable, if the UK Parliament decides to diverge from the common rulebook in a way that causes serious friction in trade, the backstop solution might well come into play.42

21.The December 2017 Joint Report said that the areas of EU-UK alignment under the backstop must include “those rules of the Internal Market and the Customs Union which, now or in the future, support North-South cooperation, the all island economy and the protection of the 1998 Agreement.” Negotiators have conducted a joint mapping exercise of these areas of North-South cooperation. The results of this mapping exercise have not been published and therefore the exact scope of the ‘full alignment’ commitment remains unclear. When the Committee visited Dublin in January 2018, we heard that 142 areas of north-south cooperation had been identified. In our previous two reports on the progress of the negotiations, we have called for the results of the mapping exercise to be published.43 In a letter to us dated 24 April 2018, the then Secretary of State for Exiting the European Union said that he was committed to publishing the results as soon as they are available. However, he said that the joint mapping exercise “remains part of ongoing negotiations with the European Commission and further work has been agreed to finalise it.” He also said that as the mapping exercise was a joint UK-EU endeavour, it would be necessary to coordinate any release of information with the European Commission and the Irish Government.44 On 24 July 2018, the Rt Hon Dominic Raab MP, the Secretary of State for Exiting the European Union, repeated this commitment by telling us that we could expect to receive the results soon. However, he did not provide an indicative timetable.45 On 23 August 2018, the Secretary of State told us in a letter that he was “happy to share the final list with the Committee, once negotiations on this are concluded, and ahead of any publication. As previously set out, as this is a joint exercise any publication will need to be coordinated with the Commission and Irish Government.”46

22.While the Government and the European Commission disagree on the viability and territorial scope of one another’s proposals, both sides now agree on the issues that the backstop must cover. On 19 June 2018, they published a Joint Statement that said that both sides agreed that “the scope of the [European Commission’s] draft Protocol reflects the issues that require legally operative agreed text in the Withdrawal Agreement.”47 On 3 September 2018, Michel Barnier told us that the European Commission was happy to consider further proposals from the Government on the backstop. He said:

it is not necessarily our backstop, as covered in this document. We are open to discussing other backstops, so we can discuss this text, we can make changes to it. We are open, but whatever happens, there has to be a backstop. We need that. It has to be an operational backstop in legal terms.48

23.Negotiators have agreed that there must be a backstop option in the Withdrawal Agreement to protect an open trade border on the island of Ireland, otherwise there can be no deal. We welcome the fact that the European Commission has said that it has no objection to a UK-wide backstop “in principle”. This is the only approach that will prevent an economic border from being drawn in the Irish Sea which would not be acceptable. However, time is running out and therefore the European Commission must show more flexibility and a willingness to work with the Government to find a practical solution.

24.In the Joint Report of December 2017, the Government accepted responsibility for proposing specific solutions to address the unique circumstances of the island of Ireland, and while we welcome the Government’s publication of its own backstop proposal it is becoming a matter of serious concern to us that it is not complete. It does not explain how regulatory checks—which are more onerous than those that relate to VAT, excise or tariffs—would be eliminated, and it does not explain fully how a backstop, which must meet the objectives in the December 2017 Joint Report, can be “time limited”. Without a workable backstop proposal to solve the Irish border question there will be no Withdrawal Agreement. As a matter of urgency, the Government must set out clearly how it intends to eliminate regulatory checks at the border and how the backstop might be time limited when, by definition, it would need to remain in place until such time as an alternative arrangement that would achieve the same outcome could be implemented.

25.The Government has not set out the full extent of the rules that are necessary to maintain North-South cooperation on the island of Ireland, which have been scoped in a joint mapping exercise between the Government and the European Commission. We note that the exercise is subject to ongoing negotiations, but we were told in April that the Government was hopeful that these would be concluded “soon”. We call on both sides to conclude these negotiations and to provide the results of the mapping exercise to us as soon as possible.

26.We think it is essential that the joint commitment to avoid a hard border in the Withdrawal Agreement is reflected in the Political Declaration and ensured in the future relationship.

