Quebec, Scotland, and substate governments’ roles in Canadian and British trade policy: Lessons to be learned

Following Brexit (the withdrawal of the UK from the EU and the European Atomic Energy Community at the end of 31 January 2020), the British government stated that it hoped to reach a new trade agreement with Canada to be modelled after the Canada–EU Comprehensive Economic and Trade Agreement, the first free-trade deal for which Canadian provinces were directly involved at every stage of negotiations. In the UK, while there are mechanisms for the involvement of devolved regions in European policy, there is no clear constitutional doctrine as to the roles they should play in elaborating trade policy more generally. Moreover, the asymmetric nature of the UK’s devolution system complicates the involvement of its devolved governments in trade negotiations. By providing a specific focus on the cases of Quebec and Scotland, this article provides a comparison of substate governments’ roles in trade negotiation and trade promotion. It concludes that, while there seems to be only limited scope for substate governments’ formal input into future trade negotiations, their trade and investment promotion organizations allow them to pursue different objectives over trade outcomes within a unified national framework.