Why is there so little Bregret and what might change that?

Polling shows relatively little evidence of ‘Bregret’ (Brexit Regret). There has only been a small shift towards people thinking that in retrospect it was the wrong decision to vote to leave, and were there another in or out referendum today there is no real reason to think that the outcome would be different to what it was in 2016.

This might seem surprising in view of the mounting evidence of economic damage and the evident lack of progress in the exit negotiations, and whilst it is quite possible that opinions will change as that evidence continues to grow I suspect that they are unlikely do so to any great extent. That matters, because only sustained and significant polling evidence that a significant majority of people now want to remain will change the political dynamic of Brexit, and if that is going to have any effect there is not much time left for it to happen.

One reason explaining the lack of Bregret goes back to the Referendum itself, which showed that the political saw ‘it’s the economy, stupid’ is not a reliable guide and, hence, the almost entirely transactional case for EU membership put by the Remain campaign failed to win enough support. Hence David Davis’ comment to German business leaders on Friday that it is a mistake to put politics ahead of prosperity was so widely mocked, since that is precisely what Brexit does.

However, that does not mean accepting what is now often said, that the vote to leave was about cultural identity rather than economics. For one thing, the NHS £350M claim, which certainly had some effect on the result, was, for all its well-documented flaws, an economic argument. More generally, apart from the fact motivations to vote leave were variegated (as were those of remain voters) and all single factor explanations are facile, culture and economics are not separate realms but interact in all sorts of ways. For example, during the campaign I heard some leave voters talk about issues of deindustrialisation and its malign effects on community. Their mistake, in my view, was to believe that EU membership was the cause of this and that leaving the EU would redress it – but my point here is rather that these voters made an explicit link between economics and culture.

So instead of thinking about the vote – and any propensity now for Bregret – in terms of economics versus culture I think it is better to think in terms of the gap between Brexit as a symbolic act and Brexit as a series of concrete legal, economic and political arrangements. In a post last May, I wrote about how there is the strange sense from those who argue most vociferously for Brexit that, somehow, Brexit won’t change anything. For example, I’ve seen Brexiters ridicule the idea that leaving the EU could mean needing visas to travel to the EU or that it could mean restrictions on air travel within the EU. Or that security cooperation with EU countries would be diminished. Or that European fruit and vegetables might be less easily sourced. Or that British people would face restrictions on retiring in EU countries. Or, possibly the most ubiquitous (and for those on the receiving end, most hurtful and infuriating) since the referendum, leave voters saying to their friends and neighbours from EU countries: ‘oh, but we didn’t mean you when we said there were too many immigrants’.

I don’t think that these things are necessarily to do with the idea that Britain can ‘cherrypick’ some parts of the EU that they like. Rather, what underlies such sentiments is two related things. One is a taking for granted of the familiar accoutrements of modern life without realising that they are the product of extensive, albeit largely invisible, institutional arrangements. So of course ‘nowadays’ planes fly us to wherever we want without restrictions, as if this were not the outcome of complex agreements such as the European Common Aviation Area (ECAA), and of course we can travel visa-free in Europe, as if that were not the outcome of freedom of movement rights. In some ways, Brexiters, who despise technocrats and bureaucrats and rail against extra-national decision making, also treat it as an act of nature that there are Europe-wide regulatory systems. But they are not an act of nature – they are concrete legal arrangements from which, on Brexit, British citizens can be excluded. There is no ‘of course’ about it.

The related underlying issue is that for many Brexiters the vote to ‘take back control’, with all its emotional resonance, was not thought about in concrete legal or institutional terms but as a kind of symbolic, feel-good act. That, indeed, is the implication of the Brexit White Paper which affirms (para 2.1) that sovereignty was never lost by EU membership but that “it has not always felt like that”.

What this now means is well-illustrated by the Channel 4 News report this week about how Grimsby, where some 70% voted to leave, is now seeking special exemption from any new tariffs or barriers for its principal fish-based industries. There have been similar calls from leave voting areas like Cornwall and Wales for special protection from the loss of EU grants and subsidies. The Grimsby report was widely mocked by remainers for indicating stupidity or hypocrisy, but I think it is better understood as an expression of this disconnect between Brexit as a symbolic act and as something that entails non-symbolic consequences.

