1. European Commission (2023) Population on 1 January, Eurostat statistics (accessed November 2023)
2. The UK’s population is approximately 67 million in comparison. Office for National Statistics (2021) United Kingdom population mid-year estimate (accessed November 2023)
4. For example, the successful international proliferation of Europe’s GDPR showed how EU democratic norms can shape global standards on privacy issues, and EU initiatives such as the EU-US and EU-India Trade and Technology Council; the digital partnerships with Japan, South Korea, and Singapore; or the Global Partnership on Artificial Intelligence at the OECD, have great potential to shape democratic technology standards globally. See Ringhof, J and Torreblanca, J (2022) The geopolitics of technology: How the EU can become a global player (European Council on Foreign Relations)
5. European Union External Action (2021) Human Rights & Democracy
6. The EU’s values are laid out in article 2 of the Lisbon Treaty (Treaty on European Union) and the EU Charter of Fundamental Rights. Note that the Council of Europe, which is not part of the EU but has a long tradition of co-operation with the EU, also shares the EU’s values of human rights, democracy and the rule of law. The European Convention on Human Rights protects the human rights of people in countries that belong to the Council of Europe, which includes all EU member states.
7. For example Scotland’s National Performance Framework, which sets out an overall purpose and vision for Scotland, is guided by our values to treat all our people with kindness, dignity and compassion, respect the rule of law and act in an open and transparent way. Scottish Government National Performance Framework (accessed November 2023)
8. Scottish Government (2023) Building a New Scotland: Creating a modern constitution for an independent Scotland
9. Young, A. L. et al. Europe’s Gift to the United Kingdom’s Unwritten Constitution – Juridification, in: Albi, A., Bardutsky, S. (eds) (2019) National Constitutions in Europe and Global Governance: Democracy, Rights, the Rule of Law, pp. 83 – 139, p. 83
10. ScotlandIS (2023) Scottish Technology Industry Survey 2023 and UKTN (2022) Regional spotlight: Why the future is bright for Scotland’s tech industry
11. See Scottish Government (2023) Scottish Energy Statistics Hub (accessed November 2023)
12. See Life Sciences Scotland Animal Bioscience, Aquaculture and Agritech (accessed November 2023)
13. See European Commission (2022) 2022 Strategic Foresight Report which focuses on the interplay between the EU’s twin transitions in a new geopolitical context. The 2023 Strategic Foresight Report focuses on reconciling wellbeing and prosperity as part of those transitions.
14. Scottish Government (2021) Steadfastly European: Scotland’s Past, Present and Future
15. Scottish Parliament, The path to devolution (accessed November 2023)
16. Welsh Government (2021) Reforming our Union: Shared Governance in the UK 2021
17. The Smith Commission (2014) Smith Commission Report
18. As set out in Scottish Government (2022) Building a New Scotland: Renewing democracy through independence, the range of voices recognising that Scotland is a nation within a voluntary partnership of nations, with a right to democratic self-expression and determination, is longstanding and reaches across the political spectrum.
19. What Scotland Thinks (2023) How would you vote in a second EU referendum?
20. For example, Scottish Government (2018) Scotland’s Place in Europe: people, jobs and investment or Fraser of Allander Institute (2016) Modelling the long-term impact of Brexit on the Scottish economy. Also, Scottish Government (2022) A stronger economy with independence and Fraser of Allander Institute (2019) Brexit and the sectors of the Scottish economy – 2019 update
21. For example European Union Achievements and benefits (accessed November 2023) and Freeman D, Meijerink G and Teulings R (2022) Trade benefits of the EU and the Internal Market (CPB). Also European Union Eur-Lex Summaries of EU legislation: Environment and climate change (accessed November 2023), Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far? and Scottish Government (2016) The EU Membership/Referendum Booklet
22. Scottish Government research identified that many of the areas most vulnerable to Brexit are in rural locations, in particular on the Scottish islands. Around half of communities in Shetland Islands, Na h-Eileanan Siar, Argyle & Bute and Dumfries and Galloway are amongst the most vulnerable communities in Scotland (20% most vulnerable data zones). Scottish Government (2019) Local level Brexit vulnerabilities in Scotland: Brexit Vulnerabilities Index (BVI)
23. UK Government (2014) Scotland analysis: EU and international issues
24. The UK has attended the meetings of the European Political Community, an initiative created in autumn 2022 as a platform for political coordination incorporating both EU and non-EU states. Former Prime Minister Truss made clear that her attendance at the first meeting was “not about moving closer to Europe” See Reuters (6 October 2022) UK’s attendance at Prague summit ‘not about moving closer to Europe’ PM Truss and Prime Minister Sunak confirmed that engaging with the European Political Community is “not about greater alignment. Under my leadership we’ll never align with EU law.” See UK Government PM speech to the Lord Mayor’s Banquet 28 November 2022
25. Scottish Government (2021) After Brexit: The UK Internal Market Act and devolution
26. Scottish Parliament (2016) Report on the UK Government’s Trade Union Bill in Scotland
27. For example, Turner, R (2021) The effect of Brexit on UK consumer protection law (Bird & Bird)
28. The Westminster government has by-passed the Scottish Government in the delivery of both the Levelling Up Fund and UK Shared Prosperity Fund and is delivering directly to Local Authorities. EU Structural Funds were seven year-long programmes; the replacement, the UK Shared Prosperity Fund, is three years. Department for Levelling Up, Housing and Communities, HM Treasury and Department for Transport (2022) Levelling Up Fund Round 2: prospectus and Department for Levelling Up, Housing and Communities (2022) UK Shared Prosperity Fund: prospectus
29. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
30. The Schengen Information System (SIS) is the most widely used and largest information sharing system for security and border management in Europe. As there are no internal borders between Schengen countries in Europe, SIS compensates for border controls and is the most successful cooperation tool for border, immigration, police, customs and judicial authorities in the EU and the Schengen associated countries. See also UK Parliament (2023) Lords Committee finds that post-Brexit UK-EU security cooperation is sub-optimal
31. Both the current UK Government and UK Labour are not seeking to join the European single market or customs union. See for example Keir Starmer’s speech of 4 July 2022: “A plan to make Brexit work” – Keir Starmer’s speech to the CER think tank and David Lammy’s speech of 21 June 2023: David Lammy MP Keynote speech (Trade Unlocked 2023 conference, June 2023). (The hyperlink is to a recording of the Trade Unlocked keynote speeches. David Lammy MP’s speech begins around 40 minutes into the recording).
32. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
33. See Chatham House (2016) Britain, the EU and the Sovereignty Myth and Taylor, R (2019) The ‘sovereign state’ is a myth. Europe’s nations are stronger when they band together (The London School of Economics).
34. Michel, C. Address by President Charles Michel to the European Defence Agency annual conference (European Defence Agency annual conference speech, 7 December 2021)
35. European Environment Agency (2022) Indicators (accessed November 2023)
36. The commitment is to reduce net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels, with an emphasis on ensuring cleaner energy, longer lasting and reusable products, and improving biodiversity and reducing pollution levels, and no net emissions of greenhouse gases by 2050. Source: European Commission (2019) A European Green Deal (accessed November 2023)
38. This is provided for by Article 14(2) Treaty on European Union
39. The allocation of seats in the European Parliament is based on the principle of ‘degressive proportionality’. Article 14(2) Treaty on European Union
40. Scottish Government (2022) Building a New Scotland: Renewing democracy through independence and Scottish Government (2023) Building a New Scotland: Creating a modern constitution for an independent Scotland
41. In the case of MacCormick v Lord Advocate, 1953 SC 396, Lord President Cooper said “The principle of the unlimited sovereignty of Parliament is a distinctively English principle which has no counterpart in Scottish constitutional law”, but outside the field of EU law the courts have not invalidated any Westminster Act. In the Reference of the United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Bill and European Charter of Local Self Government (Incorporation) (Scotland) Bill, the Supreme Court said “The Scottish Parliament…cannot qualify the sovereignty of Parliament, which is protected by a number of provisions of the Scotland Act”,  UKSC 42.
42. A referendum was held on 11 September 1997. Of those who voted 74.3% backed a Scottish parliament. After this result, the Scotland Bill was introduced in the Westminster parliament in December 1997. It became law as the Scotland Act in November 1998.
43. Scottish Government (2021) After Brexit: The UK Internal Market Act and devolution
44. The Scottish Parliament legislated for a Deposit Return Scheme in May 2020 to tackle climate change and reduce harmful littering. This policy area is entirely within the devolved competence of the Scottish Parliament. However, without the UK Government passing secondary legislation to exclude this devolved scheme from the United Kingdom Internal Market Act 2020, the scheme could not be delivered as planned in 2023. Scotland’s regulations would only apply to drinks produced or imported directly into Scotland but not to drinks that originate in, or pass through, other parts of the UK and the Scottish legislation could therefore not have full effect. The lack of an exclusion for the Deposit Return Scheme together with a number of conditions imposed by the UK Government on the operation of the scheme, made the scheme in its proposed form unviable and as a result it had to be delayed until at least 2025.
45. See Section 35 of the Scotland Act 1998
46. For example, Golub, J (2013) Far from dominating EU decision-making, France and Germany are among the least successful EU states at negotiating legislation and budget contributions (LSE blog) and Salamone, A (2019) Small States and Regions: Evolving Strategies in EU Politics, Chapter 4 in Hughes, K (2019) The Future of Europe: Disruption, Continuity and Change (Scottish Centre of European Relations) and Dooley, N (2022) Frustrating Brexit? Ireland and the UK’s conflicting approaches to Brexit negotiations (Journal of European Public Policy)
47. For example, Hughes, K (2020) Smaller States’ Strategies and Influence in an EU of 27: Lessons for Scotland (UCL European Institute)
48. Hughes, K (2020) Smaller States’ Strategies and Influence in an EU of 27: Lessons for Scotland (UCL European Institute)
50. European Parliament, MEPs (accessed November 2023)
51. Coereper is the ‘Committee of the Permanent Representatives of the Governments of the Member States to the European Union’. It comes from the French: Comité des représentants permanents.
52. Sørensen, C (2019) Who is Big in Brussels? (Think Tank Europa)
53. European Union / Finnish Government (2019) Sustainable Europe – Sustainable Future, Finland’s Presidency Programme 2019
54. Spanish Presidency of the European Union (2023) Priorities (Council of the European Union)
55. For examples of such grants and loans offered see European Commission Financial instruments: equity, guarantees, and loans (accessed November 2023)
56. Executive vice-president of the European Commission for European Green Deal, Interinstitutional Relations and Foresight, Maroš Šefčovič, is from Slovakia, with a population similar to Scotland. Executive vice-president of the European Commission for an Economy that works for People, Valdis Dombrovskis, is from Latvia, with a population of less than 2 million.
57. All EU member states are also members of the Council of Europe, which is not part of the EU but has a long tradition of co-operation and shares the same values as the EU. As a member of the Council of Europe an independent Scotland would have further opportunity for direct representation, including with appointments to the Parliamentary Assembly of the Council of Europe (PACE), which is the deliberative body and driving force of the Council of Europe, and to the Congress of Local and Regional Authorities of the Council of Europe (CLAR), which is responsible for strengthening local and regional democracy in the Council of Europe’s 46 member states.
