The multilateral construction of labour clauses in the UK-Australian and UK-New Zealand FTAs: different shades of minimalism?

As the first post-Brexit FTAs to be negotiated from scratch, the UK-Australian (UKAFTA) and UK-New Zealand (UKNZFTA) agreements offer a concrete indication of UK’s approach towards labour clauses in FTA/PTAs. In the vast literature on trade-labour linkage, this article seeks to make the following contribution. It examines the ‘multilateral construction of the trade-labour linkage’ in UKAFTA and UKNZFTA. It makes two arguments. Firstly, it argues that UKAFTA and UKNZFTA adopt ‘minimalism’ as a dominant pattern but in different shades. UKAFTA’s ‘hyper-minimalism’ concerning both the width (extent) and depth (strength) of its multilateral construction contrasts with UKNZFTA’s ‘ambitious minimalism’ where its wider scope is not associated with significantly stronger provisions. Secondly, the article situates this minimalism in the broader context of ‘Global Britain’, the term employed in official foreign policy discourse to depict the UK’s role in the world after Brexit. It submits that both agreements are a missed opportunity for a post-neoliberal Global Britain which is inconsistent with the multilateral ambitions of Global Britain and the celebratory rhetoric of the Government praising the agreements as locking-in high labour standards.