The same kind of disconnect can be seen across many aspects of the ongoing Brexit developments. In my previous post I mentioned the example of those Brexiters who are blaming the EU for suggesting that hard Brexit means a hard border in Ireland, rather than being an inevitable consequence of Britain’s choice to leave the single market and customs union. That argument is being heard more and more widely as the border issue rises in public consciousness – for example, it was made very vociferously by the Daily Telegraph columnist Janet Daley on the BBC’s Dateline London show today.

The underlying thought process seems to be – these are not the consequences that we wanted from the Brexit vote and ‘therefore’ they are either nothing to do with that vote (denial) or are being unnecessarily forced on us by the EU and/or obstructive remainers (blame). It is true that there are some pro-Brexit people who do neither of these things and who not only accept that Brexit brings certain adverse consequences but, even, think that this can be seen as positive in terms of restoring national resilience. I have heard some leave voters say something like this, and it seems to be the view of, for example, pro-Brexit blogger Pete North and, in a different way, one of the Leave campaign’s biggest donors, Peter Hargreaves, the latter arguing that the insecurity caused by Brexit will be fantastic.

This, explicitly in the case of Hargreaves, is the kind of ‘Dunkirk’ vision of Brexit but – whatever else one could say about it – it is not the platform that the Leave campaign fought on, and it certainly does not seem to be how most leave voters see things. The Grimsby voters, for example, appear not to be embracing their new-found insecurity but are seeking an exemption from it, just as those making the Janet Daley argument want there to be no border controls once we have taken back control of our borders. But nor is there any evidence that they regret voting to leave the EU. Writ large, this is significant for those expecting widespread Bregret to put a last minute halt to Brexit. If the consequences of Brexit are either denied or blamed upon the EU, and not attributed to or accepted as resulting from the vote to leave, then no such Bregret can be expected.

If all this is right, then there are only two ways that Bregret could occur. One would be for the narrative to change and for leave voters to link the consequences with their vote. But this is extremely unlikely for basic, psychological reasons - there is a technical term for this which I can’t recall, but it is essentially because people don’t find it easy to admit that they have made a mistake. And that’s likely to be especially so if this is pointed out to them by precisely the disdainful ‘elitists’ and ‘experts’ who proved so ineffective during the campaign.

The second possibility is far more conceivable. It is to redirect the narrative of blame on to the leading figures in the Leave campaign. On to all of those who repeatedly and in various ways claimed that leaving would be easy, and would lead to sunny uplands where cake would be both had and eaten. And on to all those who failed to mention, or denied, the consequences on things as diverse as nuclear medicine and the Irish border. In short, it is far more likely that leave voters will accept the proposition that they were fooled by politicians – as indeed they were – than that they fooled themselves. It is also likely to have far more traction than, for example, repeatedly insisting that the referendum was only advisory, or that only 37% of the electorate voted to leave. The idea that politicians lie is not, after all, an especially outlandish one nor is it an especially complex one. If leave voters – not all of them, but just, say, 20% of them – come to believe that they were lied to about Brexit then Bregret becomes a possibility.

 

Update (19/11/17): Thanks to various people on Twitter for reminding me that the psychological concept that eluded me in the penultimate paragraph was cognitive dissonance. This was, indeed, what I was thinking of. However, Dr Garrett M. Morris has helpfully suggested that a better psychological concept to capture what I was trying to express is one that I was not aware of, namely the backfire effect.

By accident or design, a 'no deal' Brexit is getting closer

Theresa May’s commons statement on Brexit progress was a strange, confused and confusing mixture indicative of the strange, confused and confusing situation we are now in. On the one hand it showed some glimmers of realism about how in any ‘transition period’ ECJ jurisdiction would continue. That immediately attracted the ire of the Brexit Jacobins, such as the ubiquitous Rees-Mogg. Interestingly, there are signs that the Brexiters in the cabinet – Gove, especially – are more relaxed about this, reflecting, I suppose, the distinction between those who have the luxury of not having to take any responsibility and those who do. On the other hand, there was a much harder sense that May is preparing for a ‘no deal’ or 'Kamikaze' Brexit, and in that, of course, she has the unqualified support of the Ultras.

Why should ‘no deal’ even be being spoken of at this point? The answer seems to be a realization that the EU is unlikely to agree that sufficient progress has been made on phase 1 issues in order to progress to trade talks, and raising ‘no deal’ is perhaps designed to put pressure on the EU – or more accurately the individual member states – to give ground on this (and, by the way, even if they do UK ideas of what the future trade relationship would look like are unrealistic).