58. Hughes, K (2019) Brexit, Scottish Independence and Leaving a Union (Scottish Centre on European Relations)
59. Scottish Government (2023) Devolution since the Brexit Referendum
60. Dooley, N (2022) Frustrating Brexit? Ireland and the UK’s conflicting approaches to Brexit negotiations (Journal of European Public Policy)
61. Hughes, K (2020) Written Evidence to House of Commons Committee on the Future Relationship with the EU. Note also that every council in Scotland voted to remain in the EU in the 2016 EU referendum: Electoral Commission (2019) EU referendum results by region: Scotland
62. BBC News (2016) Five facts from Scottish EU referendum vote
63. For example, the Office for Budget Responsibility forecasts indicate that the impact of Brexit on UK productivity will be 4% in the long run, Office for Budget Responsibility (2023) Brexit analysis (accessed November 2023)
64. McDonagh, B. I sat at the EU’s negotiating table for years – and saw how great Britain’s influence was, The Guardian, 22 July 2019
65. Scottish Government (2020) EU-UK negotiations: outcome analysis
66. For example, the UK Government has agreed to allow unlimited quantities of beef, tariff-free, into the UK after 15 years. In contrast, the EU–New Zealand FTA will maintain quotas permanently and apply a 7.5% tariff providing greater protection to EU farmers and food producers from New Zealand imports. New Zealand Foreign Affairs and Trade: EU-New Zealand Free Trade Agreement Annex 2A – Tariff Elimination Schedules (accessed November 2023) and New Zealand Foreign Affairs and Trade: UK-New Zealand Free Trade Agreement Annex 2A – Schedule of Tariff Commitments for Goods (accessed November 2023)
67. Scottish Government (2022) Free Trade Agreements: letter to UK Government
68. See Dawson J and Gower, M (2020) End of Brexit transition: Security cooperation (House of Commons Library) and House of Lords (2021) Beyond Brexit: policing, law enforcement and security. See also Letter 25 July 2023 from Baroness Hamwee, Chair Justice and Home Affairs Committee to The Rt Hon Suella Braverman KC MP, Home Secretary regarding the outcome of the Committee’s inquiry into Post-Brexit UK-EU security cooperation (UK Parliament)
69. Bradford, A (2019) The Brussels Effect: How the European Union Rules the World (Oxford Academic)
70. UK Government (2023) CE marking (accessed November 2023)
71. For trade in goods, the Trade and Cooperation Agreement does not eliminate customs procedures and controls, rules of origin in order to benefit from the abolition of tariffs, or the non-tariff barriers resulting from regulatory divergence. For services, the flexibilities offered by the Trade and Cooperation Agreement are not comparable to the ease with which services can be delivered in the European single market. See for example Du, J and Shepotylo, O (2022) TCA, Non-tariff Measures and UK Trade (Enterprise Research Centre). See also British Chambers of Commerce (2022) Brexit Trade Deal Not Delivering
72. Brexit put an end to the freedom of movement for both EU citizens in regard to the UK and UK citizens in regard to the EU.
73. For example, Casalicchio, E. 15 things Vote Leave promised on Brexit — and what it got, POLITICO, 24 December 2020.
74. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
75. See for example UK in a Changing Europe (2023) Where next? The future of the UK-EU relationship, Freeman, R et al. (2022) Unravelling deep integration: UK trade in the wake of Brexit (UK in a Changing Europe) and Kren, J and Lawless, M (2022) How has Brexit changed EU-UK trade flows? Economic and Social Research Institute Working Paper No. 735.
76. Scottish Government (2022) State of the economy: May 2022. Analysis excludes oil and gas.
77. The latest data shows that total value of Scottish food exports to the EU were 11% higher in the year ending June 2023 than the year ending June 2019. Despite this, many of Scotland’s food sectors have continued to see lower exports to the EU – including a 38% fall in exports of fruit and vegetables, and a 45% fall in exports of animal feed over the same period. Similarly, food imports from the EU into Scotland have slowed significantly over the same period – down 13%. This slowdown is particularly acute for fruit and vegetables, down 45%, and for fish and seafood, down 65%. HM Revenue & Customs (2023) UK regional trade in goods statistics: second quarter 2023 (last accessed November 2023). A detailed breakdown of the trade data in interactive tables is available here Regional trade data table – UK Trade Info
78. Bakker, JD et al. (2023) Brexit and consumer food prices: 2023 update (Centre for Economic Performance, LSE)
79. Fraser of Allander Institute (2022) Effects of inflation are not felt equally by all households
80. Dhingra, S. et al (2022) The Big Brexit - An assessment of the scale of change to come from Brexit, The Economy 2030 Inquiry (The Resolution Foundation)
81. Springford, J (2023) Brexit will cost UK workers about £1,300 in lost income each year, say experts (Centre for European Reform)
82. UK Government (2022) Impact assessment of the FTA between the UK and Australia: executive summary and UK Government (2022) Impact assessment of the FTA between the UK and New Zealand executive summary
83. Office for Budget Responsibility (2023) Brexit analysis (accessed November 2023) and Office for Budget Responsibility (2023) Economic and fiscal outlook (accessed November 2023). Many other reports from a wide range of respected economic researchers confirm the negative economic impacts of Brexit. For instance, the Centre for European Reform (2021) Cost of Brexit: October 2021 analysis found that in October 2021, UK goods trade was 15.7% or £12.6 billion lower than it would have been if the UK had stayed in the European single market and customs union.
84. For example, customs procedures and regulatory checks. National Audit Office (2021) The UK border: Post UK–EU transition period. Also, Bakker, JD et al. (2022) Non-tariff barriers and consumer prices: evidence from Brexit (Centre for Economic Performance, LSE)
85. House of Commons Environment, Food and Rural Affairs Committee Seafood and Meat Exports to the EU Eighth Report of Session 2019-21, House of Commons 1189, 29 April 2021.
