The Comprehensive and Progressive Agreement for Trans-Pacific Partnership (“CPTPP”) entered into force between Canada and the United Kingdom on September 1, 2026, expanding preferential market access on both sides of the Atlantic.

The UK is Canada’s largest trading partner in Europe and fourth-largest merchandise trading partner worldwide. As the CPTPP’s 12th member, the UK brings the bloc to nearly 600 million consumers and over 15% of global GDP, with a combined GDP of approximately £12.9 trillion (2025 terms).

Canada’s ratification of the UK’s Accession Protocol (bringing the Agreement into force for trade between the two countries) arrives as Canada actively pivots away from its reliance on the Canada-U.S. trade corridor. The federal government’s inaugural Canada Investment Summit in Toronto on September 14–15, 2026, is designed to catalyze $1 trillion in total investment over five years to advance that diversification effort. As U.S.-Canada trade tensions continue to reshape supply chains—for more on Canada’s approach, see our recent article on Ottawa’s calibrated retaliatory tariffs—agreements like the CPTPP take on heightened strategic importance.

For the UK, CPTPP membership advances its post-Brexit global trade strategy. With Canada’s ratification complete, UK businesses have preferential access across all 12 CPTPP member economies—and a stronger platform for investment in Canada’s priority sectors, including energy, infrastructure, critical minerals, and technology.

This article outlines the key implications of the CPTPP’s entry into force for businesses in Canada and the UK, and practical steps for using the new framework.

A brief history of the UK’s accession to the CPTPP

The UK's accession followed several years of negotiations. Key milestones include:

  • July 16, 2023: The UK signed the CPTPP Accession Protocol, formalizing its commitment to join the agreement.
  • December 15, 2024: The UK officially became the 12th CPTPP member—the first country to accede since the agreement entered into force in 2018.
  • May 6, 2026: Canada's implementing legislation—the Act to implement the Protocol on the Accession of the United Kingdom to the CPTPP—received royal assent.
  • July 3, 2026: Canada ratified the protocol, triggering entry into force of the CPTPP for trade between Canada and the UK on September 1, 2026.

The Canada-UK Trade Continuity Agreement (“TCA”) governed the bilateral relationship before the CPTPP. The UK’s Accession Protocol does not replace the TCA; instead, it gives businesses an additional framework. The TCA already eliminates tariffs on 99% of UK tariff lines for Canadian exports. The CPTPP complements that access and, for certain products and activities, may result in preferable access to the other market. Businesses should compare the two agreements for each product or transaction and claim under the more favourable terms.

Five key aspects for Canadian businesses

1. Investment protections and ISDS access

The CPTPP protects Canadian investors in the UK through national treatment, most-favoured-nation treatment, fair and equitable treatment, and protection against uncompensated expropriation.

Chapter 9 also establishes investor-state dispute settlement (“ISDS”), allowing Canadian investors to bring claims against the UK (the “host state”) before an independent tribunal. This is a significant improvement over the TCA, which does not provide a comprehensive ISDS mechanism, and gives Canadian investors in the UK additional protection.

2. Cumulation of origin for supply chain flexibility

Under the CPTPP’s rules of origin, inputs from any CPTPP member can count toward originating status for duty-free imports. This provides more supply-chain flexibility than the TCA, which limits qualifying content to Canada and the UK.

This flexibility benefits Canadian manufacturers with multi-country Indo-Pacific supply chains. Businesses sourcing components from Japan, Vietnam, Australia, or other CPTPP members can combine those inputs to meet rules-of-origin thresholds when exporting finished goods to the UK.

3. Staged tariff reductions and choice of agreement

Canada’s implementing legislation adds the UK, the Channel Islands, and the Isle of Man to the countries eligible for preferential tariff treatment under the Customs Tariff. Tariff reductions on a broad range of goods will be phased in, with the staging schedule varying by product.

Businesses can compare CPTPP and TCA tariff rates and choose the more favourable treatment for each product.

For Canadian agri-food exporters, the CPTPP improves on the TCA in several concrete ways: additional duty-free tariff-rate quota volumes for certain meat products; immediate duty-free, quota-free access for sweetcorn (previously subject to a permanent TRQ under the TCA); preferential treatment for poultry and egg exports to the UK; and a more liberal pathway to origin for agricultural exports, including certain processed fish products that cannot access the UK market under the TCA at all. For UK agricultural exporters, CPTPP accession provides crucial access to Canadian CPTPP tariff-rate quotas (“TRQs”) covering key dairy categories, including tariff-free quota volumes for cheese, cream, and butter.