Governance of the Withdrawal Agreement

27.The second main part of the Withdrawal Agreement49 that is yet to be agreed is the governance arrangements for the Withdrawal Agreement, and specifically the mechanisms that will be used to settle disputes between the two sides. The Government has agreed to accept the jurisdiction of the CJEU during the transitional/implementation period.50

28.The Commission has set out its proposals for dispute resolution, most recently in the draft Withdrawal Agreement. Both sides have agreed to give the CJEU full jurisdiction as currently provided for in the EU Treaties during the transition/implementation period in respect of the interpretation and application of the Withdrawal Agreement. Both sides have also agreed to establish a Joint Committee, co-chaired by the UK and European Union, which will be responsible for the implementation and application of the Agreement. The Joint Committee would have the power to adopt decisions which would be “binding on the Union and the United Kingdom” that will “have the same legal effect as this [Withdrawal] Agreement”. All decisions by the Joint Committee would be made by mutual consent.51

29.Negotiators have not agreed what would happen if the Joint Committee is unable to resolve a dispute. The European Commission has proposed that disputes that cannot be resolved by the Joint Committee will ultimately be settled by the CJEU at the request of either party. It has also proposed that the CJEU would be able to enforce disputes with a power to impose penalty payments.

30.The Government disagrees that the CJEU should be the ultimate arbiter of the Withdrawal Agreement. Although it has acknowledged the fact that the CJEU is the ultimate arbiter of EU law within the European Union, it has previously rejected the suggestion that the CJEU must therefore be given the power to enforce and interpret international agreements between the European Union and third countries. In August 2017, the Government published a paper exploring how the provisions of the Withdrawal Agreement and any future partnership agreement might be overseen once the UK has left the European Union. It said, “There is no precedent, and indeed no imperative driven by EU, UK or international law, which demands that enforcement or dispute resolution of future UK-EU agreements falls under the direct jurisdiction of the CJEU.”52 The Government has not yet published a specific counter-proposal to the EU’s proposal.

31.The White Paper on the future EU-UK relationship said that the Government favours arbitration for dispute resolution in specific cases that arise under the agreements that establish the future EU-UK relationship. However, it also said that arbitration would not cover all disputes and would be conditioned by a requirement for any arbitration panel or the Joint Committee to seek a preliminary ruling from the CJEU in relation to EU rules, by mutual consent. It said:

The Joint Committee or arbitration panel would have to resolve the dispute in a way that was consistent with this interpretation. This would respect the principle that the court of one party cannot resolve disputes between the two.53

It is not clear whether the Government views a similar model of dispute resolution applying to the Withdrawal Agreement.

32.In our May 2018 report on the progress of the negotiations we agreed with the Government that “the CJEU should not be the final arbiter after the transition/implementation period is concluded” but we acknowledged that “dispute resolution [cannot] be left to the Joint Committee for technical and political arbitration alone” and that the “only acceptable solution is a final arbiter whose composition is balanced between representatives from the UK and the EU’s institutions.”54 In answer to a question about arbitration, the Secretary of State told the European Scrutiny Committee on 5 September 2018 that, “we are making good progress”.55 We have not yet seen the Government’s proposals for how the membership of an arbitration panel would be agreed, including how consideration would be given to including specialist expertise for a specific case.

33.Since our last report on the progress of the negotiations in May 2018, we have not seen any progress between the two sides on agreeing how disputes over the provisions in the Withdrawal Agreement should be settled. We acknowledge that the European Union will wish to preserve the autonomy of the CJEU to interpret EU law, but it should recognise that the Withdrawal Agreement is a deal between two sides. In August 2017, the Government set out a range of possible dispute settlement mechanisms and models of arbitration that are common in international agreements, but it did not declare which one it preferred. We repeat our recommendation from our May 2018 report that the Government set out its preferred arrangement for dispute resolution.