86. Findlay, K. Scottish seafood Brexit woes have not gone away, The Press and Journal, 27 April 2022 and Fordyce, D. How Brexit has affected the Scottish seafood industry… and what’s yet to come, The Grocer, 10 January 2022
87. Farming UK News (2022) Scottish growers ‘angry’ with ongoing ban on selling seed potatoes to EU
88. UK in a Changing Europe (2022) Post-Brexit imports, supply chains, and the effect on consumer prices and Office for National Statistics (2022) Early insights into the impacts of the coronavirus (COVID-19) pandemic and EU exit on business supply chains in the UK: February 2021 to February 2022 (accessed November 2023)
89. Scottish Government (2021) Export statistics Scotland: 2019 (accessed November 2023)
90. Accounting for 8.4% of employment in Scotland and employing 220,000 people. Scottish Government (2022) Growth sector statistics (accessed November 2023)
91. Financial services exports to the EU in were 9% below 2019 levels in 2021 and 4% below 2019 levels in 2022. Office of National Statistics (2023) UK trade in services: service type by partner country, non-seasonally adjusted (accessed November 2023)
92. The decline in UK imports of services from the EU, such as financial services (-30%) and intellectual property (-13%), was most severe in 2021, with EU imports down 26% on 2019 levels, compared to a fall of 5% for imports of non-EU services. Although COVID may have been a contributing factor in 2021, the growth in UK imports of services from the EU continued to underperform, (by 7 percentage points compared to the growth seen for non-EU imports relative to pre-pandemic levels) in 2022. Office for National Statistics (2023) UK trade in services: service type by partner country, non-seasonally adjusted (accessed November 2023)
93. Ernst & Young Global Limited (2022) EY Financial Services Brexit Tracker: Movement within UK financial services sector stabilises five years on from Article 50 trigger
94. RIBA Architecture (2021) Brexit guidance: Recognition of professional qualifications between the UK and EU/EEA (accessed November 2023)
95. UK Government (2021) Selling services to the EU, Switzerland, Norway, Iceland and Liechtenstein
96. House of Commons Committee of Public Accounts EU Exit: UK Border post transition Thirty-Sixth Report of Session 2021-22, HC 746, 9 February 2022, page 11
97. UK in a Changing Europe (2021) The impact of Brexit on UK services
98. Scottish Government (2021) Brexit barriers facing artists and musicians
99. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
100. European Commission European Travel Information Authorisation System (ETIAS) (accessed November 2023)
101. O’Carroll, L and Allegretti, A. Dover ferry passengers advised to arrive early amid fears of summer-long disruption, The Guardian, 25 July 2022, Kelso P. Dover delays are a lesson in Brexit realities – and they may be about to get worse, Sky News, 5 April 2023 and Clinton, J. Dover queues begin to shorten after morning of long waits for travellers, The Guardian, 29 July 2023
102. The number of UK fishing related jobs fell 6% between 2021-22 compared to 2019-20 (Whale, S. Hook, line and sinker: How Brexit betrayed the UK fishing industry, POLITICO, 22 June 2023). See also Scottish Government (2022) The Contribution Of EU Workers In The Social Care Workforce In Scotland 2022 and The Institute for Government (2021) Supply chain problems
103. Scottish Government (2023) BICS weighted Scotland estimates: data to wave 91 (accessed November 2023)
104. National Records of Scotland (2023) Projected Population of Scotland (2020-based) (accessed November 2023)
105. Expert Advisory Group on Migration and Population (2019) UK immigration policy after leaving the EU: impacts on Scotland’s economy, population and society (Scottish Government)
106. Scottish Government (2023) Building a New Scotland: citizenship in an independent Scotland
107. Scottish Government (2018) Scotland’s place in Europe: people, jobs and investment, page 36
108. For example, The Nuffield Trust shows that the decision to leave the EU, and resultant lower EU migration, is exacerbating shortages in the NHS. McCarey, M and Dayan, M (2022) Has Brexit affected the UK’s medical workforce? (The Nuffield Trust)
109. European Commission The UK and Erasmus+ (accessed November 2023)
110. For example, between 2013/14 and 2022/23, over 20,000 Scottish higher education students and staff participated in studying, training and teaching in the EU under the Erasmus + programme. Source: Erasmus + UK National Agency Results and statistics (accessed November 2023). Over €140 million in Erasmus+ funding was awarded to over 1,100 Scottish projects between 2014 and 2020. Erasmus + UK National Agency Results and statistics (accessed November 2023)
111. European Commission (2018) Erasmus+ higher education impact study
112. Scottish Government / Welsh Government (2021) Joint statement on Erasmus+ exchange programme
113. Based on conversion carried out on 7 November 2023, when €1 converted to around £0.87 (rounded to two decimal places) from XE.COM
114. European Commission (2021) Erasmus+ 2021-2027 programme brings over €26.2 billion to support mobility and cooperation
117. Community Learning and Development are included in the Erasmus+ programme but excluded from the Turing Scheme. As a result, the absence of Erasmus+ will impact on the Community Learning and Development, which predominately supports disadvantaged groups.
118. See for example American Association for the Advancement of Science (2023) U.K. finally rejoins Horizon Europe research funding scheme, Sir Ball, J (2023) “Horizon Europe news comes not a moment too soon” (The Royal Society of Edinburgh), McKie, R. UK’s years out of EU Horizon programme did ‘untold damage’, say scientists, The Guardian, 9 September 2023 and UK Government (2023) UK joins Horizon Europe under a new bespoke deal
120. European Commission Funding & tenders (accessed November 2023)
121. European Commission Horizon 2020 (accessed November 2023)
122. European Commission Horizon Europe (accessed November 2023)
123. Scottish Parliament (2019) SPICe Spotlight: Financial risks to Scotland’s EU structural funds
124. Note that EU Structural Funds were seven year-long programmes; the replacement, the UK Shared Prosperity Fund, is three years.
125. Despite Scotland’s strong foreign direct investment performance within the UK (See EY (2023) Navigating Through Turbulence), leaving the EU has resulted in lower investment in the UK as a whole. There is growing evidence that firms are excluding the UK in their supply chains due to uncertainty over UK-EU trading relationship. The number of EU investment projects into the UK declined by 9% between the referendum and March 2019. See Breinlich, H. et al (2020) Voting with their money: Brexit and outward investment by UK firms (European Economic Review) and Du, J. et al (2023) How did Brexit affect UK trade? (Contemporary Social Science).
126. Springford, J (2022) The cost of Brexit to June 2022 (Centre for European Reform). Separate Scottish Government modelling estimated that Scotland’s GDP could be 6% (£9 billion in 2016 prices) lower by 2030 compared to continued EU membership. Scottish Government (2020) EU-UK negotiations: outcome analysis
127. Bank of England (2023) Monetary Policy Report – February 2023 and British Chambers of Commerce (2023) BCC Economic Forecast: Fragile Economy Stuck In First Gear
128. House of Lords (2021) Beyond Brexit: policing, law enforcement and security (UK Parliament) and UK Parliament (2023) Lords Committee finds that post-Brexit UK-EU security cooperation is sub-optimal
129. Scottish Government (2022) Building a New Scotland: Renewing democracy through independence
130. See Aston University (2022) UK exports suffered £12.4bn decline in 2021, largely attributed to non-tariff measures and Kassam, A and Chrisafis, A. ‘It won’t be easy’: the European exporters battling Brexit bureaucracy, The Guardian, 29 December 2021. The Organisation for Economic Cooperation and Development (OECD) predicts that the UK will have the second slowest average economic growth in the G7 over the next two years with the International Monetary Fund finding the same in their latest World Economic Outlook. Sources: OECD (2023) OECD Economic Outlook June 2023 and International Monetary Fund (2023) World Economic Outlook Update, July 2023: Near-Term Resilience, Persistent Challenges
131. McEwen, N (2020) The Sewel Convention in Parliament and Brexit (UK in a Changing Europe)
132. As of 3 November 2023. On two of these occasions the Scottish Parliament refused consent, but the UK Government did not consider that consent was required and did not seek legislative consent. Nine occurrences are listed in Scottish Government (2023) Devolution since the Brexit Referendum. In addition the Retained EU Law (Revocation and Reform) Act, which received Royal Assent on 29 June 2023 and the Northern Ireland Troubles (Legacy and Reconciliation) Act, which received Royal Assent on 18 September 2023.
