New Withdrawal Agreement

Deal Comparison Summary – Main Changes

Sources: Direct Legal Texts and House of Lords and Commons Library briefings and analysis.

Withdrawal Agreement


  • No longer contains provisions for UK to maintain customs area with EU
  • Northern Ireland (NI) remains in UK customs zone, applies EU customs code for certain goods. European Commission has explained that this would avoid “any customs checks and controls on the island of Ireland”
  • Non-EU/UK parts/goods that will not be subject to commercial processing (finishing) in NI, may have EU customs code applied – subject to Joint Committee.


Single Market

  • “Level playing field” commitment for UK
  • Northern Ireland aligns on some rules for goods, including sanitary and phytosanitary (SPS) rules and in agriculture (some of these SPS rules/differences already exist)



  • UK responsible for applying VAT legislation, ‘including collection of VAT and setting of VAT rates’
  • VAT exemptions and reduced rates that are applied in Ireland could also apply in NI


UK Internal Market

  • Nothing in protocol could prevent the UK from ensuring unfettered access for goods moving from Northern Ireland to other part of the UK
  • No duties payable by UK residents for movement of personal property


Consent Mechanism

  • Assembly in Belfast would vote on continuation of arrangements every 4 years. Arrangements remain if they receive a simple majority
  • If super-majority, arrangements remain for 8 years


Political Declaration

Northern Irish Backstop

  • Removed and Replaced


Economic Partnership: Goods

  • ‘Close relationship’ replaced with Free Trade Agreement


Economic Relationship: Regulatory Aspects

  • Removed


Economic Relationship: Customs

  • More specific measures – Trusted Trader Scheme, Customs co-operation and co-operation on VAT and fraud


Economic Relationship: Open and Fair Competition

  • Commitments remain to maintaining high standards in social and environmental measures, including adhering to international treaties (such as Paris Climate Change) and ‘in so doing, they should rely on appropriate and relevant (European)Union and international standards’


Foreign Policy: Operations and Missions

  • Stresses EU and UK sovereignty and case by case decision-making



  • More clarity and restriction on referrals to European Court of Justice (ECJ). However, will refer to ECJ where relevant.