Caribbean Trade Law and Development

Tag: CARIFORUM

  • Making the UK-CARIFORUM EPA Work for Post-Brexit UK-CARIFORUM Trade

    Making the UK-CARIFORUM EPA Work for Post-Brexit UK-CARIFORUM Trade

    Alicia Nicholls

    As of January 1, 2021, the formal trading relationship between the United Kingdom (UK) and CARIFORUM countries (with the exception of Haiti) is no longer governed by the Economic Partnership Agreement signed between the European Union (EU) and CARIFORUM countries (EU-CARIFORUM EPA) in 2008. Instead, while that agreement continues between the remaining EU-27 and CARIFORUM countries, the new UK-CARIFORUM Economic Partnership Agreement (UK-CARIFORUM EPA) provisionally applies to UK-CARIFORUM trade until ratified by all parties. As with any trade agreement, market access on paper is of little value unless firms can convert it into meaningful market penetration in practice. This article explores how CARIFORUM countries could make this ‘new’ agreement work for deepening UK-CARIFORUM trade.

    UK-CARIFORUM trade

    The UK-CARIFORUM EPA provides duty-free and quota-free access for goods, preferential access for services providers and investors, among other things. The novelty of the agreement applies more so to its date of signature than its substance as it merely replicates or ‘rolls over’, to the extent practicable, the provisions of the EU-CARIFORUM EPA to ensure trade continuity between the UK and CARIFORUM countries once the former had left the EU. As such, the market access conditions CARIFORUM exporters face in the UK market, and vice versa, remain unchanged in substance from what obtained under the EU-CARIFORUM EPA.

    Preserving post-Brexit access to the UK market for CARIFORUM exporters was critical for the region as the UK was a major export market within the EU for many CARIFORUM countries and the major destination for certain CARIFORUM exports like rum, bananas and sugar. It is also an export destination for Trinidad’s methanol and liquified natural gas (LNG) exports. The UK-based Caribbean diaspora community is a key demandeur of CARIFORUM products such as rum, sauces, seasonings, biscuits and other ‘nostalgic’ goods.  

    The Ex Post Evaluation of the EU-CARIFORUM EPA Report released by the European Commission last year noted that many CARIFORUM producers also used the UK as an entry point into the EU market and identified the Caribbean diaspora in the UK as ‘a key facilitating factor’. Using the UK as an entry point might no longer be that attractive an option for CARIFORUM firms given that the UK is no longer within the EU single market or customs union.

    Overall, however, trade between the UK and CARIFORUM has been on a general decline, according to data from the UK Office of National Statistics.Over the twenty year period between 2000 and 2020, UK imports from CARIFORUM countries declined as a percentage of UK imports, except for a spike to 0.53% in 2009, immediately after the signing of the EU-CARIFORUM EPA. In spite of this, the UK remains a major source market for tourist arrivals to the region, and for some CARIFORUM countries like Barbados, the main source for FDI in the tourism sector and second home market.

    Deepening UK-CARIFORUM relations

    Export diversification is one of the strategies identified by CARIFORUM countries as part of their post-COVID-19 recovery efforts. In light of the above, there is clearly scope for both expanding and diversifying current UK-CARIFORUM trade away from mostly low-value added products and into higher value manufactured goods and high value-added services. There is scope for encouraging greater UK FDI into the region outside of traditional sectors like tourism and real estate and into renewable energy, education, health and other sectors linked to the UN sustainable development goals (SDGs). The UK-CARIFORUM EPA’s Protocol III on Cultural Cooperation (the Cultural Protocol) which replicates that of the EU-CARIFORUM EPA, can be leveraged to promote greater UK-CARIFORUM trade in the creative industries through, for instance, joint film and music productions.

    Deepening UK-CARIFORUM relations appears to be a goal for both regions as evinced by the Action Plan and communique released from the Tenth UK-Caribbean Ministerial Forum held in March 2021. Trade and commercial relations was one of the six substantive areas of joint action identified. Among the goals under that action item are the establishment of a UK-Caribbean Business-to-Business (B2B) Roundtable, commitment to identify opportunities to use the significant capacity available for export credit financing support to the region through UK Export Finance (UKEF), to promote and expand UK-Caribbean trade flows and to further reduce market access barriers for one another’s exporters. In addition to this, the UK also expanded its diplomatic footprint in the Caribbean by opening new permanent missions in some CARIFORUM Member States in 2018 and in 2020 appointed a Trade Envoy for the twelve Commonwealth Caribbean countries.

