Eighteen peers took part in a debate on a motion to take note of the future of United Kingdom trade and customs policy in the light of two recent white papers (Preparing for our future UK trade policy (Cm 9470) and Customs Bill: legislating for the UK’s future customs (Cm 9502)).
The Government approach
International Trade Minister Baroness Fairhead opened the debate. She focused her remarks on two Bills that have recently been introduced in the Commons: the Trade Bill and the Taxation (Cross-border Trade) Bill. They will be go through their Commons legislative stages in the new year, after which they will be debated in the Lords. She explained that the Trade Bill will “create powers that enable the UK to transition trade agreements that currently exist between the EU and other countries, and that the UK is part of via our membership of the EU… It will create the powers needed to implement the World Trade Organization’s Agreement on Government Procurement, known as the GPA, as an independent member instead of as part of the EU... [It] will also establish a new independent UK Trade Remedies Authority to provide a safety net to protect domestic industries from unfair and harmful trading practices and any unforeseen surges in imports which cause injury.”
The minister explained that the Taxation (Cross-border Trade) Bill (previously known as the customs Bill), deals only with matters of taxation. It will “allow the UK to charge customs duty on goods, including those imported from the EU; allow the Government to set out how, and in what form, customs declarations should be made; set out rules relating to the collection, administration and enforcement of import duty; and give the UK the freedom to impose additional rates of import duty, including those resulting from trade remedies investigations. It does this primarily by creating a new UK trade remedies framework to be overseen by the independent Trade Remedies Authority.” Full details of how the trade remedies framework will operate have not been determined, she added.
On future customs arrangements, the minister said that the Government would “be guided by what delivers the greatest economic advantage to the UK, and by three strategic objectives: continued trade between the UK and EU member states that is as free and as frictionless as possible; the avoidance of a hard border on the island of Ireland; and the establishment of an independent international trade policy. The Government are clear that cliff-edge changes are in no one’s interests. That is why we want a smooth transition, which is at the heart of the two published White Papers. It is also why we are proposing an implementation period: so that businesses and Governments—in both the UK and the EU—will have time to adapt.”
Support for staying in the Customs Union
Peers taking part in the debate were overwhelmingly of the view that a good customs arrangement would look very similar to the existing one, and indeed, that ideally the UK would not leave the Customs Union. Lord Kerr (crossbencher), a former diplomat who helped draft article 50, said the easiest way to solve the present problem would be to “reinterpret what Brexit means and to consider, as the costs of leaving become clearer, whether it might not be better to avoid the damage to our trade that will be done by leaving the customs union and the single market.” Former TUC chief Lord Monks (Labour) said the Government must ‘think again and look again’ at whether we have to exit the single market and the customs union. “Can we not stay in the European Economic Area? Can we negotiate a Norway-plus deal rather than a Canada-plus deal?” While not perfect, “If we are to stick to the result of the referendum, however, it is the only option that minimises the damage of Brexit, as others have said, and solves the Irish border issue.” Lord Liddle (Labour) said the Government was “prioritising the creation of an independent trade policy when it has no need to do so to respect the referendum vote”. Baroness Murphy (crossbencher) said that, “by abandoning the common market and the customs union, it seems to me that we are abandoning things that we have taken so much trouble to build up over the last 40 years.”
Lord Horam (Conservative) cautioned that “anything outside a customs union will have some friction. It may not be sufficient friction to light a fire, but it will be some sort of friction.” Lord Whitty (Labour) thought that, “during the transition period, it seems almost a no-brainer that, while we will have left the European Union, we should stay within the single market and the customs union.”
More questions than answers
Baroness Verma (Conservative), chair of the Lords’ EU External Affairs Sub-Committee, said it was ‘extremely disappointing’ that neither of the two options outlined in the Government’s customs white paper was presented with sufficient detail to allow her committee us o examine properly what the “new customs partnership” option would look like, because, in the Government’s own words, it is an “innovative and untested approach”. “Given that we have less than 16 months before we depart from the EU, it is clear that a whole plethora of questions need to be answered on what a customs framework will look like.” She added that her committee “has taken large amounts of evidence from businesses” and others, and “there were significant warnings that uncertainty and the slow progress being made would undoubtedly start to impact seriously on business investment decisions if the Government failed to ensure that real progress was made with the negotiations.”