No Withdrawal Agreement

34.Since the White Paper on the future EU-UK relationship was published, attention has also been devoted to the prospect of the UK leaving the European Union without a Withdrawal Agreement, the so-called ‘no deal’ scenario. This will happen if the Government and the European Union fail to agree a mutually acceptable Withdrawal Agreement and Political Declaration on the future EU-UK relationship. It could also happen if the UK Parliament or the European Parliament vote against the ratification of these documents (provided there is no subsequent rapid renegotiation, an extension of the Article 50 timeframe or the suspension of Article 50). Under these circumstances, the UK would leave the European Union in accordance of the terms of Article 50, on 29 March 2019 without a Withdrawal Agreement. The Institute for Government has published an infographic that shows the possible routes to a no deal scenario:56

35.Major manufacturers based in the UK have talked publicly about the risks to their businesses if this happened. An Airbus risk assessment said that the effect of no deal on just-in-time supply chains would lead to unrecoverable delays to production. The cost to the company’s turnover could be up to £1 billion per week:

Every week of unrecoverable delay would entail material working capital impact, re-allocation cost, cost for inefficient work, penalty payments to customers and up to €1B weekly loss of turnover. Despite the incremental stocks, the disruptions in a no deal Brexit situation are likely to add up to several weeks; potentially translating into a multi-billion impact on Airbus.57

On 26 June 2018, BMW’s Customs Manager said in a statement to the media that “We always said we can do our best and prepare everything, but if at the end of the day the supply chain will have a stop at the border, then we cannot produce our products in the UK”.58 Moreover, on 5 July 2018, Ralf Speth, the Chief Executive of Jaguar Land Rover, said that without the right deal, tariffs would cost the company £1.2 billion a year and make it unprofitable to remain in the UK.59

36.In contrast to this, John Longworth, a former Director General of the British Chambers of Commerce and now Co-Chairman of the campaign group Leave Means Leave, has said that there would be benefits to the UK from a scenario in which the UK traded with the European Union on WTO terms. He acknowledged that a no deal scenario would be disruptive in the short term but said:

Because we would be able to remove tariffs, it would reduce the cost of living–especially for the poorest–boosting disposable income and the economy in the process. Trade deals would include non-tariff barriers, further boosting the economy and reducing living costs.60

37.The former and current Secretaries of State for Exiting the European Union have said that ‘no deal’ does not necessarily mean that there would be no deals at all between the UK and the European Union. On 25 April 2018, the Rt Hon. David Davis MP, then Secretary of State for Exiting the European Union told us that sectoral deals with the European Union and its member states could be reached to mitigate the most disruptive effects of having left the European Union without a Withdrawal Agreement. He said:

Indeed, it would also depend on what you mean by “no deal”. I have said to this Committee before that the complete absence of any outcome is unlikely. You might end up with a bare-bones deal; that is a phrase I think I have used before. You might end up with a whole series of bilateral deals. We are looking at tiny probabilities here. I do not think no deal is a significant probability at all. A massively higher probability is a deal. In the event it goes down that other route, nobody wants that. No other country wants that. Talk to Spain. They do not want their aviation issues blocked.61

38.On 23 August 2018, the Secretary of State for Exiting the European Union said that a failure to finalise or ratify a Withdrawal Agreement would not preclude there being sufficient goodwill to negotiate sectoral deals to ameliorate the effect on individuals and businesses. He said, “I find it difficult to imagine that our EU partners would not want to cooperate with us even in that scenario in key areas like this, given the obvious mutual benefits involved.”62 However, this cannot be guaranteed. On 3 September 2018, Michel Barnier told the Committee “if there is a no deal there is no more discussion. There is no more negotiation. It is over and each side will take its own unilateral contingency measures and we will take them in areas such as aviation but this does not mean mini deals in the case of a no deal.”63 It is not clear to us whether this is what would actually happen and we note that it is reported that the Department for Transport has written to other EU member states to ask for separate negotiations on haulage and aviation in the event of no deal, which suggests that the Government may have a different view.