133. UK Parliament (2023) Retained EU Law (Revocation and Reform) Act 2023
134. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
135. Scottish Government (2022) Retained EU Law Bill: letter to the UK Government, Letter from the SG Cabinet Secretary for Constitution, External Affairs and Culture to the UK Secretary of State for Business, Energy and Industrial Strategy, sent on 22 September 2022 and Scottish Government (2023) Retained EU Law Bill concerns – letter to the UK Government, Letter from the SG Cabinet Secretary for Constitution, External Affairs and Culture to the UK Secretary of State for Business and Trade, sent on February 2023. See also Scottish Parliament (2023) Legislative Consent Memorandum for the Retained EU Law (Revocation and Reform) Bill (Scottish Parliament)
136. Pew Research Center (2019) European public opinion three decades after the fall of Communism
137. Boltho and Eichengreen (2008) find a 5% boost to EU GDP. A ~2% boost to EU GDP is found by Ilzkovitz, F et al. (2007). In ‘t Veld (2019) estimates within a DSGE-framework an average of 8-9 % higher EU GDP in the long run. Boltho, A and Eichengreen B (2008) The economic impact of European integration (Center for Economic Policy Research).
Ilzkovitz, F et al. (2007) Steps towards a deeper economic integration: the internal market in the 21st century. A contribution to the Single Market Review (European Commission).
T’ Veld J (2019) Quantifying the Economic Effects of the Single Market in a Structural Macromodel (European Commission)
Freeman D, Meijerink G and Teulings R (2022) Trade benefits of the EU and the Internal Market (CPB)
138. Campos, NF et al. (2019) find that GDP per capita was 10% higher in the first ten years after joining the EU. Lehtimaki J and Sondermann D (2021) recent work concludes that there is a higher real GDP per capita for the overall single market area of around 12–22%, with smaller EU member states benefitting even more than larger ones. A study by CPB (2022) found that smaller and more open economies such as the Netherlands, Denmark, Belgium and Ireland benefit the most, with trade benefits ranging from 3.1% to 4.4%.
Campos, NF et al. (2019) Institutional integration and economic growth in Europe (Science Direct)
Lehtimaki, J and Sonderman, D (2021) Baldwin versus Cecchini revisited: the growth impact of the European Single Market (Empirical Economics)
Freeman, D. Meijerink, G and Teulings, R (2022) Trade benefits of the EU and the Internal Market (CPB)
139. Migrants can directly contribute to the economy through increasing the supply of labour, thereby boosting productive capacity, resulting in higher levels of economic activity and employment. Migrants can also help address skill and labour shortages in key sectors and regions. See research linking international migration to productivity growth such as Migration Advisory Committee (2018) Migration Advisory Committee (MAC) report: EEA migration (UK Government) and Jaumotte, F (2016) Impact of Migration on Income Levels in Advanced Economies (International Monetary Fund)
140. Scottish Government (2022) Building a New Scotland: A stronger economy with independence
141. Scottish Government (2018) Scotland’s role in the development of future UK trade arrangements, pp14-16, Scottish Government (2018) Scotland’s place in Europe: people, jobs and investment and Scottish Government (2021) Steadfastly European: Scotland’s Past, Present and Future
142. British performing artists seeking to tour in the EU must comply with the specific immigration and employment requirements of each EU country they visit, creating significant bureaucracy. Moreover, the movement of performance equipment may be subject to restrictions on goods exports, requiring export declarations and other paperwork, adding further to costs. See UK in a Changing Europe (2023) Where next? The future of the UK-EU relationship
143. Mattocks, K (2019) Culture, the arts and Brexit (The Political Studies Association (PSA))
144. European Commission (2023) Population on 1 January, Eurostat (accessed November 2023)
145. Office for National Statistics (2020) Census 2021: United Kingdom Population mid-year estimate (accessed November 2023)
146. European Commission (2022) Business demography statistics (accessed November 2023)
147. Department for Business, Energy and Industrial Strategy (2023) Business population estimates for the UK and regions 2023: statistical release (accessed November 2023)
148. European Commission (2023) DG Trade statistical guide (Publications Office of the EU) (accessed November 2023)
149. Scottish Government (2019) Export Statistics Scotland (accessed November 2023)
150. Bakker J et al (2022) Non-tariff barriers and consumer prices: evidence from Brexit (Centre for Economic Performance, The London School of Economics and Political Science)
154. European Commission European industrial strategy (accessed November 2023)
155. The Carbon Border Adjustment Mechanism is a measure seeking to prevent the risk of carbon leakage and support the EU’s ambition on climate mitigation. See European Parliament (2023) EU carbon border adjustment mechanism; Implications for climate and competitiveness
156. SchengenVisaInfo (2022) EU Council Approves Extension of Mobile Roaming Scheme Without Extra Fees Throughout the Bloc
157. Pinsent Masons (2022) Digital Single Market 2022 and Marcus JS, Petropoulos, G and Yeung, T (2019) Contribution to growth: The European Digital Single Market Delivering economic benefits for citizens and businesses, Study for the Committee on the Internal Market and Consumer Protection, Policy Department for Economic, Scientific and Quality of Life Policies (European Parliament).
158. The formal adequacy agreement between the UK and EU will run for four years, after which it will be subject to review and extension if the level of data protection in the UK continues to be adequate. The Information Commissioner’s Office Adequacy (accessed November 2023)
159. Data taken from 2019 when the UK was in the EU. Scottish Government (2019) Businesses in Scotland: 2019
160. The Ernst and Young 2023 UK and Scotland Attractiveness Survey finds that important factors for investors in the UK include the quality of life, quality of education, environmental commitments and transport infrastructure. In 2022, Scotland was the top UK location for attracting Foreign Direct Investment outside London. Scotland also polled as the most attractive place in the UK to invest after London. Separately, estimates by CEPR find that EU membership increases FDI by as much as 50% from EU countries, and 60% from non-EU countries, with deep integration with the European single market as the driver. Campos, N, Estrin, S and Bruno, R (2021) Foreign investment, European integration, and the Single Market(Centre for Economic Policy Research)
161. Scottish Government (2021) The Brexit vote, 5 years on – what do we know so far?
162. Bromhead A, Adams R and Casey C (2021) Ireland’s economy since independence: what lessons from the past 100 years? (Economic Observatory)
163. Much of the trade diversification reflects not only the historical reliance on trade with Britain but also the export pattern of newly established foreign firms in Ireland. A number of features of Irish economic policy have contributed to this. These include low corporation tax and other incentives for inward investment, a well-educated but under-employed workforce pre-single market, the English language and shared time-zone, and social partnerships which facilitated wage moderation and macroeconomic stability through the late 1980s to early 2000s. Nevertheless, the expansion of trade with EU countries while maintaining traditional links is notable.
