The UK's Trade Strategy – Considerations for UK businesses and regulators

We regularly advise both governments and industry and flag below aspects of the strategy which are particularly relevant to businesses and regulators.

Supply Chains

The UK Government will review its approach to responsible business conduct, focusing on global supply chains. The Trade Strategy highlights the government's continuing interest in forced labour– a global issue not limited to China.

New statutory guidance "Transparency in supply chains: a practical guide" has been issued to assist businesses comply with the Modern Slavery Act 2015.

There will be new opportunities for businesses to engage with the UK Government on supply chain issues, as the UK Government will:

• Launch a 'Supply Chain Centre' within the Department for Business and Trade (DBT), which will work with businesses to build supply chain resilience critical to the UK's security. Analysis will inform funding decisions of Public Financial Institutions (such as the British Business Bank).
• Establish an Economic Security Advisory Service to facilitate communication between business and relevant government bodies such as the Supply Chain Centre, Geopolitical Impact Unit, National Protective Security Authority, and National Cyber Security Centre.

Balancing Trade and National Security

The UK Government will launch a 12-week consultation on updating the definitions covering 17 sensitive areas[1] subject to mandatory notification under the National Security and Investment Act.  UK businesses operating in these areas – or businesses considering acquiring entities that do – should carefully consider the proposals and consider responding to the consultation.

Mutual Recognition Agreements (MRAs)

MRAs for trade in goods and services can tackle sector-specific barriers outside of economy-wide Free Trade Agreements (FTAs).

The UK Government will pursue more MRAs, focusing on countries and fields with most potential to boost growth. Fieldfisher has advised the UK Government and professional regulators on mutual recognition arrangements with several jurisdictions, and we recommend that:

• Goods: Industry bodies for highly-regulated/advanced manufacturing sectors identify opportunities for DBT to negotiate MRAs with key export markets.
• Services: Regulatory and professional bodies identify priority jurisdictions for their members with the aim of facilitating the professional mobility between those jurisdictions.

Services

The Trade Strategy acknowledges the UK's position as a leading exporter of services and has clearly committed to supporting services trade. The strategy also recognises the increasing role of services in facilitating exports of goods.

Due to the intangible nature of services, international commitments governing trade in services can be complex and difficult for business to navigate. Further, countries tend to be conservative in committing to liberalising services trade or in lowering behind-the-border barriers.

Our team includes former negotiators for the UK Government and are well-placed to support businesses in navigating the complex international regime on trade in services to help provide a competitive advantage in expanding in difficult markets.

Rules of Origin for Goods

The UK will engage with business on the benefits of joining the Regional Convention on Pan-Euro-Mediterranean preferential rules of origin (PEM). PEM could significantly simplify rules of origin for businesses that have goods supply chains in Europe and the Mediterranean region.

Businesses should consider whether they can lower customs duties or customs compliance requirements by optimising their supply chains and redesigning their goods to take advantage of tariff engineering.

Trade Defence and Trade Remedies

The UK Government intends to address economic threats such as strategic weaponisation of trade that go beyond traditional unfair practices (subsidies, dumping and surging imports).

The UK will strengthen its trade defence toolkit by:

• Consulting on new legislation to respond to deliberate economic pressure against the UK.
  • Other jurisdictions' implementation of similar legislation (see the EU's Anti-Coercion Instrument) suggests that measures could include suspension of tariff concessions or IP rights. Businesses with supply chains spanning potential targets of the new legislation should consider responding to the consultation to prevent inadvertent impacts.
• Introducing new legislation expanding the UK's powers to respond to unfair trade practices and protect critical sectors such as steel.
  • Existing safeguards on steel are set to expire in June 2026 and the government has launched a Call for Evidence seeking stakeholders' views on steel trade measures.

The UK Government will overhaul the trade remedies system by:

• Introducing legislation enabling the Trade Remedies Authority (TRA) to adopt a more assertive approach on issues like imports from countries with unfair market distortions.
  • UK industries facing unfair competition from economies such as China would be better placed to bring trade remedies complaints under the proposed legislation.
  • It will be important for exporters from such economies to engage early with the TRA's investigation to take advantage of potentially lower duty rates on account of cooperation.
• Improving business' access to trade remedies by reducing the cost and increasing the speed of applications.
  • This will help smaller traders in affected industries to contribute data to the TRA and better protect UK industry.
• Making the trade remedies system more accountable to Ministers, enabling swift and sufficient protections for businesses through government intervention when necessary.
  • The new trade remedies system will likely have more scope for executive discretion. Affected industries may be able to put forward broader policy considerations in making their submissions.

Wider Commentary

Fieldfisher LLP is a partner with the Centre for Inclusive Trade Policy, whose commentary can be found here and here.

Our Experience

With experts based in London, Brussels and China offices, our specialist International Trade team provides first-class strategic and commercial international trade law advice to global clients. With decades of experience advising both governments and businesses, we have a deep understanding of government processes, political dynamics and commercial drivers.