The United Kingdom of Great Britain and Northern Ireland (UK) left the EU on 31 January 2020, but the vast majority of energy-related issues remained unaffected until the end of 2020, when the transition period concluded. The Trade and Cooperation Agreement, between the EU and the UK, which includes a section on energy, provisionally applies since January 2021.
After nearly 50 years of EU membership, the EU-27 and UK energy markets are deeply interlinked, thanks to electricity interconnectors and gas pipelines running between Great Britain and Northern Ireland on the one hand and France, the Netherlands, Belgium and Ireland on the other. In recent years, the UK has been a net importer of energy, with the EU providing 5-10% of its electricity and 4%-12% of its gas.
On 1 January 2021, the UK left the EU's internal energy market. Energy trading through electricity interconnectors between the EU and Great Britain is no longer managed through existing single market tools, such as EU market coupling, as these are reserved for EU countries. Only Northern Ireland will maintain part of the single electricity market with Ireland, as provided by the Withdrawal Agreement.
Furthermore, the UK left the European Atomic Energy Community (Euratom), including the nuclear common market, which entails strong guarantees for the safe and peaceful use of nuclear energy and the security of atomic energy supply and enables the pooling of knowledge, research, infrastructure and funding of nuclear energy.
The EU-UK Trade and Cooperation Agreement
The energy section of the EU-UK Trade and Cooperation Agreement is covered under Title VIII, and will run until 30 June 2026. There are also 4 energy-related annexes, covering
- lists of energy goods, hydrocarbons and raw materials
- energy and environmental subsidies
- non-application of third party access and ownership unbundling to infrastructure
- allocation of electricity interconnector capacity at the day-ahead market timeframe
A separate agreement between Euratom and the UK covers cooperation on the safe and peaceful use of nuclear energy.
Energy efficiency and renewable energy
EU-UK energy cooperation is grounded on delivering the clean transition and ensuring security of energy supply. The UK has reaffirmed its ambitions on energy efficiency and renewables for 2030, and both the EU and the UK have committed to practical measures to facilitate the integration of more renewable energy sources into the electricity system.
The EU-UK Trade Agreement covers cooperation on offshore renewable energy development, with a focus on the North seas (North Sea and Irish Sea). The scope of cooperation reflects the EU's strategy on offshore renewable energy. In December 2022, a Memorandum of Understanding establishing a cooperation framework was signed between the UK and the North Seas Energy Cooperation, a High-Level Group comprising the European Commission, EU countries in the region, Norway, and formerly the UK, before its exit from the EU.
Security of electricity and gas supply
The EU-UK Trade Agreement helps ensure security of electricity and gas supply, by establishing a dedicated framework for continued EU-UK cooperation in this area. This is particularly relevant for Ireland, which is isolated from the rest of the EU internal energy market at least until new interconnections are built.
Additionally, there is a framework for transmission system operators (TSOs) to develop new arrangements for trading over interconnectors, as the UK TSOs cannot participate in internal EU procedures such as EU market coupling. This allows electricity trade with the UK to continue, although less efficiently than the system used inside the EU.
For trading over electricity interconnectors, the EU and the UK will task transmission system operators with developing a new arrangement based on multi-regional loose volume coupling. This specific process will link the distinct and separate markets in the EU and the UK, using a different algorithm to EU market coupling and with access only to commercial data from markets directly linked to the UK.
Technical cooperation between TSOs and energy regulators
The UK will not be able to participate in EU bodies such as the Agency for the Cooperation of Energy Regulators (ACER), the European networks of transmission system operators for electricity (ENTSO-E) and for gas (ENTSOG).
The EU-UK Trade Agreement therefore provides for a cooperation framework for EU and UK transmission system operators (TSOs) and energy regulators.
Nuclear energy
The Euratom-UK Agreement allows for wide-ranging cooperation on nuclear safety and peaceful uses of nuclear energy. It is underpinned by assurances that both sides will comply with international non-proliferation obligations.