    Recommendations

    In addition to the commitments made under the Action Plan, there are some concrete ways in which the UK-CARIFORUM EPA can be utilized to deepen post-Brexit UK-CARIFORUM trade and investment. These include the following:

    1. Raise awareness by both CARIFORUM and UK firms of the market access opportunities under the UK-CARIFORUM EPA. Many firms remain unaware of these opportunities;
    2. Accelerate the establishment of the proposed UK-Caribbean B2B Roundtable and set concrete deliverables for what this roundtable will seek to achieve;
    3. Promote greater ties between CARIFORUM-UK businesses to encourage greater information-sharing on market and investment opportunities. This could be done, for example, through the B2B Roundtable, as well as through formalized links between the Chambers of Commerce and industry associations of the region and in the UK;
    4. Make greater use of existing institutions like the Caribbean Chamber of Commerce in Europe, whose remit also extends to the UK, to promote greater links between UK and CARIFORUM-based businesses;
    5. Explore ways in which the region, including regional institutions, can work more closely with the UK Trade Envoy for the Caribbean, the UK missions, UK Export Finance (UKEF) and other trade-related UK agencies to promote greater UK-CARIFORUM trade;
    6. Conduct a study to determine the current barriers impacting CARIFORUM businesses seeking to access the UK market and propose solutions for how these could be overcome to promote greater CARIFORUM-UK trade;
    7. Conduct a study on the ways in which the new EU-UK trading relationship impacts the use of the UK as an entry point to the EU and ways in which this could be mitigated;
    8. Better leverage the UK-based Caribbean diaspora for enhancing UK-CARIFORUM trade and investment. Aside from the usual benefits of remittances and diaspora FDI, the diaspora could also provide market intelligence, business mentoring and coaching for CARIFORUM entrepreneurs interested in trading with UK firms or establishing a presence in the UK;
    9. Make greater use of economic diplomacy by leveraging CARIFORUM countries’ diplomatic missions in the UK to identify opportunities for UK-CARIFORUM trade and investment;
    10. Accelerate the establishment of the joint institutions provided for under the UK-CARIFORUM EPA.

    Alicia Nicholls, B.Sc., M.Sc., LL.B. is a trade and development consultant with a keen interest in sustainable development, international law and trade. All views herein expressed are her personal views and should not be attributed to any institution with which she may from time to time be affiliated. You can read more of her commentaries and follow her on Twitter @LicyLaw.

  • EU-CARIFORUM EPA Monitoring Report finds five-fold increase in EU FDI to CARIFORUM

    EU-CARIFORUM EPA Monitoring Report finds five-fold increase in EU FDI to CARIFORUM

    Alicia Nicholls

    Foreign Direct Investment (FDI) from the European Union (EU) increased five-fold to CARIFORUM countries on a whole over the period 2013-2017, with the Bahamas and to a lesser extent, Barbados, being the main destinations. This increase, however, was not as a direct result of the EU-CARIFORUM Economic Partnership Agreement (EU-CARIFORUM EPA). These are some of the conclusions emanating from the final report of the study “Ex-post evaluation of the Economic Partnership Agreement (EPA) between the European Union and CARIFORUM” evaluating the implementation of the EPA over the period 2008-2018.

    The EU-CARIFORUM EPA was signed in 2008 and has been provisionally applied since then. It liberalises trade and investment between the EU and CARIFORUM on the basis of asymmetrical reciprocity and provides for development cooperation. It comprises 15 countries on the CARIFORUM side and had included the then 28 EU Member States when the United Kingdom was still an EU member. The first EPA monitoring report of 2014 had found several implementation shortcomings and it appears not much has changed since that first report.

    The current report found overall that implementation of the Agreement has been “mixed”, noting that while “clear progress in implementation has been made, several shortcomings remain.” It revealed implementation shortcomings in a number of categories, namely, liberalisation commitments, regulatory commitments, as well the institutional commitments. It further stated that “while in the EU not many shortcomings in terms of EPA implementation were observed, there are clearly barriers in place which can limit the CARIFORUM countries’ expected benefits under the EPA.” Several implementation shortcomings on the CARIFORUM side have been noted, including regarding commitments on intellectual property rights, electronic commerce and regional preferences.