164. The EU share referred to here covers EU-15 as given in Bromhead A, Adams R and Casey C (2021) Ireland’s economy since independence: what lessons from the past 100 years? (Economic Observatory)
165. O’ Rourke, K (2019) A Short History of Brexit (Pelican), p. 143. Ireland’s comparative performance through this period is also discussed in detail in O Grada, C and O’Rourke, KH (2021) The Irish economy during the century after Partition (CAGE)
166. OECD Balanced International Trade in Services (2005-2019) (accessed November 2023)
167. Note that both Gross Domestic Product (GDP) per head and Net National Income (NNI) per head are presented in the table as GDP measure for Ireland is distorted by the activities of multinational companies. Both measures are in US dollars and are expressed in terms of current purchasing power parities (PPPs) to provide a meaningful comparison of economic activity between Ireland and the UK in a given year. While GDP measures the value of what is produced in a country, NNI measures how much of that value stays in the country. NNI differs from GDP by Net Factor Income which for Ireland is mostly an outflow of profits of foreign- owned multinationals. Net National Income is calculated as part of National Accounts all around the world so it can be compared between countries. See OECD Disposable income and net lending – net borrowing : Net national income per head, US $, current prices, current PPPs (accessed November 2023). See also The World Bank Population, total (accessed November 2023) and OECD Gross domestic product (GDP) : GDP per capita, USD, current prices and PPPs (accessed November 2023). Note that, despite rapid growth in GDP and income per capita in recent decades, measures of Ireland’s consumption per head – a rough measure of current living standards of households – are currently below the EU average. Honohan, P (2021) Is Ireland really the most prosperous country in Europe? (Central Bank of Ireland)
168. O’Rourke, KH (2017) Independent Ireland in Comparative Perspective, Irish Economic and Social History, 44(1), 19–45.
169. Net National Income per head is included in this table because there are widely recognised problems with using GDP as a measure of the Irish economy. These have been set out by the Central Bank of Ireland in, Byrne S, Conefrey T and O’Grady M (2021) The Disconnection of GDP from Economic Activity Carried out in Ireland (Central Bank of Ireland) and FitzGerald, J (2018). National Accounts for a Global Economy: the case of Ireland, QEC Special Article (The Economic and Social Research Institute)
170. OECD GDP per head and OECD Net national income per head, World Bank Population, total, De Bromhead, A, Adams, R and Casey, C (2021) Ireland’s economy since independence: what lessons from the past 100 years? (Economics Observatory). United Nations, UN Comtrade (2022) (accessed November 2023)
171. OECD GDP per head and OECD Net national income per head, World Bank Population, total, De Bromhead, A, Adams, R and Casey, C (2021) Ireland’s economy since independence: what lessons from the past 100 years? (Economics Observatory). United Nations, UN Comtrade (2022) (accessed November 2023)
172. European Commission (2021) Brexit Adjustment Reserve: Commission approves €920.4 million pre-financing for Ireland. The Irish Government offered a package of support for its industry after Brexit, see for example Irish Government (2020) Government Brexit Advisory, Financial and Upskilling Supports (accessed November 2023).
173. European Commission Recipients and results of EU aid (accessed November 2023)
174. Zuleeg F, Emmanouilidis JA and Borges de Castro R (2021) Europe in the age of permacrisis (European Policy Centre)
175. European Commission EU solidarity with Ukraine (accessed October 2023)
177. Godin, M and Sigona, N (2019) EU families feel more welcome in Scotland than they do in the rest of the UK (London School of Economics and Political Science). See also the Scottish Government’s National Performance Framework which includes a national indicator measuring experience of people coming to live in Scotland. Scottish Government’s National Performance Framework National Indicator Performance (accessed November 2023)
178. See Scottish Government Human rights (accessed November 2023)
179. Scotland has provided a safe and secure route to sanctuary for more than 25,000 people from Ukraine who have arrived in the UK with a Scottish sponsor. See UK Government Ukraine Sponsorship Scheme: Visa data by country, upper and lower tier local authority (accessed November 2023). See also Scottish Government (2021) Migration: Attracting And Welcoming People To Scotland – A Scotland for the future: opportunities and challenges of Scotland’s changing population
180. See Article 3, European Commission (2016) Consolidated Versions of the Treaty on European Union and the Treaty on the Functioning of the European Union
181. Scottish Government (2020) The European Union’s Strategic Agenda for 2020-24: Scotland’s Perspective
182. The amount of renewable electricity generated in Scotland in 2022 is the equivalent of powering all households in Scotland for around three and half years. Scottish Government (2023) Energy Statistics for Scotland – Q4 2022 (accessed November 2023).
183. Scotland’s net exports of electricity (exports minus imports) in 2021 were 16,028 GWh, and in 2022 were 18,749 GWh. See Scottish Government (2023) Scottish Energy Statistics Hub – Annual Electricity imports and exports for export figures (accessed November 2023).
