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If Britain avoids a no-deal crash-out from the EU when its resignation letter expires on 29 March 2019, it will still have left the customs union, unless a stay of execution is agreed.
Only EU states can be members of the customs union and the UK has resigned, via Theresa May’s Article 50 notification, which removed the pin from a grenade with a two-year fuse.
Attempts to re-insert the pin, through a transition period after March 2019, are being resisted even inside the British cabinet.
Trade secretary Liam Fox maintained last Sunday that Britain has nothing to fear from a no-deal outcome, a position so deluded that it provoked a negative response from several prominent Leave campaigners.
It is reasonable at this stage to assume that some form of transition will eventually be agreed, but the long-term deal will see Britain outside the CAP and with a new trade policy.
This could be a comprehensive trade agreement retaining at least some aspects of single market access but any new partnership with the customs union (from outside, a-la-Turkey) will be resisted by ultra Brexiteers, including the trade secretary, who believe that the common external tariff is holding Britain back.
Liam Fox’s job, after all, is the pursuit of new trade deals outside the customs union.
Donald Trump has promised a ‘‘beautiful’’ trade agreement with Britain after Brexit and the US exporters of agricultural produce will expect to be beneficiaries.
Emily Davis, spokeswoman for Robert Lighthizer, the US trade representative, elaborated on the president’s remark.
“Ensuring that US exporters of food and agricultural products have the market access in Europe due to them even after Brexit is a high priority for the administration,” she said, according to the Financial Times.
Brexiteers have listed the prospect of cheaper food imports as one of the potential upsides of departing the EU. It is, and moreover rather difficult to think of too many others.
Safety standards
The UK is a substantial net food importer and world prices are below European prices.
But there is a snag: European food safety standards are demanding and it is not clear that the British public will be happy with US imports, or imports from other major potential suppliers, which do not meet equivalent standards.
A recent report from the University of Sussex lists four problems with a US deal.
Bovine somatotropin (BST) is used in dairy production in the US. EU authorities have banned its use, and the importation of animals or products there-from, because “BST administration causes substantially and very significantly poorer welfare because of increased foot disorders, mastitis, reproductive disorders and other production-related diseases.
"These are problems which would not occur if BST were not used and often result in unnecessary pain, suffering and distress.”
Hormones
Beef hormones are popular with cattle producers in the US as growth promoters: they economise on feed requirements.
The EU assessment concluded that beef from treated cattle posed risks to vulnerable groups including pregnant women and young children, and it is illegal to import beef unless it comes from animals not treated with hormone implants.
GM foods are restricted in the EU through labelling requirements and production controls.
The US permits far more GM crops and food to be lawfully produced and sold than is allowed in Europe.
Chlorinated disinfectant for poultry products is permitted in the US but banned in Europe, the source of the ‘‘chlorinated chicken’’ flap in the UK over the summer, which brought forth prompt denials from ministers that any relaxation of food safety standards was contemplated.
Some experts believe that European food safety standards are over-cautious, although I never feel the need to pack personal rations on my occasional trips to the Land of the Free.
The US authorities insist that American food is perfectly safe. While the experts disagree, there is no prospect of any early realignment between US and European rules.
Britain may yet have to forego the opening of its food market in any future trade deal with the US, or with other prospective partners on Liam Fox’s ambitious list, since public opinion in Britain will revolt otherwise. Indeed, the tabloid press, which fed the decades of Europhobia that spawned Brexit in the first place, have already made a live issue out of chlorinated chicken.
The prospects for a ‘‘beautiful’’ post-Brexit trade deal with the US were never great and restricted access to the UK food market reduces the attractions for the US.
Public sensitivities about food may yet see the UK agreeing to European norms for the long term, even if the UK struggles with other components of an EU trade agreement.
This would ease the path to a special cross-border regime in Ireland for live animals, as well as intermediate and consumer food products.
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