That in itself is absurd. The reason there has been no progress on phase 1 is almost entirely because the UK has failed to come up with anything remotely realistic on the issues of citizens’ rights, the financial settlement or the Irish border. And the reason for that, as ever, is because the Brexit Ultras won’t countenance anything realistic on the first two of these, whilst there is no obvious solution to the third of them. Moreover, progress has been made slow by the lack of British preparation prior to triggering Article 50, the time wasted by the election and by Tory infighting, the confused departmental structure created to handle Brexit, and the low-energy approach of David Davis to the negotiations.

What May is proposing to the EU probably leaves them with no option other than to decline it – at which point they will be accused of collapsing the talks and, possibly, giving a pretext for a UK walkout. If this is indeed about negotiating tactics then it is taking a massive gamble since it would, at the least, precipitate an immediate further collapse of sterling. In the longer run, using such tactics risks the possibility of a ‘no deal’ by accident – the political equivalent of nuclear brinksmanship going wrong. If that happens then the consequences will, of course, be economically and socially catastrophic – as outlined in an alarming, but by no means alarmist, post by pro-Brexit blogger Pete North.

Even accepting that Brexit is going to happen, there is absolutely no reason why it needs to be pursued in this way. I don’t just mean that a soft (single market) Brexit would avoid what is happening now. I mean that even a hard Brexit does not need to be pursued in this fantastically reckless and incompetent way. Having made its ill-advised choice, the government could fairly easily deal with citizens’ rights by not fixating on an ECJ role, and with the financial issues which are not, in the overall scheme of the costs of Brexit (and certainly the costs of a no deal Brexit) so great. And on Ireland they could at least develop some meaningful proposals, unlike the latest absurdity. Above all, there is absolutely no reason why they need to be in such a hurry. Given the complexities involved, there’s no reason in principle why the UK could not seek a much longer transition period and/or an extension of the Article 50 period. Whilst neither could be guaranteed, a more pragmatic and conciliatory stance from the UK could have made them achievable.

But for the ultras, if not for the government, the ‘no deal’ scenario is not something to be raised as a negotiating ploy – no matter how absurd and, had things been approached differently, unnecessary – it is the desired outcome. This is abundantly clear from the statements of many of them, including a contemptible piece by Bernard Jenkin, every sentence of which was a distortion of the truth, when it was not an outright lie. The overall message was clear – Brexit should be easy, and is only being prevented from being so by the vindictiveness of the EU and the machinations of remainers, in which conspiracy the Treasury and the CBI were included.

What Jenkin and his allies plainly want is for the talks to collapse and for a no deal Brexit to occur. Whether this is because they hope this will be a platform for a complete re-design of the UK along hard Right lines, or just because they are so viscerally bent of shape by their hatred of the EU is hard to tell. At all events, the government is now hostage to them, meaning that any halfway economically pragmatic approach to Brexit is politically impossible, and anything which is politically possible is economically untenable. So we are getting closer to ‘no deal’ even if, as David Allen Green argues, it is not inevitable.

It’s possible that this will change – a collapse of the talks would, as Jolyon Maugham suggests, throw into sharp relief just what a calamity ‘no deal’ would be, and might precipitate some parliamentary regrouping around sanity. But it is equally likely in such a scenario that a narrative of ‘EU punishment’ is whipped up, driving us headlong to the reality of ‘no deal’. If that comes about, those of us who can would be well-advised to make plans to emigrate, whilst those who can’t should stock up on tinned goods and install some good, strong locks.

It should never be forgotten that nothing remotely like the situation we are in – let alone that which might shortly unfold – is what was promised to those who voted to leave the EU. They were repeatedly told that leaving would be quick, easy and wholly positive. Every reptilian Brexit politician who piously invokes ‘the will of the people’ to justify this emerging national tragedy should be reminded of that.

A reply to John Redwood

John Redwood’s blog post (“Brexit policy and how to negotiate”, 1 August 2017) may be taken to represent the views of the more hardline Brexiters about the current situation. Indeed, to the extent that he is regarded by Brexiters as one of their leading intellectual lights it may be taken as representing their strongest case. This post is a reply.

Redwood: “I am glad the PM has made clear we will end freedom of movement and have our own migration policy on exit, as I reminded people here on this blog last week”.