    Implementation gaps related to the institutional commitments are common to both Parties, according to the report. Ratifications have, however, increased since the last report with 25 out of the (then) 28 EU countries and 10 out of 15 CARIFORUM countries having ratified the agreement.

    It is not lost on the reader that there are some clear assumptions expressed in the report, some of the same assumptions that have resulted in the EU unfairly placing some CARIFORUM countries on its blacklists for tax and anti-money laundering and countering the financing of terrorism (AML/CFT) purposes. For one, with regard to the increase in FDI, the report questioned “to what extent these are productive investments, as they are concentrated in the Bahamas and to a lesser extent Barbados”, which are low tax jurisdictions, and that “in the consultations, no clear champions could be identified”.

    The EU remains the top provider of development assistance to the region. It is, therefore, curious that while the report rightly listed a number of development challenges facing CARIFORUM, including climate change and the COVID-19 pandemic, it unfortunately appears to flippantly note that “the countries do not face these challenges alone, but together with their key partners”. That statement ignores the fact that CARIFORUM countries are primarily small island developing States whose capacity to meet these challenges, is much more circumscribed than that of larger countries. One only needs to look at the fact that CARIFORUM countries face significant challenges in accessing COVID-19 vaccines for their populations on equal terms as larger countries.

    Another interesting finding from the report regarding FDI is that the EPA has had a low impact on EU FDI into the CARIFORUM tourism sector. The EPA, it argued, was rarely among the decisive factors driving FDI to the region and “the level of awareness of the EPA is very low, with even large investors often being unaware of the EPA.”

    It should be noted that the EPA does not include a full investment chapter as the EU Commission at the time only had competence to negotiate investment liberalisation. Investment protection provisions are not included in the EPA’s investment chapter. Investors would have to rely on protections included in the individual BITs existing between various CARIFORUM and EU countries, where available and in force, most of which predate the EPA.

    In sum, the study found that the EPA had occasioned limited changes in overall trade and investment between the EU and CARIFORUM, leading to a conclusion of a lack of a clear impact of the EPA. It also outlines several recommendations.

    The executive summary of the final report may be accessed here.

    Alicia Nicholls, B.Sc., M.Sc., LL.B. is a trade and development consultant with a keen interest in sustainable development, international law and trade. All views herein expressed are her personal views and should not be attributed to any institution with which she may from time to time be affiliated. You can read more of her commentaries and follow her on Twitter @LicyLaw.

  • UK-CARIFORUM Economic Partnership Agreement: What does it all mean?

    UK-CARIFORUM Economic Partnership Agreement: What does it all mean?

    Alicia Nicholls

    On March 22, 2019, the United Kingdom of Great Britain and Northern Ireland (UK) and nine of the fifteen States comprising the Caribbean Forum (CARIFORUM), a subgroup of the African, Caribbean and Pacific (ACP) countries, signed the CARIFORUM-UK Economic Partnership Agreement (CARIFORUM-UK EPA)  which seeks to ensure that the current trade preferences between the UK and CARIFORUM remain after the UK’s departure from the European Union (EU).

    This makes CARIFORUM one of nine trading partners with which the UK has to date successfully concluded a trade continuity agreement. This development has been widely welcomed by businesses and private sector associations in the Caribbean. But why was the CARIFORUM-UK EPA necessary and what does it provide for?

    The CARIFORUM-UK EPA is between the United Kingdom of Great Britain and Northern Ireland on the one hand, and the fifteen CARIFORUM States (Antigua & Barbuda, The Bahamas, Barbados, Belize, the Commonwealth of Dominica, The Dominican Republic, Grenada, The Republic of Guyana, Jamaica, St. Kitts & Nevis, St. Lucia, St. Vincent and the Grenadines, Suriname and Trinidad & Tobago), on the other.

    Nine of the CARIFORUM countries (Barbados, Belize, Dominica, Grenada, Guyana, Jamaica, St. Kitts & Nevis, St. Lucia and St Vincent and the Grenadines) signed the Agreement on March 22, 2019 at a signing ceremony in Castries, St. Lucia. Two other CARIFORUM States, Trinidad & Tobago and the Dominican Republic, signed on April 1, 2019 and on April 4, 2019, respectively. The remaining CARIFORUM States have indicated they will sign shortly.

    Why is the CARIFORUM-UK EPA necessary?