Key areas of cooperation under the agreement include
- the supply and transfer of nuclear material, non-nuclear material, technology, and equipment
- trade relating to the nuclear fuel cycle
- safe management of spent fuel and radioactive waste
- nuclear safeguards, physical protection, nuclear safety, and radiation protection
- use of radioisotopes and radiation in agriculture, industry, and medicine
- geological and geophysical exploration, and uranium resource development
- regulatory aspects of the peaceful use of nuclear energy
- research and development, including UK participation in the ITER project
The Euratom-UK agreement is underpinned by a shared commitment to uphold a high level of nuclear safety standards. Compared to other nuclear cooperation agreements, it contains ambitious provisions on nuclear safety cooperation. These include the safe management of spent fuel and radioactive waste and radiation protection, including emergency preparedness and response.
The UK remains bound to international instruments on nuclear safety, such as the Convention on Nuclear Safety, the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, the Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency and the Convention on Early Notification of a Nuclear Accident. The Euratom and the UK are committed to working together on improving international nuclear safety standards and conventions, and their implementation.
The agreement also allows for continued cooperation on matters covered by established Euratom systems for monitoring and exchanging information on levels of radioactivity in the environment, including the European Community Urgent Radiological Information Exchange (ECURIE) and the European Radiological Data Exchange Platform (EURDEP), and established expert advisory groups in the field of nuclear safety, including the European Nuclear Safety Regulators Group (ENSREG). This enables early notification and the exchange of reliable radiological information between EU countries and the UK in the event of a nuclear accident. It also allows rapid, coordinated responses to radiological emergencies by sharing real-time data.
A key feature of the agreement relates to the peaceful uses of nuclear energy. Nuclear safeguards provisions are foreseen in the agreement to ensure that both parties adhere to their non-proliferation commitments and that cooperation serves only peaceful purposes.
According to the Euratom-UK Agreement, any transfer of nuclear material, non-nuclear material, equipment or technology need to be made in accordance with the international commitments of Euratom, EU countries, and the UK in relation to the peaceful uses of nuclear energy.
The cooperation envisaged under the Euratom-UK Agreement includes the use of radioisotopes and radiation in agriculture, industry, medicine and research. This is especially useful for minimising the risks of shortage of supply of medical radioisotopes, and to support the development of novel technologies and treatments.
The agreement facilitates the exchange of information regarding the supply of radioisotopes.
The UK continues to participate in the ITER project actions and activities through its membership of the Fusion for Energy (F4E) Joint Undertaking. The Trade and Cooperation Agreement includes provisions for associating the UK to EU programmes, however, this still needs to be adopted by a specialised committee that will be established under the agreement.
This will also allow the UK to participate in the Euratom research and training programme and to become a member of the Joint Undertaking Fusion for Energy (F4E) as an associated third country.
The Euratom Community has negotiated separate agreements on the peaceful uses of nuclear energy with a number of third countries based on the Euratom Treaty, including the USA, Canada, Australia, Japan and Ukraine. A well-established pattern in this sense exists both in the Euratom Community and at international level. Moreover, Euratom possesses specific competences linked to the substance of these type of agreements, for which the specific and separate Euratom legal basis is necessary.
Level playing field measures in the energy sector
As well as the cross-sector level playing field provisions that are relevant for the energy sector, including on social and environmental issues, the EU-UK Trade Agreement includes energy specific provisions. These relate to energy sector subsidies, non-discriminatory promotion of energy from renewable sources, prohibition on export restrictions (including export monopolies and export licences), and dual pricing of energy goods.
Documents
- 13 MARCH 2024
- 13 MARCH 2024
- 12 FEBRUARY 2021
- 13 MARCH 2024
Related links
- Relations with the United Kingdom
- Press release: EU-UK trade and cooperation agreement (24 December 2020)
- Questions and answers on EU-UK trade and cooperation agreement (24 December 2020)
- EU-UK Trade and Cooperation Agreement
- Euratom-UK Agreement