During the painful Brexit negotiations to extract the UK from the EU, Theresa May was famously told that Britain “could not have its cake and eat it” in terms of wanting things both ways.
In other words you cannot have the benefits of membership but not actually be a member. It seemed simple at the time.
But now the approach of “cakism”, as Boris Johnson called it, seems to be back on the menu but this time with Labour prime minister Sir Keir Starmer wanting a trade deal with the US at the same time as trying to get a reset trade arrangement with the EU.
As one pro-EU activist terms it: “Chlorinated chicken has replaced cake. You can’t have Trump’s (US) chlorinated chicken and a closer relationship with the EU.”
The prime minister has insisted there is “no choice” to be made between the US and EU, but with two crucial dates coming up quickly he may well be forced into a difficult choice which could determine the direction of Britain for a generation.
What are the dates?
On 19 May Sir Keir Starmer will host a summit in the UK with EU leaders where he will announce details of a Brexit reset deal.
On the table is a new defence arrangement but also plans to remove barriers between the UK and its largest market.
About seven weeks later Donald Trump’s 90 day suspension of new tariffs will come to an end on 8 July.
That date has become an unofficial deadline for the UK and US to conclude a new trade deal. While the deal would be unusual in that it largely focuses on future growth industries such as biotech and artificial intelligence, it would aim to remove almost all tariffs.
The UK stuck in the middle of a trade war
While Sir Keir keeps repeating that there is no need to make a choice the growing evidence is that he will have to do so, and given the dates pretty quickly.
One issue is that Trump appears to be determined to have a trade war with the EU and is treating it similarly to China.
In fact, the tariffs threatened on the EU were double the 10 per cent for the UK to 20 per cent. Already issues like signing up to EU energy regulations on carbon levies.
But with Trump seeing bas on chlorinated chicken and hormones in beef as a trade barrier/ tariff equivalent, the UK will be under pressure to roll back on food safety regulations too.
As the European Movement noted: “If the UK decides as part of a deal to allow in products not accepted for EU market, that makes a food safety/SPS/veterinary deal with EU more difficult - EU would need to know those products could not enter its territory. That would be almost impossible to do. UKICE or ECIPE might have done some further work on more specific potential clashes. Trouble is we only have the vaguest idea what a UK-US deal might look like.”
Added to that JD Vance is already understood to be applying pressure for the tech industry, not least over repealing hate speech and online safety laws.
But if a US trade deal involved significantly laxer UK regulation of US tech companies - especially the treatment of data - than applies in the EU, that would likely create a further regulatory barrier to UK-EU trade and would certainly be a political issue which would damage trust and make EU less inclined to enter a closer relationship with UK.
Starmer must make a choice
One of Britain’s foremost international trade experts, Marco Forgione, director general of the Chartered Institute of Exports and International Trade, is convinced that it will be very difficult for the prime minister to achieve a significant Brexit reset and a trade deal on Trump’s terms.
He said: “A trade deal with the US could also lead to growing divergence between the UKand EU.”
And he warned that Northern Ireland, which currently still sits in the EU single market because of its land border with Ireland, will be caught in the crosshairs.
“The potential divergence caused by a possible economic agreement with the US might require a “reset” with the EU, especially with regards to Northern Ireland. All made more complicated if the EU imposes retaliatory tariffs on the US.”
Another expert, Chris Southworth, secretary general of the International Chamber of Commerce UK said: “A traditional free trade agreement with the US is not recommended.
“The UK has tried and failed twice to agree such a deal and, in the process, wasted 10 years when it would have been better to be more practical and build on areas of commonality and strength.
“The FTA format fails because there are significant areas of difference in consumer values and standards as well as policy. UK consumers do not want US firms running NHS health services and do not want US food standards [hormone beef or chlorinated chicken]. Equally, the US is reluctant to open up government procurement to UK companies.”
He went on: “There is an excellent opportunity to reset EU trade relations and strengthen cooperation. Given the EU is the UK’s closest market and 40 per cent of UK trade this should be a major priority.
“The larger economic opportunity is to remove all friction across the European trading system and start with aligning legal infrastructure across Europe and transform the trade environment between the UK and EU to become fully digitalised so trade is cheaper, faster and simpler for all businesses both in the EU and UK.”
But the PM is still optimistic
Sir Keir spoke to President Trump today and appears to remain optimistic about getting a deal done.
A Downing Street spokesperson said: “The prime minister spoke to the President of the United States Donald Trump this afternoon.
“The leaders began by discussing the ongoing and productive discussions between the UK and US on trade. The Prime Minister reiterated his commitment to free and open trade and the importance of protecting the national interest.
“The leaders also discussed the situation in Ukraine, Iran and recent action taken against the Houthis in Yemen.”
“They agreed to stay in touch.”
US threatens to walk away from Russia-Ukraine peace talks ‘within days’
U.S.-born citizen held by ICE in Florida jail
Campaigners and charities horrified by revelations about impact of Trump’s USAID cuts
Single-sex spaces for women will be ‘more dangerous’ after Supreme Court ruling
Bid to disqualify Reform’s Andrea Jenkyns from mayoral election
Trump expected to make UK state visit and visit King Charles in September