184. As of June 2023, 477 renewable electricity projects with a capacity of 23.0 GW were in the pipeline in Scotland; 4.2 GW of these are under construction, 6.7 GW are awaiting construction and 12.0 GW in planning. Scottish Government (2023) Scottish Energy Statistics Hub – Pipeline renewable capacity by planning stage (accessed November 2023). By way of comparison, we need 5-6 GW to meet peak electricity demand in Scotland. See Scottish Government (2023) Scottish Energy Statistics Hub – Installed supply capacity and peak electricity demand (accessed November 2023)
185. Scottish Government (2022) Hydrogen action plan
186. European Commission (2022) REPowerEU: A plan to rapidly reduce dependence on Russian fossil fuels and fast forward the green transition
187. Marine Scotland Facts and figures about Scotland’s sea area (coastline length, sea area in sq kms) (accessed November 2023)
189. Scotland’s offshore wind operational capacity was 2.7 GW as at the second quarter of 2023 (Scottish Government, Scottish Energy Statistics Hub Operational renewable capacity, accessed November 2023), with a further 8.3 GW of pipeline capacity (under construction, awaiting construction or in planning) (Scottish Government, Scottish Energy Statistics Hub Pipeline renewable capacity, accessed November 2023). In addition to this pipeline capacity, our ScotWind leasing round provides seabed rights for potential development of almost 28GW of offshore wind energy (Crown Estate Scotland, ScotWind leasing round – Offshore Wind, accessed November 2023); and the Offshore Wind Scotland, Innovation and Targeted Oil & Gas (INTOG) offshore wind leasing round could add a further 5.4GW of capacity, subject to planning and consenting decisions and finding a route to market. Offshore Wind Scotland Innovation and Targeted Oil and Gas (INTOG) leasing round, (accessed November 2023)
190. This comprises pipeline capacity already captured on the Scottish Energy Statistics Hub (accessed November 2023), the Scotwind leasing round, and the Innovation and Targeted Oil & Gas (INTOG) projects as set out in the previous endnote.
191. European Commission The North Seas Energy Cooperation (accessed November 2023)
192. Demogenes, B (2020) EU Focus on the Bioeconomy Holds Great Promise for the Growth of Green Jobs (Climate Scorecard)
193. SAE Renewables MeyGen (accessed November 2023)
194. Orbital Marine Power O2 – Orbital Marine (accessed November 2023)
195. Scotland has 18% of Europe’s carbon dioxide storage capacity based on an estimated 46Gt in Scotland and 260Gt in Europe. This calculation is based on the following sources: Scottish Centre for Carbon Storage (2009) Opportunities for CO2 Storage around Scotland – an integrated strategic research study and Turrell, W et al (2022) A Review of National Monitoring Requirements to Support Offshore Carbon Capture and Storage (Frontiers in Marine Science) also Zhang et al. (2022) European carbon storage resource requirements of climate change mitigation targets paper (Science Direct).
196. Scottish Government (2023) Circular Economy (Scotland) Bill
197. Scottish Government (2023) Scotland’s Blue Economy: current status review
198. European Commission (2019) A European Green Deal (accessed November 2023)
199. European Commission (2023) The Green Deal Industrial Plan
200. European Commission Recovery and Resilience Facility (accessed November 2023)
201. The European Commission’s ambitions (see Political Guidelines for the Next European Commission 2019-2024) are fully aligned with our own domestic agenda of creating a net zero economy by 2045, ending Scotland’s contribution to climate change. See Scottish Government (2023) Draft Energy Strategy and Just Transition Plan
202. Scottish Government (2022) Biodiversity strategy to 2045: tackling the nature emergency
203. The Climate Group Under2 Coalition (accessed November 2023)
204. Scottish Government (2022) Edinburgh Declaration on post-2020 global biodiversity framework
205. For example, through the UN Climate Summit (COP26) in Glasgow in 2021 and the UN Biodiversity Summit (COP15) in Montreal, Canada in December 2022
206. The Times Higher Education World University Rankings 2024 (accessed November 2023)
207. Universities Scotland (2022) REF 2021: Scotland’s universities deliver research of “world leading” quality and impact
208. Vanguard Initiative Vanguard Initiative (accessed November 2023)
209. Scottish Government (2020) Scotland’s Inward Investment Plan: Shaping Scotland’s Economy
210. Scotland’s AI Strategy (2021) Scotland’s AI Strategy
211. According to the latest available data (2020), the wider Life Sciences sector employs 42,500 people in 728 businesses and Higher Education Institutions. Scottish Government (2023) Growth sector statistics (accessed November 2023)
212. See Life Sciences Scotland, Animal Bioscience, Aquaculture and Agritech (accessed November 2023)
213. Scottish Industries Directory Life and Chemical Sciences (Scottish Enterprise) (accessed November 2023)
214. Food and Agriculture Organization of the United Nations (2022) Fisheries and Aquaculture: Global Production by Production Source (1950-2021) (accessed November 2023); Scottish Government (2022) Scottish fish farm production survey 2021
215. See ScotlandIS (2023) Scottish Technology Industry Survey 2023 and Scottish Government (2022) A Trading Nation – An Export Plan for Scotland’s Technology Sector, and Scottish Development International Games and creative industries opportunities in Scotland (accessed November 2023)
216. Scottish Government (2021) Scottish Space Strategy launched
217. Scottish Development International: Scotland’s space industry opportunities and space capabilities (accessed November 2023)
218. Scottish Government (2021) Supporting Our Digital Technology Sector – A changing nation: how Scotland will thrive in a digital world and Scottish Government (2022) Inspiring a new generation of tech entrepreneurs
220. Scottish Government (2022) A Culture Strategy for Scotland
221. In 2019, producers based outside of Scotland spent an estimated £165.3 million on the inward production of films and high-end TV programmes filmed on location or in studio facilities in Scotland. Source: Screen Scotland (2022) The Economic Value of the Screen Sector in Scotland in 2019
222. Wellbeing Economy Alliance: Wellbeing Economy Governments (WEGO) (accessed November 2023)
223. European Commission, Alternative measures of progress beyond GDP (accessed November 2023)
224. Scottish Government (2018) Scotland’s Place in Europe: security, judicial co-operation and law enforcement
225. Scottish Government (2023) Building a New Scotland: Creating a modern constitution for an independent Scotland
226. For example, the EU Charter of European Union Agency for Fundamental Rights reports regularly on performance in areas such as gender, LGBTI and race equality.
227. The guidelines for accession negotiations approved by the Luxembourg European Council in 1997 and Helsinki European Council in 1999 provide that each applicant country proceeds at its own rate, depending on the merit and preparedness of the applicant country. See also the European Commission’s 2021 Enlargement package for the Western Balkans and Turkey which has a new methodology that is also a merit-based approach. This merit-based approach is also being used for Ukraine, Moldova and Georgia. See European Commission (2023) Enlargement Package
228. Article 50 author Lord Kerr says Brexit not inevitable, BBC News, 3 November 2016
229. Copenhagen criteria, also known as the accession criteria, are conditions agreed by the European Council in Copenhagen in 1993 which a candidate country must satisfy to become a member state.