Response: The PM’s position on freedom of movement is not clear, in fact, as Ian Dunt’s analysis (“No. 10 announcement on free movement completely without meaning”, politics.co.uk, 31 July 2017) explains. What is clear is that with her authority diminished by the General Election result, this and other policies are a matter of dispute within the government, with different ministers openly articulating different positions.

Redwood: “She has also clarified the issue of a transitional Agreement. The UK has not asked for one. We still have 19 months left to negotiate a proper Agreement. Negotiating a transitional one would require prior consent to a full Agreement, then allowing discussion of how to transition from the one to the other. It is not intrinsically easier to negotiate a Transitional Agreement than a permanent Agreement, and requires consent to where the two parties are going during transition”.

Response: This is correct both as regards the fact that the UK has not asked for a transitional agreement and as regards the incoherence of the position of those arguing for one without any clear idea of what the end state of the transition would be. However to say that there are 19 months left is to forget that the agreement needs ratification. So there are really more like 14 months left.

Redwood: “There are those in the Opposition, the media and business who seem to want to turn the EU/UK talks into a negotiation amongst ourselves about what we are trying to achieve. This is damaging to the UK’s official negotiating strategy, as it leads some in the EU to think that if they delay and prod the UK will change its mind and offer to carry on with budget contributions, freedom of movement and the other items that so favour the rest of the EU”.

Response: This is misleading in that it is those within the Tory Party and more especially the Cabinet who are conducting this internal negotiation, precisely because there is no agreement amongst them as to what the UK’s strategy should be. In this they have been extraordinarily irresponsible (to an extent without precedent in modern British political history) since they have already chosen of their own volition to trigger Article 50 without having reached such an agreement. What we are seeing, as we have since at least 2015, is the internal divisions of the Tory Party overriding any sense of care about the national interest, as pointed out by former Tory MP Matthew Parris in a recent excoriating article (“The Conservatives are criminally incompetent” The Times 28 July 2017 [£]). What is damaging to the UK’s negotiation from an EU perspective is their dismay that the UK has no clarity or detail. It is true that business groups are trying to open up the possibility of a transitional agreement, and the reason for that is obvious: businesses are well aware that an agreement within the Article 50 period is impossible and that without a transition there will be catastrophic effects for business. That is simply pragmatic business self-interest: what is surprising is that the current Tory Party are so remote from business and so pre-occupied with pursuing an anti-business policy in the form of Brexit.

Redwood: “MPs and others in senior positions in the Labour party keep changing their minds about membership of the single market and customs union, long after Parliament has voted decisively both to send the Article 50 letter and to exit both the single market and Customs Union”.

Response: Correct. The Labour position is completely incoherent.

Redwood: “Let’s have another go at reminding people what the UK has already decided. The people voted to leave the EU. They did so with both official campaigns pointing out this meant leaving the single market and customs Union. They voted leave to take back control, especially of our money, our laws and our borders”.

Response: This is simply untrue. The Leave campaign never clearly specified that voting to leave the EU meant voting to leave the single market and the customs union. Indeed many leading Leave campaigners including Daniel Hannan and Owen Paterson explicitly said that it did not mean leaving the single market. Moreover when the Treasury put out its long-term economic forecasts for Brexit in April 2016 it explicitly identified three variants of Brexit: continued single market membership, a free trade agreement, and WTO trading. There was never any sense given to the electorate that leaving the EU meant any one thing. This is a matter of record and to deny it is simply to lie. Indeed, the whole situation that the government now finds itself in derives from the fact that the Referendum result was a vote against membership of the EU but not a vote for what should happen next. That is absolutely fundamental to any honest discussion of Brexit, as is a recognition that the country was virtually split down the middle by the Referendum and the need, therefore, to find a way forward that reflects this.

Redwood: “Remain supporters then forced legislation and Parliamentary votes to test out the will of the people. Parliament voted overwhelmingly to leave the EU. The Commons since the election has voted to leave the single market and customs union as part of that, as was always implied in the previous Parliamentary votes”.

Response: ‘Forced’ is a peculiar way of putting the fact that as a matter of law a Parliamentary vote was required, but the fact of the result of that vote is not in dispute.

Redwood: “Some Remain supporters now want to invent a Transitional Agreement, requiring the UK to go on paying budget contributions, accepting freedom of movement, and continuing to accept new EU laws. This is not government policy, and is clearly against the wishes of the people as expressed in the Referendum”.