39.On 23 August 2018, the Secretary of State for Exiting the European Union set out in a speech five steps the Government is undertaking to prepare for the prospect of leaving the European Union without a Withdrawal Agreement. These included passing the legislation that is needed to prepare for UK withdrawal, recruiting extra staff across Government,64 “bolstering institutional capacity” to take on functions currently operated at EU-level, negotiating the continuance of international agreements and allocating money for no deal preparations.65

40.Independently of one another, the Government and the European Commission have published technical notes that advise on preparations for a no deal scenario, aimed at individuals, businesses and public institutions. On 19 July 2018, the European Commission issued a document that outlined some of the main effects.66 The document emphasised that negotiations on the draft Withdrawal Agreement are continuing and that a negotiated settlement is the EU’s preferred outcome. However, it also noted that important issues remain unresolved. In the event of the UK leaving the European Union without a Withdrawal Agreement, the document said that controls at borders “could cause significant delays, e.g. in road transport, and difficulties for ports”, where there could be “long lines of vehicles waiting for customs procedures to be fulfilled”. It also said that the UK would become a third country for trade and regulatory issues, which would “represent a significant drawback compared to the current level of market integration”. It emphasised that while many measures would have to be taken at EU level, national, regional and local governments also need to step up preparation to “mitigate the worst impacts of a potential cliff-edge scenario”. The European Commission also published 68 technical notices advising on preparations for specific sectors of the economy, including health and food safety, financial services, customs, transport, and company law.67

41.The Government has started to publish its own documents providing advice to stakeholders on what to do in the event of no deal. On 23 August 2018, the Government published the first tranche of 25 documents—approximately one third of the total—which included technical notices on importing and exporting, regulating medicines and medical equipment, workplace rights and farming, among other subjects.68 The Secretary of State said that he expected to publish the full set of no deal technical notices by the end of September 2018.

42.The Government’s technical notices show that in many sectors, the Government would mitigate the effect of there being no deal by acting unilaterally with the assumption that the European Union would respond in kind. For example, in his speech on 23 August 2018, the Secretary of State drew attention to the technical notice on ‘Batch testing medicines if there’s no Brexit deal’, which illustrates this approach.69 Manufacturers can currently batch test medicines anywhere in the EU, EEA or other third countries with whom the EU has a Mutual Recognition Agreement. To ensure continuity of supply of medicines to the UK in a no deal scenario, the UK would continue to accept batch testing of human medicines carried out in these countries. The Secretary of State said he would expect the EU to do the same:

given that we start from a position of common rules, we would also hope and I think expect, in good faith between close partners, that the EU would recognise medicines from this country with our regulatory approval. But in a no deal scenario, we can’t guarantee it.70

43.On 4 September 2018, Philip Rycroft, Head of UK Governance Group and Permanent Secretary of the Department for Exiting the European Union, told us that the Government had undertaken country by country analysis of the effect of no deal on the EU27. In answer to a question on whether these would be published, he said, “We do not have any immediate plans, but it is certainly information that is informing decisions that Ministers take about their position across the range of scenarios that we are planning for.”71

44.There has been renewed debate in the UK on the prospect of the UK leaving the European Union without a Withdrawal Agreement. It is in the interests of both sides to successfully conclude negotiations on the Withdrawal Agreement, so that the 21-month transition/implementation period is secured, and that certainty is provided for citizens and businesses in the European Union and the UK. It is clear that there would be significant consequences for the UK and the European Union from a no deal outcome. We remain of the view that this would be chaotic and damaging for the UK economy and would leave many businesses facing huge uncertainty.

45.In many areas, the Government’s no deal contingency planning rests on the European Union taking reciprocal action to minimise harm. This assumes that, if no deal is reached, there would be sufficient goodwill between the two sides that specific sectoral agreements could still be reached to minimise damage to the UK and EU economies. When we met Michel Barnier, he ruled this out and we would ask the Government to respond to his statement. Furthermore, even if both sides wanted to work together to find ways to mitigate the worst effects, it is far from clear that there would be enough time to negotiate, agree and implement any sectoral deals before the UK leaves the European Union at the end of March 2019. The Government has said that further technical notices will be published throughout September. We will take further evidence on these and the effects of a potential no deal exit from the European Union. We think it particularly important that there should be a notice covering the Irish border issue. We also call upon the Government to publish the country by country assessments on EU member states’ economic interests that the Department has undertaken.