230. The Netherlands has been a net contribution since the mid-1990s, many decades after it, together with Belgium and another four nations, formed the European Economic Community (ECC) in 1957. Belgium, in contrast, has been and remains today a net recipient, with higher spending allocated from the EU budget supporting activity of many EU institutions based in Belgium. Denmark joined the EU in 1973, around the same time as the UK and Ireland, and became a net contributor in the late 1990s. In contrast, Ireland remained a net recipient of EU funds from the year it joined the EEC and only became a net contributor in 2018. Austria, Finland and Sweden all joined the EU in 1995. Sweden has been a positive net contributor from day one whereas Austria and Finland, in contrast, became net contributors only at the start of 2000s.
231. House of Commons Library (2022) The UK’s contribution to the EU budget (UK Parliament)
232. See Office of Budget Responsibility (2022) Economic and fiscal outlook
233. Parker, G and Giles, C. The deafening silence over Brexit’s economic fallout, Financial Times, 20 June 2022.
234. ‘Empathy’ for independent Scotland joining the EU says Tusk, BBC News, 2 February 2020
235. See Bevington, M (2020) How new member states join the EU: all you need to know (UK in a Changing Europe) and The accession of Austria, Finland and Sweden to the European Union – Historical events in the European integration process (1945–2014) (CVCE)
236. Scottish Government (2022) Building a New Scotland: A stronger economy with independence
237. The European Commission’s spokeswoman for economic affairs, 30 October 2022, “It is up to individual countries to calibrate their path towards the euro and no timetable is prescribed.” Nutt, K. EU official spokeswoman: Members must commit to join the euro – but timetable open, The Herald, 30 October 2022.
238. The convergence, or Maastricht, criteria measure EU member states’ preparedness to adopt the euro. They are defined as a set of macroeconomic indicators, which focus on: price stability, sound public finances, exchange- rate stability and long-term interest rates. See European Commission Convergence criteria for joining
239. European Commission ERM II – the EU’s Exchange Rate Mechanism
240. Jean-Claude Juncker, 15 September 2017, ‘I don’t intend to force countries to join the euro if they are not willing or not able to do so’ (European Commission)
241. European Commission (2023) New economic governance rules fit for the future
242. Croatia, Hungary and Poland all joined the EU with deficits higher than 3%.
243. Scottish Government (2022) Building a New Scotland: A stronger economy with independence
244. European Parliament Think Tank (2020) Marketing of and trade in fishery and aquaculture products in the EU and Guillen J, Natale F, Carvalho N. et al (2019) Global seafood consumption footprint. Ambio, Vol 48, 2019
245. Boris Johnson, 16 June 2016, “Talking to the fishermen and the workers at the factory, they are clear: whilst Britain is in the EU we cannot take measures to protect our fishing industry and stocks. And if we Vote Leave we can take back control over UK waters, set our own fishing policies, and support our fishermen”. www.facebook.com/borisjohnson/posts/10153762887651317, Facebook, (accessed November 2023)
246. Warburton, S. Salmon Scotland urges post-Brexit digital push to slash costs, The Press and Journal, 5 April 2022
247. ‘Core waters’ refers to waters within the “metropolitan” or “European” EU but excluding the Special Territories of the EU (e.g. Outermost Regions and Overseas Countries and Territories). European Commission (2020) European Marine Observation and Data Network. Scotland’s 63% share of the UK’s current Exclusive Economic Zone (EEZ) is an estimated 462,315 km2. Together with the adjacent continental shelf limits, Scotland’s seas are an estimated 617,643 km2. Marine Scotland Facts and figures about Scotland’s sea area (coastline length, sea area in sq kms) (accessed November 2023)
248. European Commission The common agricultural policy: 2023-27 (accessed November 2023)
249. European Commission (2019) A European Green Deal (accessed November 2023)
250. European Commission (2020) Farm to Fork Strategy
251. European Commission (2021) EU biodiversity strategy for 2030
252. Scottish Government (2022) The Next Step In Delivering Our Vision For Scotland As a Leader In Sustainable And Regenerative Farming
253. Scottish Government (2022) Building a New Scotland: A stronger economy with independence. See endnote 44: £14,000 is the difference between Scotland’s GDP per capita (offshore measure) and the average GDP per capita of the ten small economies as introduced in Building a New Scotland: Independence in the modern world. Wealthier, happier, fairer: why not Scotland? There are widely recognised concerns over Ireland’s GDP statistics (see for example Byrne S, Conefrey T and O’Grady M (2021) The Disconnection of GDP from Economic Activity Carried out in Ireland (Central Bank of Ireland)) and therefore it is worth noting that the difference in GDP per capita between Scotland and the average for this group of countries excluding Ireland still remains significant, on average £11,000 per person higher in 2021. Scotland’s GDP per capita includes a geographical share of extra-region (offshore) activity and is sourced from GDP Quarterly National Accounts: 2022 Quarter 1 (January to March). GDP per capita, measured in current prices and current Purchasing Power Parities (PPPs), for other countries is sourced from OECD database Level of GDP per capita and productivity. Scotland’s GDP per capita in current prices and current PPPs is estimated by applying a PPP conversion factor for the UK published by OECD Conversion rates – Purchasing power parities (PPP) – OECD Data. Difference in levels of GDP per capita reflects differences in historical growth rates and past performance may not be indicative of future performance.
254. Tooze, A (2022) Chartbook #184 – Nostalgia for decline in deconvergent Britain, 30 December 2022
255. Burn-Murdoch, J. Britain and the US are poor societies with some very rich people, Financial Times, 16 September 2022
256. Scottish Government (2022) Building a New Scotland: A stronger economy with independence
257. Scottish Government (2019) Export statistics Scotland: 2019
258. The Labour Party (2022) A plan to make Brexit work” – Keir Starmer’s speech to the CER think tank, 4 July 2022
259. European Commission Agreements with non-EU countries (accessed November 2023)
260. The rate of goods subject to Sanitary and Phytosanitary (SPS) measures varies by each product. CBI (2021) UK-EU Veterinary Agreement (accessed November 2023)
261. Nick Thomas-Symonds, Shadow UK International Trade Secretary interviewed on BBC Newsnight, 29 August 2023
262. Cabinet Office (2023) The Border Target Operating Model: August 2023
263. See paragraph 66 of Cabinet Office (2023) The Border Target Operating Model: August 2023
264. The Schengen acquis is defined by 1999/435/EC: Council Decision of 20 May 1999
266. Hayward, K and McEwen, N (2022) An EU border across Britain: Scotland’s borders after independence (UK in a Changing Europe)
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