    The UK is currently due to leave the EU on April 12, 2019, unless a further extension to June 30, 2019 requested this week by the UK government is granted by the EU-27.  Until the UK officially leaves the EU, the UK’s trade relations with the fifteen CARIFORUM countries remain governed by the CARIFORUM-European Union Economic Partnership Agreement (CARIFORUM-EU EPA) which was signed and has been provisionally applied since 2008.

    The CARIFORUM-EU EPA provides for the asymmetric liberalization of trade between the EU and CARIFORUM States. This includes duty-free and quota-free goods access, preferential access for services providers and investors, and protection for intellectual property. It also includes disciplines relating to government procurement and competition, for example, as well as extensive development cooperation provisions.

    When the UK ceases to be an EU member, the CARIFORUM-EU EPA will continue to apply between CARIFORUM States and the remaining EU-27. However, the UK will no longer be party to any of the EU’s trade agreements with third parties, including the CARIFORUM-EU EPA. In the absence of a trade continuity agreement, trade between the UK and CARIFORUM would revert to World Trade Organization (WTO) Most Favoured Nation (MFN) rules. This would have implications for businesses, services providers and investors in the UK and CARIFORUM States dependent on the preferential market access provided for by the CARIFORUM-EU EPA.

    A great summary of current CARIFORUM-UK economic relations may be found in the report prepared by the Secretary of State for International Trade for the UK Parliament. According to statistics from the UK Office of National Statistics (ONS) cited in that report, total goods and services trade between the UK and CARIFORUM States (excluding Haiti) accounted for 0.2% of total UK trade and was £2.5 billion in 2017.

    Although there has been a steady decline in CARIFORUM-UK trade over time, the UK currently remains the main market for CARIFORUM exports to the EU. For example, it is a major market for Caribbean rum, banana and sugar exports. Additionally, the UK remains an important source market for tourists to the Caribbean and in the case of Barbados, remains that country’s largest source market for tourist arrivals and real estate foreign direct investment (FDI).

    To avoid any disruption in trade and to create some modicum of certainty for UK and CARIFORUM businesses and consumers once the UK leaves the EU, the UK and CARIFORUM promptly commenced dialogue on the conclusion of a trade continuity agreement that would replicate the provisions of the CARIFORUM-EU EPA, to the extent possible.

    What does the CARIFORUM-UK Agreement include?

    The CARIFORUM-UK EPA, whose main text comprises seventy-six pages, replicates to the extent possible, the text of the CARIFORUM-EU EPA. The previously mentioned Parliamentary Report provides an excellent synopsis of the Agreement, including the necessary differences between the CARIFORUM-UK EPA and CARIFORUM-EU EPA.

    Where necessary, the CARIFORUM-UK EPA has removed and replaced references to the EU in the text,  provided for the continuation of time-bound periods, as well as limited the territorial scope of the Agreement to the CARIFORUM States and to the United Kingdom, its Crown Dependencies and Gibraltar.

    The CARIFORUM-UK EPA will only take effect once the UK has left the EU. Similar to the CARIFORUM-EU EPA, the CARIFORUM-UK EPA provides for provisional application which allows it to be provisionally applied before all the parties have done the necessary domestic ratification steps to allow for the Agreement’s entry into force.

    Additionally, the CARIFORUM-UK EPA provides a safeguard in the event of a ‘no-deal’ Brexit. A non-legally binding MoU between the UK and participating CARIFORUM countries aims to stop the gap between the date the CARIFORUM-EU EPA ceases to apply to the UK until the date when the CARIFORUM-UK EPA takes effect. Under this MoU, the parties will use their best endeavours to bring the CARIFORUM-UK EPA into effect as between them within three months of the MoU’s coming into effect, during which time the UK will apply the tariff schedule laid out under the CARIFORUM-UK EPA to those CARIFORUM States which have signed both the CARIFORUM-UK EPA and the MoU. So far, the UK has signed an MoU with the original nine CARIFORUM signatories and another MoU with Trinidad & Tobago.

    Since the CARIFORUM-EU EPA’s signature in 2008, many developments have impacted on rule-making in trade agreements. Like the CARIFORUM-EU EPA, the CARIFORUM-UK Agreement includes mechanisms for monitoring the Agreement’s implementation, as well as a revision clause allowing for the parties to broaden or amend the Agreement, including the possibility of bringing the UK’s British Overseas Territories within the scope of the Agreement.