Lord Leigh of Hurley (Conservative) worried about the effects of uncertainty. “I am a member of the Chartered Institute of Taxation, which reports examples of businesses already altering supply chains, as that is the only way at present to plan with any certainty. For example, stock currently sold by the UK to European customers will now be warehoused within the EU to service that market, the stock never reaching the UK, having obviously been sourced from abroad. In that way, firms seek to avoid potential barriers to trade that cannot be predicted accurately at this time. Lord Cope (Conservative) also felt uncertainty was having a harmful effect. “The Government must do all that they can to bring greater certainty to the situation as soon as possible,” he said.
The business perspective
A number of peers used examples of companies they are aware of to illustrate the difficulties exporting businesses could be faced with after Brexit. Baroness Golding (Labour), once an MP in the Potteries, said the ceramics industry had expressed to her “its concern over the dumping of imported goods below their normal value, such as their domestic price. Given that distorted economies such as those of China and Russia will be included in our market, strong parliamentary input to our trade rules will be essential to enable the industry to keep the Government up to date with what is happening throughout our country.” The minister, Baroness Fairhead, replied that the Government would aim “to provide transparent thresholds for the application of measures” and an economic interest test “will provide a balance between regions, primary producers, downstream industries and consumers.” A ‘lesser duty rule’ will “ensure that effective remedies are in place without imposing unnecessary costs.”
Lord Whitty (Labour) referred to a briefing session that had been arranged earlier in the day by the CIOT, where a number of customs, VAT and excise experts met with parliamentarians to inform discussion around the proposed legislation. “At lunchtime I, along with a number of other noble Lords, attended a seminar of customs experts. The message that came across was somewhat complicated and, in some ways, depressing. For businesses… there will almost certainly be additional administration and significant costs. There may be serious delays and businesses may eventually be faced with a deterrence to trade. A lot of those companies are not aware of the complexities, because for 40 years they have not had to operate with them. Many small companies export only to the European Union and to nowhere else, and they will be faced with much more complex transport, customs and taxation procedures than they have been used to. They will also have to face the rules-of-origin requirements.” He said this would be “a nightmare for a lot of small businesses, and they need taking through it very carefully”.
Lord Whitty added that he had met a trade association representing small, sophisticated electronics companies that have specialist markets in the EU, multi-sourced components and multinational supply chains. “One company produces ventilation equipment in Britain and exports it to the EU, but 30% to 40% of its components are made in the EU. It asks questions such as: is there a minimum level of EU content in order for tariffs not to be charged, or for administrative costs to be avoided? What if the components are not of EU origin—as some still are—but are partially EU and partially third country? Is there a minimum level at which that has to be declared? How will origin composition need to be recorded and reported, and with what level of evidence? Will that company suffer duties—if duties there are—on the total value? What records will it need to keep? What checks will it face? Will that mean delays at Dover, Calais or Boulogne for exports or component imports? The company is worried about such things, and about continuing acceptability of the product standards to which it has hitherto worked; hence, it is also worried about continued regulatory equivalence. It and hundreds and hundreds of other exporting companies require clarity, they require it soon, and they need the Government to start that mentoring process now and take them through it.
Peers were concerned about the damage that tariffs could do to British business. Liberal Democrat Treasury spokesperson Baroness Kramer said that, “The 10% tariff that would be applied to our automotive sector under WTO rules would frankly destroy most of the automotive industry in this country… Tariffs of 35% for the dairy industry would clearly be devastating. There are not many ways to overcome that because any attempt to subsidise gets us in trouble with state aid rules.” Baroness Quin (Labour), a former minister for Europe, worried that, “in a harsh trading environment any changes to tariffs or non-tariff barriers—sometimes even marginal changes—or suddenly becoming penalised by the rules of origin… can be the difference between export success and failure.”