Response: The idea of a transitional agreement comes from Cabinet Ministers, such as Philip Hammond, who may have supported remaining in the EU but now accept that the UK is leaving. Whatever its merits, it cannot be said to be either for or against the wishes of the people as expressed in the Referendum, since they were never asked that question.

Redwood: “When asked why they want this, they usually argue that the other EU member states will damage their trade with us and our trade with them if we do not accept continuing features of EU membership. It is a cruel irony that the most pro EU are the most negative about the nature and likely actions of our EU partners”.

Response: This, to be both frank and charitable, is childish. It is the UK which is choosing to leave the EU, not the other way around, and that choice has consequences for the trading relationship. Redwood and Brexiters in general need to have the courage and honesty to take responsibility for that choice. If ‘we do not accept continuing features of EU membership’ then of course we do not continue to trade on the same terms. To coin a phrase, Brexit means Brexit. The issue isn’t about any benevolence or lack of it on the part of the EU, it is just a matter of reality: if the ‘will of the people’ is for the UK to be a third party state then that is what it will be, with all the consequences entailed.

Redwood: “They are also going to be proved wrong on this as on so much else about Brexit. WTO rules work fine, if the rest of the EU really does want to damage its valuable exports of agricultural produce and cars. Their more voluminous exports will attract far more tariff than our sales to them. Under WTO rules and international law the EU cannot stop companies and individuals in its territory buying and selling things with the UK”.

Response: This is a repeat of the usual ultra-Brexiter mantra and exhibits its usual detachment from reality by invoking the car industry (see here for discussion) and the UK trade deficit (supposedly an advantage, and yet we have a services surplus so what of that?) and failing to recognize that a far higher percentage of UK trade is with the EU-27 than EU-27 trade is with the UK. But more fundamentally it ignores the fact that tariffs are not nearly as important as non-tariff barriers and that WTO rules, far from ‘working fine’ would be a catastrophe for the UK as has been repeatedly explained for example in summary by me, but also by trade experts, by businesspeople, by journalists, and by the better-informed Brexiters such as Peter North who concludes: “One can say, unequivocally, that the UK could not survive as a trading nation by relying on the WTO Option. It would be an unmitigated disaster, and no responsible government would allow it”.

Final note: There is a huge irony here. It is precisely the fact that crashing out of the EU on WTO terms would poleaxe the UK that has driven the call for transitional arrangements from those trying pragmatically to salvage something from the year-zero ideologues such as Redwood. But for those of us who want to remain in the EU those ideologues are actually helpful, in that if they are successful in driving Britain to the brink of disaster they will assist our attempts to save our country from going over it, whereas the ‘pragmatists’ because they sound more reasonable are more likely to take us all the way to disaster, albeit more slowly. Of course it would be far better for Britain if we had not been put in the current position at all, and whatever now happens the Brexiters have irrevocably damaged our country, economically, culturally and geo-politically. Still, given that we are where we are, the position taken by Redwood (and his fellow ultra-Brexiters), dishonest and absurd as it is, might just help us to avoid the worst. If the ultras can defeat the pragmatists there’s just a tiny chance that the national catastrophe of Brexit will be averted.

[Updated with minor edits and reformatting, 2 August 2017] 

The myth of the WTO option

When Theresa May said that “no deal is better than a bad deal” this was widely interpreted to mean that she would be prepared to see the UK trading on WTO terms if necessary. It bears saying, first of all, that if the UK leaves the EU with no deal, it will have a calamitous impact well beyond trade – everything from airline flying rights to data transfer protocols would be affected, each of which is a hugely complex issue in its own right.

As regards trade, May is channelling what has been a persistent Brexiter myth going back well before the referendum. The myth is that WTO rules offer some kind of basic, entry-level framework for international trade which is sitting, ready and waiting, for the UK to ‘revert to’. Nested within that myth is another one, namely that what is at stake in international trade rules is primarily, or even solely, tariffs (a misunderstanding that remainers, too, are prone to). And nested within that is an idea that it is companies that do trade, not governments, so that international trade rules and agreements are a nicety if not an irrelevance.