    The institutions under the CARIFORUM-EU EPA have been replicated in the CARIFORUM-UK EPA. For example, it establishes a Joint CARIFORUM-UK Council responsible for the Agreement’s implementation and operation, as well as a CARIFORUM-UK Trade and Development Committee to assist the Joint Council. Two joint institutions (namely, the Special Committee on Agriculture and Fisheries and the Technical Sub-Committee on Development Cooperation), which had been established after the CARIFORUM-EU EPA’s signature, are directly included through dedicated articles in the CARIFORUM-UK EPA’s text.

    What does it all mean?

    As of the date of this article’s publication, the UK still remains an EU member. The original Brexit Day (March 29, 2019) has passed and the extension date of April 12, 2019 is fast approaching. In light of British MPs’ rejection of the Draft Withdrawal Agreement for the third time and no clear consensus among MPs on what they believe the future EU-UK relationship should be, the UK Government has asked for a further extension to June 30, 2019. As it stands, the threat of a ‘no-deal’ Brexit still remains a real possibility.

    In light of the current Brexit chaos, CARIFORUM countries’ conclusion of a trade continuity agreement with the UK was a prudent move to preserve continuity and certainty for our businesses, consumers and investors. The CARIFORUM-UK EPA will only take effect once the UK leaves the EU and until such time, CARIFORUM-UK trade relations will remain covered by the CARIFORUM-EU EPA. Indeed, it could be regarded as an insurance policy of sorts – providing peace of mind and only used if and when needed.

    The text of the CARIFORUM-UK Economic Partnership Agreement may be found  online here, while the Parliamentary Report which provides a good synopsis may be found here.

    Alicia Nicholls, B.Sc., M.Sc., LL.B., is an international trade and development consultant with a keen interest in sustainable development, international law and trade. You can also read more of her commentaries and follow her on Twitter @LicyLaw.

  • ‘No Deal’ Brexit Scenario Increasingly Likely: What does this mean for CARIFORUM-UK Trade?

    ‘No Deal’ Brexit Scenario Increasingly Likely: What does this mean for CARIFORUM-UK Trade?

    Alicia Nicholls

    The countdown is on. With 100 days to go before the United Kingdom’s (UK) scheduled withdrawal from the European Union (EU), and the ratification of the Draft Withdrawal Agreement less likely, both sides have this week announced contingency plans for a ‘No-Deal Brexit’. What do these recent developments mean for CARIFORUM-UK trade, not just at the policy level, but at the firm level as well?

    It has been a busy week in Brexit news. After delaying the House of Commons vote on the Draft Withdrawal Agreement which was scheduled for December 11th, UK Prime Minister Theresa May this week announced that the promised vote will be held the week of January 14, 2019. In the interim, Mrs. May will be seeking to obtain additional legal assurances from the EU-27 that the deal’s ‘backstop’ provision would not keep the UK in a customs union with the EU indefinitely.

    UK and EU Brexit Contingency Plans Underway

    However, in recognition of an increasingly likely ‘no deal’ scenario, the May Government also announced plans to, inter alia, put 3,500 troops on standby, allocate monies from a contingency fund to key government departments, and outlined a post-Brexit immigration plan.

    The EU, for its part, has sought to safeguard the interests of its own EU-27 citizens and businesses by implementing a contingency plan comprising 14 legislative measures and targeting key Brexit-vulnerable sectors. Specifically on trade, the EU noted, inter alia, that “all relevant EU legislation on the importation and exportation of goods will apply to goods moving between the EU and the UK”. In a clear signal to the May Government, the EU was quick to point out that its contingency plan is meant to safeguard EU citizens foremost, that the measures do not replicate the benefits of EU membership, and that these will not mitigate all the risks of a ‘no deal Brexit’.

    Why is a ‘no deal’ more likely now?

    In an article I recently co-authored with Dr. Jan Yves Remy last week, we highlighted at least four scenarios for future UK-EU relations and analysed what each scenario may mean in turn for CARIFORUM-UK relations. Brexit represents the most epochal and seismic shift in UK trade and political policy in recent history. Brexit developments remain quite fluid, but recent developments evince the increasing likelihood of the ‘no deal’ scenario.

    EU leaders have repeatedly ruled out a return to the negotiating table. A renegotiated withdrawal agreement, therefore, now appears highly unlikely. Despite calls for a second referendum, including from former British Prime Minister, Tony Blair, this option has been fervently dismissed by the May Administration, which remains committed to her slogan of ‘Brexit means Brexit’, although she had been part of the ‘remain’ camp before the referendum.