The rules of origin rules were also picked up by Kramer: “Talking a little off piste at the [CIOT-organised] meeting we were at today with one of the food producers, who works for a major company, he tried to explain to me that to complete rules of origin he has to account for every drop of milk in making his food product if he goes through a customs barrier. That milk could come from three or four different places, but every single drop has to be tracked. It is the same for the sugar, the flour and every other component that goes into those foodstuffs. The challenge, burden and administrative demands that that leads to are huge: export declarations, licences and other kinds of supporting evidence. They are myriad and a nightmare.” She then explained how rules of origin interact with free trade agreements. “I take the automotive sector again as a typical example. Under free trade agreements around the world, the zero tariff is available only to a country that is exporting an automotive product that has 60% local country content. The highest UK content for any car we export is 43%. That is unusual; the average is 10%. The industry says that it is pretty much impossible to increase the number of suppliers in the UK to push up that number. They have been trying to do it for years. Economies of scale matter. For example, if you are going to produce ball bearings for your cars, you will do it in one place for the whole of Europe. You cannot afford to put up a separate supplier for a product of that kind in the UK. I do not know how many other products this applies to. I gather it is a really serious issue in the food processing industry. We need to understand how all that works. Here is another issue raised in the meeting today. Perhaps the food product a producer is selling meets rules of origin content, but say it is a flour-based product, we have a bad harvest and at the last minute he needs to switch his source of supply. He might then fall foul of rules of origin content and suddenly face a tariff. All these questions have to be answered so that businesses can plan and deal with them.”
Regulatory divergence versus frictionless trade
Baroness Kramer said that, at the meeting with customs specialists, “it was absolutely evident that the only way to have frictionless trade is to have an identical process to the one we have today, with no change whatever. That is the precondition for frictionless trade… Once we move out of the customs union, we move into a regime in which divergence constantly increases: we go from the moment of least friction to moments of increasing friction.” She said the Government needed to make “a realistic and detailed assessment of those costs, the burdens that will be placed on businesses and the consequences for the ordinary people of this country.” She said the just-in-time concept was “critical to the economics and efficiency of virtually every one of our major industries. It underpins lower-cost production and makes the UK a place where it is viable to build a business.” Drawing on her experience as a Transport Minister, she described traffic movements in Dover as “like watching a ballet: a constant, unbroken stream of trucks rolls on to and off ferries. There are no checks whatsoever at Dover because the friction that they would introduce to the system would destroy just-in-time and the businesses that it underpins”. She added: “For people who do not understand how just-in-time works, I have talked to some of the automotive industries: product leaves the European factory at 8 am, to be in the UK production line at 11 am. It is that tight; the consequences of any disruption are extraordinary, but absolutely no one has produced a viable scheme that does not disrupt those timings.”
Kramer went on to draw further on the CIOT’s briefing. “This is the whole issue of regulatory alignment. Again, a very good example was given at the meeting today. What do you do if the EU is completely resistant to the idea of GM food? I understand why, but we are quite likely to make trade agreements with countries that would permit GM to come into the country. If any GM maize is fed to a chicken, that chicken cannot be sold to the EU. How do you track the detail, demands and complexity of this? It is astonishing.”
Baroness Quin made a similar case. “It has often been put to us that, outside the EU, we will be free to make our own rules, but if we want frictionless trade, it cannot be in our interest to have regulatory divergence from the European Union. Regulatory divergence may give us more theoretical freedom to do our own thing, but it will not lead to frictionless trade and we cannot have both.” Describing himself as a ‘reluctant but optimistic Brexiteer’, Viscount Waverley (crossbencher) said that “Brexiteers should understand, and accept, that frictionless trade will be perceived by some as though we are still in—but surely this is a small price to pay to ensure overall readiness.”
Lord Kerr felt regulatory alignment was key to how good a deal with the EU we will eventually get. “The greatest obstacle is not tariffs but differential standards. In services, of course, the greatest obstacle is regulatory misalignment. It is not just in Ireland that the issue of regulatory alignment is important; it is the key to the whole negotiation.”
Transition period or implementation period?
There was some disagreement about whether the two year transition period was really an implementation period. Lord Leigh of Hurley felt that it was a two-year implementation period “to give sufficient time for businesses to plan and for Governments to implement the new regime. But Lord Whitty felt that “a transition period needs to be a transition period; it is not simply an implementation period, because we will not have agreed what exactly we are going to implement. It needs to be, in effect, a standstill period, during which we can negotiate the full details of a free trade agreement—assuming that we have a bare-bones agreement to start with. It will also probably be used to negotiate a full-scale security agreement. In addition, in the context of this debate, we will need that time to develop and test new customs procedures and the systems they involve on this and the other side of the Channel, and to familiarise business with them, staff them up and make sure that they operate properly.”
Lord Kerr saw few good options. He observed that “the standstill agreement that is being talked about is one that the EU has been offering since April. It is in its April guidelines.” But it would mean “we would no longer have a vote in Council, judge or Commissioner and we would no longer have Members of the European Parliament, but we would agree to respect, in the Prime Minister’s words, all the rules and regulations of the EU during that period. We would be enjoying, if that is the word, a sort of colonial status. It might be politically a little ignominious but economically very convenient”. He felt it “would be wrong to call it a transition or an implementation period because, by the time it ends in 2021, we would have nothing agreed to transition to and nothing to implement. It cannot therefore provide the certainty that employers and investors now seek.”
