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

2016年英国脱欧公投后，英国首相特蕾莎·梅表示，英国政府希望尽快与加拿大达成新的贸易协定，以加拿大-欧盟“全面经济贸易协定”（CETA）为蓝本，英国一旦离开欧盟，将被排除在外。有趣的是，这项协议是加拿大第一项自由贸易协议，加拿大各省直接参与了谈判的每一个阶段。除了魁北克总理让·查雷斯特在很大程度上发起了贸易谈判外，各省从一开始就深入参与了加拿大谈判授权本身的制定。相比之下，目前尚不清楚英国的权力下放政府和议会（苏格兰、北方爱尔兰和威尔士）在谈判、影响或实施与加拿大的未来贸易协议方面可能扮演什么角色。虽然有一些机制可以让权力下放的国家参与制定欧洲政策，但英国宪法没有明确的原则或学说来规定权力下放的国家在制定贸易政策时应该发挥的作用。此外，英国权力下放的不对称性使被下放的政府和议会参与贸易谈判变得复杂。由于英国和加拿大的宪法原则不尽相同，因此有必要对地方政府在此类贸易谈判中所扮演的角色以及可能扮演的角色进行比较分析。它将提供重要的见解，说明贸易政策的多层次治理可能产生的好处、实用性和冲突，以及它对与贸易间接相关的责任下放（如农业补贴）的影响。它还将提供有关加拿大-英国双边贸易谈判如何在次国家行为体的参与方面产生新的创新方法的见解。因此，这一知识综合的目标有两个：第一，更好地了解两种模式之间的差异、其理论和实际理由、其长处和弱点以及在双边谈判之后如何调和它们;第二，就加拿大和英国之间未来的贸易谈判中各省和下放地区如何参与的问题吸取教训，但也许最重要的是如何在可能的范围内改进和最大限度地利用这两种情况。

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.