    Labour leader, Jeremy Corbyn, has tabled a no confidence motion against Prime Minister May which, if successful, could change the current Brexit trajectory. However, despite her current unpopularity, there is no guarantee Mrs. May would be defeated or that her successor would abandon the Brexit plans. As alluring as it sounds, a ‘No Brexit at all’, scenario, therefore, at this stage still appears unlikely.

    Possible Implications of ‘no deal’ for CARIFORUM-UK trade

    Due to former colonial ties, the UK is currently most CARIFORUM (CARICOM plus the Dominican Republic) countries’ main trading partner within the EU and is also one of the main source markets for tourist arrivals and foreign direct investment to CARIFORUM countries. Given these historic and economic ties, CARIFORUM and the UK are currently in the advance stages of negotiating a roll-over of the concessions under the CARIFORUM-EU Economic Partnership Agreement which currently define CARIFORUM-UK trading relations until the UK leaves the EU. While details about the roll-over negotiations have been sparse, this agreement has reportedly taken into account the possibility of a ‘no deal’ Brexit. It is in the ‘no deal’ scenario that this roll-over arrangement has its most utility as it at least assures CARIFORUM traders of continued preferential market access to the UK if the latter leaves the EU without a transition deal in place.

    However, while the EPA ‘roll-over’ preserves the market access status quo, it does not mitigate all the risks of a ‘no deal Brexit’. Without a transition agreement in place, UK goods (and imported goods entering through UK ports of entry) will immediately after March 29, 2019 no longer have free circulation within the EU single market and will revert to World Trade Organisation Most Favoured Nation (MFN) levels – that is, they will be subject to EU import duties and non-preferential rules of origin. This, therefore, takes away the incentive for CARIFORUM firms which, due to a shared language and customs, would have used the UK as a ‘springboard’ for entering the wider EU market by establishing a commercial presence in the UK.

    Moreover, because many CARIFORUM countries’ air and sea links to continental Europe are still mainly through the UK, CARIFORUM firms will have to consider what impact these new ‘no deal’ arrangements (such as reimposed customs duties and customs checks) may have on their trade with both UK and EU partners and on their supply chains. New arrangements for aviation and haulage between the EU and UK will also add delays and increased freighting costs. These higher costs will have to be borne in mind in business planning, pricing and other decisions.

    One of the biggest threats of a ‘no deal’ Brexit is the volatility of sterling which has seen large drops in value whenever unfavourable news hits the market. If not already done, currency risks will have to be taken into account by CARIFORUM firms when negotiating commercial terms with UK trading partners and in their own risk assessments.

    With regard to tourism, the reduced spending power of UK visitors to the region, or any downturn in the UK economy due to fall-out from a ‘no deal’ Brexit’, would adversely impact those CARIFORUM countries where UK tourists account for a sizable market share or where UK purchasers account for sizable real estate purchases. Changes in UK-EU aviation arrangements may also make the cost of travel to the region more expensive for those continental European travellers which have to transit through the UK to reach the Caribbean (those which do not have the benefit of direct flights). As such, it would be beneficial for CARIFORUM countries to expand their direct air and sea links with continental Europe.

    In spite of the above, it is not all doom and gloom. There is the opportunity for CARIFORUM to redefine CARIFORUM-UK trading relations by going beyond the mere EPA roll-over and negotiating a new free trade agreement in the future with the new ‘Global Britain’ the May Administration seeks to advocate. It also gives CARIFORUM countries an additional nudge to expand their trading relations with the EU-27 themselves by making better use of the EPA, which is currently underutilised. This is also an opportune time as CARIFORUM, as part of the African, Caribbean and Pacific (ACP) grouping, is in the process of renegotiating a post-Cotonou arrangement with the EU.

    The takeaway is that the uncertainty continues! With all the news about Brexit, it is not surprising that some firms or persons may experience ‘Brexit fatigue’. It is, however, incumbent on regional firms which currently do business with, or are seeking to conduct business with those in the UK to keep abreast of these developments and to make the necessary contingency plans to ensure minimal disruption to their trading.

    Alicia Nicholls, B.Sc., M.Sc., LL.B., is an international trade and development consultant with a keen interest in sustainable development, international law and trade. You can also read more of her commentaries and follow her on Twitter @LicyLaw.