Lord Horam was one of many peers who felt a transition period was needed because a detailed agreement could not possibly be finalised in the time available under Article 50. “The transition period really has to be based on the status quo. To do otherwise would simply mean two sets of negotiations; and one set is bad enough, but two would be ridiculous. That was implied in the Prime Minister’s speech. Not only that, but it will need some legal underpinning. That period cannot exist in thin air, so I expect that there will be a Bill in the next calendar year that we will have to discuss in the House. I hope there will not be too many attempts to put red lines into that necessary Bill, because it is important that we get through it.”
The Irish border
Baroness Quin felt the Government “should admit that the current arrangements are better than the alternatives, certainly with regard to the situation in Northern Ireland and the Republic. The best way to resolve the concerns of the Irish Government and those of the DUP and Northern Ireland is to maintain these arrangements, not destroy them.” Lord Horam agreed, saying that “to remain inside the customs union is also the only sure way of solving the Irish question.”
Lord Empey (UUP), a former minister in the Northern Ireland Assembly, sought to put things in perspective. “The amount of trade done across the Northern Ireland border is, in European terms, minute. It is done by a relatively small number of significant companies, allied to a lot of local people, particularly around agriculture, produce and animals.” He thought we could have “a customs relationship between Ireland and the rest of the United Kingdom because 90% of Ireland’s goods go either to or via the UK, which is a land bridge across to Europe. We could also guarantee that we will not allow the integrity of the single market to be damaged by people who try to subvert it by bringing in goods that are not up to standards, or to use the Republic of Ireland as a back door in. All of that is possible; it is also possible, through working with the relevant customs authorities and other intelligence bodies, to communicate between Brussels, ourselves and Dublin so that we can find a way through.”
Viscount Waverley was interested in “the possibilities and benefits of an integrated digital economy platform in relation to cross-border challenges.” “I understand that the Global Coalition for Efficient Logistics—GCEL—stands ready to demonstrate the potential of its digital technology in respect of trade between Northern Ireland and the Republic, in order to enable trade to take place between the two in a manner satisfactory to all parties and without the need for a physical border.” He offered to arrange a meeting between GCEL and the minister.
Lord Campbell-Savours (Labour) was also interested a technological solution, saying that “the proposed vehicle number plate recognition system might work in Northern Ireland and perhaps at the Channel ports.” He added: “I personally had some experience of this in the early 1970s, before our entry into the Union, when we would register at the Mont Blanc tunnel entrance and clear at Cluses, 40 kilometres further up the road. You could, with trusted trader status, run a few Cluses-type operations in Northern Ireland as an alternative to destination clearance—which, I understand, is what the Government believe will happen.” However he did see “three major problems: first, white van evasion; secondly, number plate switching on trailers, which is very easily carried out; and thirdly, of course, the DUP.”
The minister, Baroness Fairhead, replying, said: “The Government have been clear that we seek to avoid a hard border in Northern Ireland. This is one of our key strategic objectives for any customs arrangements. We know that the movement of goods across the land border is key to the economies of Northern Ireland and Ireland, and both the UK and the EU recognise the unique circumstances on the island, so we welcome the European Commission’s call for flexible and imaginative solutions. We remain committed to the Belfast agreement and the common travel area, and I know that there are ideas on small businesses, when 80% of their trade goes across border.”
The challenges of negotiating trade deals
A number of peers warned that negotiating new trade deals would not be an easy task. Baroness Verma referred to “a massive task of necessary compromises and demands”. Lord Kerr, the former diplomat, said that: “Trade diplomacy is a form of mercantilist arm-wrestling. We have seen that already in the reactions of Australia and New Zealand to the division of quotas agreed between us and our European Union friends. They were instantly rejected by the Australians and the New Zealanders. It is not simply a question of dividing our share from their share; the third country will want to grow the cake.”
