How green do you want your UK-EU ‘reset’ to be?
The UK-EU reset talks on 19th May 2025 aim to review areas where closer co-operation can be pursued. Such talks were unthinkable even a year ago as the then Tory Government continued to distance the UK from Brussels to demonstrate that ‘Brexit was done’. This ideological conviction shaped the approach to cooperation with the EU and led to decisions that were opposed by business, that increased bureaucracy and that made future alignment more challenging.
In this blog we review the prospects for elements of the environment to be included in the reset by reminding ourselves of how divergence has emerged, why alignment is challenging, what green groups are calling for and where there maybe scope for greater ambition.
Diverging ambitions?
At one level EU-UK environmental policy divergence has been straightforward. As the EU kept changing, diverging just meant the UK standing still. In areas where the UK (be it the UK as a whole or England, Scotland, NI and Wales acting separately) had a clear idea of what it wanted, divergence could also be pursued more actively, not by drifting away but by openly changing track, by for example by establishing UK REACH and UK ETS.
However, divergence is cumulative: the further the UK moves away from the EU, the harder (both politically but also practically) re-alignment becomes as path dependency sets in. Moreover, until the July 2024 General Election the very thought of overt alignment with the EU in any area was toxic in Westminster. Regulatory alignment, if any, would be technical and not discussed openly, hence the quiet adoption of the same approach to tethered bottle caps.
Any form of alignment that raised the spectre of Court of justice oversight, a long-standing Brexiteer red line, was a complete non-starter. Hence, even in areas where alignment made sense to avoid the duplication of systems and processes, such as membership of EU agencies on chemicals or the environment, it was considered to be beyond the pale.
Whilst there is certainly scope for greater environmental cooperation it is uncertain how much appetite the negotiators have for it on either side of the channel. Environmental leadership appears to be faltering in the face of the ‘greenlash’ as shown in the UK by the roll-back of protected sites protection via the Planning Bill; and in the EU by further attempts to resist the greening of the Common Agricultural Policy.
Hence, our starting assumption is that there is no large appetite amongst political leaders for additional environmental action on either side of the channel.
What should be on the agenda?
Nevertheless, in this unpropitious context, environmental groups and think tanks on both sides have called for a narrow set of environmental issues to be discussed, and these are largely trade and governance related.
The Institute for European Environmental Policy and the European Environment Bureau have both called for environmental governance alignment through for example, cooperation on data-sharing, participation in the European Environment Agency, EIONET and the European Chemicals Agency.
The European Environment Bureau has called for alignment in four other key areas. First, on product standards, the EEB is calling for the UK to align with the EU’s higher regulatory protections from harmful chemicals and other environmentally driven product standards. Some of this already seems to be in train, as shown by the Product Regulation and Metrology Bill, which allows the UK to unilaterally align with EU regulations related to the environmental impact of products.
Second, the EEB calls for the EU and UK to join forces to tackle commodity-driven deforestation, to align circular economy rules, particularly around batteries and packaging waste, and to take a similar approach to the extraction and use of critical raw materials, which are central to renewable technologies and the green transition.
Third, the EEB calls for the formal linking of the UK and EU Emissions Trading Schemes. This item is potentially low-hanging fruit. Linking of the two schemes is the only area of environmental cooperation explicitly included in the TCA. The two schemes have similar designs and coverage although the EU scheme will widen with the entry into force of ETS2. So, if linking is to happen, it should be sooner rather than later. Here an immediate key barrier to their alignment is the increasingly diverging carbon price – the EU carbon price was on average $23 more per ton in 2024.
Finally, the EEB also suggests that the EU should take inspiration from some of the UK’s action to protect its coastal and marine environment – particularly on fisheries. The recent sand eel case where the UK successfully defended its decision to close waters to protect sea bird feeding grounds from over-fishing, is an example of the UK leading the EU.
What is missing?
As the EU and UK have similar climate ambitions the reset presents an opportunity for them to reiterate their commitment to net zero and to present a united front in international negotiations. The retreat of the US from international climate action certainly provides plenty of space and opportunity for greater EU-UK climate leadership and cooperation.
Nature is also notably absent from the reset speculation. Given the stated commitment of both the EU and UK to action on biodiversity and the EU’s adoption of a nature restoration law it is shame that this is not featuring as an area for cooperation. It has been officially recognized by both the EU and UK that biodiversity and climate change are intertwined and addressing one requires addressing the other. The race for net zero requires action on biodiversity. Nature is ignored at our peril.
But perhaps the key ingredient missing from the reset is bold and ambitious proposals for cooperation on the environment from ENGOs. The pragmatism and restraint in their calls for action is understandable given the context. But there is no guarantee of another ‘green wave’ and now maybe the moment for them to push for more EU-UK collaboration before this particular window of opportunity closes.