22 Both sides of the negotiations have said that “nothing is agreed, until everything is agreed.”

23 According to Michel Barnier, there are about 3,000 geographical indications. See House of Lords, Oral evidence: Scrutiny of Brexit Negotiations, 17 July 2018, Q1

25 Department for Exiting the European Union, How to prepare if the UK leaves the EU with no deal, 23 August 2018

27 The transition/implementation period is scheduled to end on 31 December 2020

28 European Commission & Department for Exiting the European Union, Joint report on progress during phase 1 of negotiations under Article 50 TEU on the UK’s orderly withdrawal from the EU, 8 December 2017, para 49, and Commission, draft Withdrawal Agreement, 19 March 2018

31 HC Deb 28 February 2018, Vol. 636, Col. 823

33 Exiting the European Union Committee, The progress of the UK’s negotiations on EU withdrawal (March to May 2018), Fifth Report of Session 2017–19, HC 1060, 24 May 2018, para 27

34 Cabinet Office, Technical Note: Temporary Customs Arrangement, 7 June 2018

36 European Commission, Press statement by Michel Barnier following this week’s round of negotiations, 8 June 2018. On 11 June 2018, the European Commission also published slides expressing further concerns about the Government’s backstop proposal. See, European Commission, Slides on UK technical note on temporary customs arrangements

37 Cabinet Office, Technical Note: Temporary Customs Arrangement, 7 June 2018

38 Institute for Government, The Irish Border after Brexit, June 2018

39 European Commission, Slides on customs controls, 22 May 2018. The red text highlights the few checks which would be eliminated by continued membership of the customs union, without continued alignment with EU regulations and standards

40 Liaison Committee, Oral evidence: The Prime Minister, HC 1393, 18 July 2018, Q9

43 Exiting the European union Committee, The progress of the UK’s negotiations on EU withdrawal (March to May 2018), Fifth Report of Session 2017–19, HC 1060, 24 May 2018, para 23. See also, Exiting the European Union Committee, The progress of the UK’s negotiations on EU withdrawal: December 2017 to March 2018, Third Report of Session 2017–19,HC 884, 18 March 2018, para 50

44 Exiting the European Union Committee, Letter to the Chair from the Secretary of State, 24 April 2018

45 Q2387. The Secretary of State confirmed this position on the publication of the joint mapping exercise in a letter to the Committee sent after 24 July 2018 evidence session. See, [insert link to letter once Committee has agreed to publish]

46 [Insert link to letter once Committee has agreed to publish]

50 In addition, the Government has arranged for preliminary rulings to the CJEU on citizens’ rights to continue for a period of eight years after the transition/implementation period

51 The draft Withdrawal Agreement also establishes specialised committees, on citizens’ rights, other separation provisions, the island of Ireland, Sovereign Base Areas, and on the financial provisions. Recommendations by the specialised committees would be referred for adoption to the Joint Committee. See, European Commission, Draft Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community, 19 March 2018

52 Department for Exiting the European Union, Enforcement and dispute resolution, 23 August 2017

53 Department for Exiting the European Union, The future relationship between the United Kingdom and the European Union, 12 July 2018, Chapter 4, paras 39-43

54 Exiting the European Union Committee, The progress of the UK’s negotiations on EU withdrawal (March to May 2018), Fifth Report of Session 2017–19, HC 1060, 24 May 2018, para 34

55 European Scrutiny Committee, Oral evidence: EU Withdrawal, HC 763, 5 September 2018, Q842

56 Institute for Government, Autumn surprises: possible scenarios for the next phase of Brexit, 17 August 2018, page 3

57 Airbus, Brexit — Risk Assessment, 21 June 2018

58 Financial Times, BMW warns Brexit could force UK plant closures, 26 June 2018

62 Department for Exiting the European Union, Secretary of State Dominic Raab’s speech on no deal planning, 23 August 2018

64 The Secretary of State said that there are more than 7,000 people working on UK withdrawal from the European Union and that there is funding for an extra 9,000 staff to be recruited into the civil service

65 The Chancellor of the Exchequer has committed £3 billion in the Budget on top of the £700 million already allocated for planning and preparations

67 European Commission, Preparedness notices

68 Department for Exiting the European Union, How to prepare if the UK leaves the EU with no deal, 23 August 2018

69 Batch testing is the process of confirming every batch of medicine has the correct composition through laboratory tests

70 Department for Exiting the European Union, Secretary of State Dominic Raab’s speech on no deal planning, 23 August 2018

Published: 18 September 2018