Baroness Henig (Labour) said her work on an inquiry into the Transatlantic Trade and Investment Partnership had “opened my eyes to the fundamental and often brutal realities of trade negotiations: the vested interests to be accommodated; the complex range of issues to be managed; and the balancing of producers’ and consumers’ interests. Most important of all was formulating a coherent communications strategy to explain all the bargaining and concessions to domestic interest groups and to the general public. When we reported, we noted that despite the great benefits that TTIP was likely to bring to Europe and the UK, members of the EU were comprehensively losing the publicity war to critics of the deal.” She observed that, “when we were a member of the EU, a lot of the politicking and contentious lobbying went on in Brussels. Of course, the UK was shielded from a lot of that and was able to blame Brussels when it was not possible to accommodate a lot of the interests. That will no longer be possible; the Government will have to face the full force of all the lobbying and competing business interests from all quarters.”
Baroness Murphy (crossbencher) said trading on WTO terms alone was not something to be desired. it was “misleading to claim that the rest of the world trades with the EU on WTO terms. The Institute for Government has pointed out that all big countries have bilateral agreements on customs co-operation, data exchange and standards. Only seven countries in the world trade with the EU on WTO terms alone, and they are pretty small fry, such as Cuba and Venezuela, which are rather disheartening bedfellows. Reverting to WTO rules is not simple, as we have already heard. It requires a division of EU import quotas, for example on beef, lamb and butter. Big food exporters such as Brazil, Argentina and America are unlikely to be thrilled with that, nor indeed if we got them would our farmers be very thrilled. The WTO proceeds by consensus among its 164 members. It makes negotiating with the 27 EU countries look easy peasy, does it not?”
Lord Price (Conservative), a former trade minister, said: “Our first step must therefore be to try to maintain what we already have. To ensure that there is no cliff edge and to make things as straightforward as possible for business, the Government plan to set out our independent schedules at the World Trade Organization which will replicate, as closely as possible, our current EU schedules. This will provide continuity for businesses that trade with countries not currently covered by bilateral agreements, such as the USA, China, India and others.” He added: “I applaud the further consistency of trade that will come from rolling over or grandfathering our current EU third-party FTAs, EPAs and association agreements, as set out in the White Paper”.
But the Labour spokesperson, Lord Mendelsohn, had his doubts. “The Government have described transitioning as a “technical process” and essentially a formality. That is true if each country gives its consent… [but] with which countries do we have an agreement in principle to roll over the deal in its entirety and how many, and which, countries have notified us that they might wish to make modifications?” He continued: “We have to be straight about the rest of the world in respect of the WTO quotas. This is a zero-sum game. We have introduced the British policy of Brexit and thought that the rest of the world will just say, “That is wonderful”. There is no greater zero-sum game in international diplomacy and the exercise of national interest than in trade. Is it any surprise that America, Australia and countries in Latin America have objected to a simple carving-up of the EU quotas in the WTO, which we thought would be straightforward? This is going to be the permanent story. The idea that the USA is going to simply roll over and change all its markets to satisfy us for Brexit—I just cannot see it.”
Baroness Kramer said that conversations she had had suggested to her “that the Government have finally accepted that there cannot be a rollover: these agreements die and there has to be a new agreement put in place. Surprisingly, the various players on the other side of this picture are turning out to be much more difficult. Everyone assumed that they would simply sign on the bottom line, and they are not doing so. Again, a number of noble Lords referred to trying to split access quotas between the remaining 27 and the UK, but that is a minor problem. We are hearing that a number of the countries see this as a great opportunity to get much better terms than they had before. They intend to use a unique opportunity, not to walk away from it.”
Responding to the debate the minister, Baroness Fairhead, said that the Government “have placed emphasis on the transitional adoption of trade agreements. Countries potentially in scope of these types of agreement—around 40 of them—account for 13% of the UK’s trade.” In response to a question about which countries are a priority, she said “we are exploring what may be possible with partners, but it is too early to say what it will mean in a particularly country”. On services she added that “Services are an essential element of the economies of the UK and the EU, so we will be seeking an ambitious free trade agreement between the UK and the EU which will be of greater scope and ambition than any preceding agreement, because we realise how important it is.”
The question of whether HMRC would be adequately resourced for Brexit was raised once again. Lord Cope asked whether the new customs declarations system was on target to be ready by March 2019. (It was, said the minister.) Cope continued, referring to the CIOT-hosted discussion earlier in the day, “We were told this morning at the seminar to which the noble Lord, Lord Whitty, referred—I think I am correct—that customs declarations were likely to increase from 50 million a year currently to 300 million. That is an enormous increase. Clearly, the statistical arrangements and IT arrangements will have to be able to deal with that… It is also true that many smaller companies will be involved in such matters for the first time and will need help from Her Majesty’s Revenue and Customs and others. Applications for accreditation of the authorised economic operator are now apparently taking about a year to process. That is unacceptable, particularly if the so-called self-assessment customs declarations are to be confined to those with full AEO status, although I hope that that will not be the case. That is particularly serious, of course, if there is no deal—but it is essential in any case, even if there is.”
