After the acrimonious and chaotic divorce of Brexit, followed by a mixture of silence and braggadocio from successive UK leaders, Keir Starmer has pledged to “reset relationships” with the EU. In a tentative first meeting with re-elected European Commission President Ursula von der Leyen, the UK and EU agreed “to take forward this agenda of strengthened cooperation at pace over the coming months”. A series of summits is planned, beginning early next year, and negotiations have started behind the scenes.
So far, the UK’s policy goals remain vague. But our work to date on the Health and International Relations Monitor project, funded by the Health Foundation, suggests several concrete measures in health and life sciences that could form part of an attempt to work more closely with the EU, with real benefits to patients, health systems, regulators and industries on both sides.
At a time of widespread medicines shortages, intense competition and change in medical technology, and concerns about infectious disease, the UK's self-imposed disconnection in key areas benefits no one. By focusing on the goal of improving health, where there is so much shared ground and so little benefit in competition, it should be possible to build a moral, legal and political case for change.
Within the rules
A significant package of useful actions could happen within the existing treaties between the UK and the EU. These could directly deliver mutual health benefits to citizens, and also build the kind of shared positive public narrative needed for anything more radical.
For medicines, infectious disease, science and data, Brexit meant that UK agencies and institutions were pulled out of a wider European structure, and the network of information and responsibilities which runs through it. Some of the benefits of cooperating could be regained by working together in a more structured and deeper way from outside.
The UK’s MHRA medicines and devices regulator and the European Medicines Agency have a shared interest in knowing about safety problems and issues on the medicines market. There is existing contact, but this could be regularised and ways of working made consistent in a memorandum. The UK Health Security Agency could build on its memorandum with the European Centre for Disease Prevention and Control (ECDC) to exchange data and align aims on stopping the spread of antibiotic resistance, which is a major global concern.
The EU has extensive plans and structures taking shape to address the serious problem of medicines shortages. The actions the EU envisages taking centrally – joint purchasing, sharing supplies across its member states, and reducing reliance on a small number of supply lines from Asia – could all shut the UK out. However, they could also be more effective without competition with the UK that could lead to squabbling over stocks, contracts and locations.
The UK government has already joined the EU Critical Medicines Alliance, an important indicator that it accepts the need for common action here, at least in part. The UK could build on the Alliance to develop lines of communication about attempts to deal with medicine shortages.
Official routes and forums already exist for much of this cooperation. The Trade and Cooperation Agreement (TCA) that came into effect as the UK left the EU has provisions for memoranda and international cooperation between the UK and the ECDC in Article 702, and for a “Medicines Working Group”.
As we have argued previously, the UK could learn a great deal and smooth the path to being included in EU health conversations if it produced data compatible with information published by Eurostat – an important comparative way to understand everything from health care staffing to medicine use. It would be possible for the UK’s data to be included in the database, as data from countries like Serbia and Türkiye has been.
The UK could also unilaterally achieve a significant degree of stability and predictability in the sharing of health data for research by committing to remain within the EU’s criteria to receive “adequacy” status for the movement of personal data.
The European Health Data Space, agreed between the European Parliament and Council to create a “single market” in health data, also creates an important new opportunity to enable research across the UK and EU. There is a specific provision in the proposed EU regulation for third countries to gain access as authorised participants if they grant the same in return, and follow standards about the use of data for purposes other than patient care (such as research). Note
In seeking common ground, the network of UK and EU non-governmental actors and personal academic connections, which we found still exists in many areas, should be a considerable advantage in seeking common ground. The UK has produced a policy paper that expresses its hopes to join the next major EU science funding programme, and gently lobbies from outside as to its direction. With no cards to play in negotiations, supporting a wider community of connections may be the best way to stay engaged.
Rewriting the rules
The EU and UK have been described by the European Centre for International Political Economy (ECIPE) as having “probably the broadest, deepest bilateral relationship in the world”. Many of the rules governing it sit in an overgrown trade agreement – the TCA.
This is due for review in 2026. UK commentators easily overrate how much of a chance a wishlist of demands stands of being adopted through this process: there will be red lines, and the EU will once again defend them strongly. However, there are two clear areas in which it could be possible to make a compelling case that the EU as well as the UK stands to benefit from deeper cooperation set out in treaties.
The first is batch testing of medicines, a regulatory step carried out by a special class of professionals for each lot of pills or bottles produced. Mutual recognition of this is common – the EU recognises Australian and US tests. The UK currently recognises tests taking place in the EU, but not vice versa.
In the current context of medicine shortages and a strong desire for more diversity in EU supplies, a step that would make it easier to export products from the UK to the EU should have clear benefits to both sides. It could be achieved by a simple mutual recognition agreement between regulators.
A second area, with less precedent but obvious advantage to be gained from cooperation, would be clinical trials. Europe as a continent is struggling to maintain its global share of trials. The EU’s recent regulatory reforms have emphasised reducing barriers to running trials across multiple member states, but the UK’s exit means it is left apart. This probably harms competitiveness on both sides, as the UK remains a relatively large centre for clinical trials.
The simplest shift – though still unprecedented – would be to commit to accept clinical trial sponsors based in the other party, as the UK already does, so that the costly need to have one on either side of the Channel or the Irish Sea could be averted.
A more ambitious step would be for the UK to participate in the EU’s shared system of approving clinical trials. Applications through the system, which allows sponsors to approach multiple member states at once, could also go to the UK. The legislation underlying this in the EU and setting out the requirements for trials was drawn up before the UK left, but not implemented until it had done so.
Because the UK is not subject to it, there would need to be special governance, safeguards and commitments in place between the two parties for any such systematic approach, in order to guarantee privacy, the ability of the EU to fully retain control over its decisions, and the UK applying different standards. But at least a partial precedent exists in the Windsor Framework designed to smooth the flow of medicines into Northern Ireland. These already set out ways, with safeguards, for a UK regulator to approve some products within the EU legal structure.
Most radically of all, the UK could fully participate in jointly approving trials to run across itself and member states at the same time. This would require legal changes on both the EU and UK side. The EU would have to relax “third country” access to a part of its internal market while retaining legal control – again something tested through the Windsor Framework. The UK would have to "dynamically align" – to fully adopt the approach, standards and processes set out in the EU’s regulations, and update to match them each time they changed.
A more comprehensive option would be for the UK and EU to negotiate a Health Security Treaty. The EU has power to make agreements with other countries to achieve any of its objectives: protecting human health is such an objective. A Health Security Treaty could put in place processes and structures to tackle both these issues rooted in the existing post-Brexit relationships and others.
It could cover critical medicines supply; safety of equipment and devices including AI; antimicrobial resistance; sustainable supply of health care professionals; and more. A treaty would involve both sides agreeing to be bound by whatever was agreed – a genuine and comprehensive reset.
Putting the patient first
These possible areas of progress should not be seen as an isolated set of requests. Even during the acrimonious process of negotiating the TCA in 2020, the EU showed in measures such as Article 702 an understanding that health is not simply another economic sector, but a matter of protecting lives and wellbeing that it is bound to try to advance in all its policies. This equally applies to issues of the security of medicine supply, currently a serious threat to public health across the UK and EU, and to smoothing the way for scientific discoveries addressing major diseases.
The UK has not always prioritised so clearly, but the new government could make the case for health, alongside defence, as an area where the shared interests of security mean practical cooperation rather than competition could be the order of the day.