That latter point – put to me by a member of UKIP just the other day – is hardly worth discussing. Apart from smuggling, no international trade can occur in the absence of some set of laws and regulations that transcend the nation state. The idea of free trade as a kind of state of nature as it appears within Brexit mythology has recently been comprehensively debunked by Professor Steven Weatherill of Oxford University writing on the EU Law Analysis blog. This is also why the Brexiter idea of sovereignty is so naïve: as soon as international trade occurs some diminution of sovereignty (in the sense that they mean it) is entailed. This applies quite as much to the WTO as the EU – arguably even more so in terms of transparency and accountability - and indeed the WTO is often criticised by activists on these grounds.

The other issues are much more complicated. The first is the complexity of unbundling the UK from the EU’s membership of WTO. Brexiters talk of this as ‘regaining our seat’, but far more is involved than moving around the table. A particular difficulty is that the EU’s current commitments to the WTO are unknown, as former WTO official Peter Ungphakhorn explains (along with much more detail on many other aspects of what is at stake):

“The only confirmed commitments on tariffs, quotas, and farm subsidies are from before 2004 when the EU had 15 member states. The EU has expanded three times since then, but in 12 years it has been unable to agree with the WTO membership on revised commitments.”

The word ‘quotas’ in this is a reminder that trading on WTO terms is not just a matter of adopting a certain tariff regime. Within that, countries have different quotas of trade, with different tariff levels above and below the quota. Thus unbundling the UK from the EU entails establishing what proportion of EU trade in a massive number of goods can be attributed to the UK. This is not just a mindbogglingly complex technical matter, although it is surely that, but also entails potentially acrimonious political negotiations not just with the EU but with other WTO members. Depending on which good is under discussion, different countries – some friendly, some hostile to the UK – will have significant interests at stake. If Brexiters complain about the difficulties of the UK ‘getting its own way’ with 27 other EU countries, they are in for a nasty shock when dealing with the 160+ WTO members. To get a flavour of what is involved, read Ian Dunt’s explanation of the issues using the example of trade in lamb. It makes for sobering reading.

In any case, tariffs and even quotas on trade in goods are not the main issues at stake here. The WTO framework has only limited applicability to trade in services and to non-tariff barriers to trade in both good and services (for an overview, see this briefing from Sussex University’s UK Trade Policy Observatory), and indeed has in many other respects been stalled since the failure of the so-called Doha Round that began in 2001 and was effectively abandoned last year. In this sense, the idea of WTO rules as a comprehensive trade framework is a misnomer. Brexiters often sneer at those who point to the dangers of leaving the single market and the uncertainties of creating free trade agreements by saying that countries such as the USA and China trade with the EU without either single market membership or a free trade agreement. The implication is that these countries simply trade on WTO terms. They do not.

In fact, such countries trade via a complex web of Mutual Recognition Agreements (MRAs) which are principally concerned with removing the non-tariff barriers to trade which are, in most cases, far more important than tariffs. Each MRA is a highly technical and, in most cases, lengthy document and the outcome of long periods of negotiation. The USA, for example, has some 135 MRAs with the EU, and China has 65. On Brexit with no deal, not only would the UK not have any MRAs with the EU but it would also have exited the EU’s MRAs with countries like the USA and China. For none of these MRAs exist as part of the WTO rules to which the UK will supposedly revert. It is for this reason that the pro-Brexit economist Peter North of the Leave Alliance writes:

“One can say, unequivocally, that the UK could not survive as a trading nation by relying on the WTO Option. It would be an unmitigated disaster, and no responsible government would allow it.”

So when Theresa May says that no deal is better than a bad deal she is either willing to entertain such a disaster or it is simply a negotiating tactic. But if it is a negotiating tactic it is a strange one since it is to say: do as I want or I will shoot myself in the head.

Update (16 February 2017): Since writing this post, I have been contacted by Peter Ungphakhorn (quoted in my post) to say that, whilst he agrees with the thrust of my argument, schedules for the EU-25 (i.e. its 2004 membership) were updated for goods in December 2016. For much more detail see his blogpost: https://tradebetablog.wordpress.com/2017/02/04/after-12-years-eu-25-goods-commitments/

I’m grateful for that information. It does reduce one aspect of the complexities I discuss (i.e. the commitments from which the UK must unbundle). Equally, the fact that it took 12 years to get to that point serves to underscore just how great those complexities are!
 

Update (11 February 2018): This blog erroneously refers to all trade agreements between EU and US (or China) as being MRAs. Only some are. But the point holds that these agreements augment WTO rules and thus it is a myth that EU trade with such countries is conducted solely on WTO terms.