Lord Leigh was also concerned about authorised economic operators. Negotiating the mutual recognition of AEOs is a must-have for both category (S) for security companies and category (C), which grants customs simplifications., he said. “I make a plea for SMEs to be offered an “AEO lite”, as many of them, as the noble Viscount said, have never prepared for a customs exit or entry clearance and have never filled out the forms, although these days you do not fill out the forms; you make an entry on a website. Otherwise, many SMEs will struggle for AEO status. When I looked into this, to my surprise I found that only 600 companies in the UK have AEO status—all of them very large organisations.” Baroness Kramer thought that there was a reason why so few UK companies have signed up to the AEO: “It is extraordinarily complex and delivers very little.”
Lord Campbell-Savours quoted the concerns of the editor of the Freight Business Journal, who had said: “One nettle that the UK may have to grasp in the run-up to Brexit is the shortage of trained customs officers … the Government lost no time in downsizing HM Revenue and Customs capabilities in this area, removing trained officers from many ports and putting a good proportion of those that remained at its centralised operation in Salford … France now has 35 times as many customs officers as the UK … And it’s not only frontline strength that has been reduced. Many … of HMRC’s top level managers with trade expertise have now retired”.
The ability of EU ports to process UK exports was also raised. “Leaving the EU without a negotiated agreement will necessitate other EU countries having infrastructure in place for the two-way process of importing and exporting to work effectively. Is there any evidence that such preparations are under way?” asked Viscount Waverley. “What is being anticipated, by whom, and at what cost over what period? From what I understand from the excellent briefing this morning, the EU is not expected to have its systems ready until 2025—a point made by the noble Lord, Lord Whitty. So even if we were to enjoy a transition period of two years, it would take us to March 2021. What is the process that would be enacted during the period 2021 to 2025?” Lord Whitty also noted this point, saying “we will need some fairly hefty work on both sides of the channel to ensure smooth, let alone frictionless, trade.” Lord Campbell-Savours asked whether discussions were now taking place with the French, Belgian and Dutch authorities about what will happen with trucks being held in stacks going into Ostend, Dunkirk, Calais and the Hook of Holland? The minister said they were.
Taxation - Making Tax Digital and trade promotion
Lord Leigh noted “that the important Making Tax Digital project, which involves important changes to submission, record-keeping and VAT reporting, is due to be implemented at almost the very same time as the Article 50 two-year period comes to an end… Can the Minister say whether the indirect tax industry, and indeed HMRC, will be able to cope with such a confluence of change?”
Lord Empey observed: “We do not incentivise companies to trade, but we could use the tax system. A simple matter, for instance, is that the Institute of Export and International Trade provides qualifications for people in exporting. Your Lordships would not go to get your car fixed by a mechanic if that person had no qualifications, or to a dentist if they had no qualifications. Why do we risk the farm—risk the company—on people trying to export if they have no qualifications? We do not give a tax incentive to companies to encourage people to take that training.” The minister, Baroness Fairhead, responded that “The Government are trying to create the right environment. For example, the recent Budget acted on business rates, increased levels of infrastructure investment, boosted R&D spending and lay the foundations for the UK to become a world leader in new technologies.”
Lord Mendelsohn, the Labour spokesperson, said that transparency, public consultation and scrutiny would be important to ensure that a future trade policy “has democratic legitimacy and will boost growth in a way that is more positively felt across all sections of society”. He said it looked like a missed opportunity “that the Trade Bill itself includes no provisions at all in this area”. The minister, Baroness Fairhead, replied that “the UK remains committed to a transparent, fair and rules-based approach to international trade and we are inviting views on that… We will be involving Parliament, the devolved Administrations and the devolved legislatures, as well as local government, business, trade unions, civil society and the public from every part of the UK, because they must have an opportunity to engage. Since the publication of the White Paper, we have been engaging with a range of stakeholders around these issues and will be looking to benefit from best practice across the world. We understand that we do not hold all the answers and we are committed to taking into account all views.”