What Is the Trade and Cooperation Agreement?

When the United Kingdom formally left the European Union's single market and customs union on 31 December 2020, it did so under the terms of the Trade and Cooperation Agreement (TCA) — a deal struck on Christmas Eve 2020 after months of fraught negotiations. The TCA governs the ongoing relationship between the UK and EU across trade, travel, security, and more.

Trade in Goods

One of the TCA's most significant provisions is that tariffs and quotas on goods traded between the UK and EU were eliminated — provided those goods meet agreed "rules of origin" requirements. This means a product must be substantially made in the UK (or EU) to qualify for tariff-free treatment; simply assembling imported components does not count.

However, the end of frictionless trade has introduced considerable new bureaucracy:

  • Customs declarations are now required for all goods crossing the UK–EU border.
  • Businesses must provide certificates of origin and comply with separate regulatory regimes.
  • Food and agricultural products face sanitary and phytosanitary checks.

The practical impact on smaller businesses trading with the EU has been significant, with increased costs and paperwork reported across a range of sectors.

Trade in Services

The TCA is considerably thinner on services than on goods. The UK lost automatic passporting rights that allowed British financial firms to operate across the EU. Each type of service now depends on a patchwork of national rules and mutual recognition agreements — many of which are still being negotiated or are absent altogether.

Travel and Freedom of Movement

Freedom of movement between the UK and EU ended with Brexit. British citizens can now visit EU member states as tourists for up to 90 days in any 180-day period without a visa, but working, studying, or living in EU countries requires individual member states' visas and permits. The European Health Insurance Card (EHIC) was replaced for new UK applicants by the Global Health Insurance Card (GHIC), which has more limited coverage.

The Northern Ireland Protocol and Windsor Framework

Perhaps the most politically contentious aspect of post-Brexit arrangements has been Northern Ireland. The original Northern Ireland Protocol — designed to avoid a hard border on the island of Ireland — created de facto customs checks between Great Britain and Northern Ireland, causing significant controversy. This was renegotiated into the Windsor Framework in 2023, creating a "green lane" for goods remaining in Northern Ireland and a "red lane" for goods moving to the Republic of Ireland and the wider EU.

Security and Data Sharing

The TCA includes provisions for ongoing law-enforcement cooperation, including access to DNA and fingerprint databases and continued collaboration through Europol. However, the UK lost access to the Schengen Information System II (SIS II), a key tool for cross-border policing.

The Ongoing Debate

The TCA is reviewed periodically, and both supporters and critics of Brexit continue to debate its economic and social consequences. Whatever one's view, understanding the architecture of the agreement is essential to following the continuing evolution of the UK–EU relationship.