The roles of provinces and devolved administrations in the negotiation and implementation of a Canada-UK trade agreement

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Following the vote on Brexit in 2016, the British Prime Minister Theresa May stated that its government hoped to reach a new trade agreement with Canada rapidly, to be modeled after the Canada-EU "Comprehensive Economic and Trade Agreement" (CETA) of which the UK will be excluded once it leaves the European Union. This agreement, interestingly, was the first Canadian free trade deal for which Canadian provinces were directly involved at every stage of the negotiations. In addition to trade talks have been initiated in good part by Quebec's Premier Jean Charest, provinces were deeply engaged, from the onset, in formulating the Canadian negotiating mandate itself. By contrast, it remains unclear what role the UK's devolved governments and parliaments (Scotland, Northern Ireland, and Wales) may have in negotiating, influencing or implementing such a future trade deal with Canada. Whilst there were mechanisms for the involvement of devolved nations in making European policy, the UK constitution has no clear principles or doctrine as to the roles that devolved nations should play in making trade policy. Moreover, the asymmetric nature of UK devolution complicates the involvement of the devolved governments and parliaments in trade negotiations. Since the UK and Canada do not function under the same constitutional principles, a comparative analysis of the roles subnational governments have played and could play in such trade negotiations is in order. It will offer important insights about the advantages, practicalities and conflicts that can emerge from the multi-level governance of trade policy, and about its implications for devolved responsibilities indirectly linked to trade (e.g. agriculture subsidies). It will also provide insights as to how a bilateral Canada-UK trade negotiation could produce new and innovative approaches with regards to the involvement of substate actors. The goals of this knowledge synthesis, accordingly, will be twofold: first, to allow for a better understanding of the differences between the two models, of their theoretical and practical justifications, of their strengths and weaknesses, and of the ways in which they could be reconciled in the wake of bilateral negotiations; and second, to draw lessons as to how the participation of provinces and devolved regions in future trade negotiations between Canada and the UK might unfold, but perhaps most importantly as to how it could be improved and maximized, within the realm of possibility, in both cases.