4. Services market access in the UK

Canadian service providers gain access to key UK sectors, including distribution, construction, and architecture. The CPTPP provides those suppliers with treatment equivalent to domestic providers in covered UK services markets, reducing barriers to expansion.

The CPTPP also expands temporary-entry options for Canadian businesspersons travelling to the UK: business visitors may stay up to 90 days in any 12-month period; investors may stay up to one year to establish or manage an investment; spouses of intra-corporate transferees may enter and work for up to three years; and highly skilled professionals on short-term contracts may stay up to 12 months—double the six-month limit under the TCA.

5. Government procurement opportunities

The CPTPP gives Canadian businesses access to UK public procurement at all levels of government, including regional and local authorities. The UK’s procurement schedule covers goods, services, and construction activities by central and sub-central government entities and public utilities above specified thresholds. The CPTPP procurement chapter requires the UK to treat Canadian suppliers no less favourably than domestic suppliers on covered contracts—ensuring open, fair, and transparent competition.

This expands meaningfully on the TCA. While the TCA (which replicates Canada-European Union Comprehensive Economic and Trade Agreement (CETA)’s procurement obligations) already provided Canadian firms with access to UK central and sub-central government procurement, the CPTPP broadens coverage in key areas, including architecture, engineering, and infrastructure. For example, a Canadian engineering or project management firm bidding on a UK regional infrastructure contract above the applicable threshold now has treaty-guaranteed non-discriminatory access. The procurement of NHS healthcare services remains excluded.

Five key aspects for UK businesses

1. Cumulation of origin and supply chain reconfiguration

The cumulation provisions apply equally to UK manufacturers. UK manufacturers can similarly combine inputs sourced from across the CPTPP bloc to meet rules-of-origin thresholds when exporting finished goods to Canada.

This is particularly relevant to sectors such as vehicle manufacturing and green technology, where multi-country supply chains are common. The CPTPP’s flexible rules of origin may also increase the uptake of preferential rates among smaller firms that previously found bilateral origin requirements too complex to navigate.

2. Digital trade and cross-border data flows

The TCA does not include dedicated digital trade provisions. The CPTPP fills that gap with commitments that facilitate cross-border data flows, prohibit unjustified data localization requirements, and ban customs duties on electronic transmissions between the UK and Canada. For UK businesses operating data-driven models, these commitments provide regulatory certainty that is not available under any other Canada-UK trade agreement. As data protectionism increases elsewhere, this framework offers a competitive edge for firms in technology, fintech, and digital services.

3. Enhanced business mobility

The CPTPP expands temporary-entry options for UK businesspersons travelling to Canada. Investors may stay up to one year to establish or manage an investment; spouses of intra-corporate transferees may enter and work for up to three years; and highly skilled UK professionals on short-term contracts may stay up to 12 months—double the six-month limit under the TCA.

These commitments give UK businesses greater certainty when deploying personnel to Canada for projects, services, or investment management.

4. Financial services and services exports

The CPTPP’s dedicated financial services chapter builds on the TCA’s existing protections by extending non-discrimination commitments across all 12 CPTPP markets. UK financial services exports to CPTPP countries totalled £10.9 billion in 2022; the agreement strengthens the framework for that trade.

The CPTPP also reinforces that UK firms need not establish a local office in Canada to supply services—a commitment that, combined with provisions on cross-border portfolio management and the free flow of financial data, gives UK financial and professional services firms a more robust platform for serving Canadian clients.

5. Canadian government procurement market

UK businesses now have non-discriminatory access to Canadian government procurement at federal, provincial, and local levels, creating opportunities in construction, infrastructure, and business services.

Canada’s CPTPP procurement schedule also covers 22 service categories not included in the TCA, including hotel and catering services. For the first time under any trade agreement, a UK hospitality firm bidding on a federal or provincial government catering contract above the applicable threshold is guaranteed treatment equal to that of a Canadian competitor.

Key takeaways

Businesses in Canada and the UK should consider the following steps as the CPTPP enters into force:

  • Assess investment protections.

    Cross-border investors should review the CPTPP’s ISDS mechanism and substantive investment protections—a significant upgrade over the TCA, which currently suspends its dispute resolution provisions.

  • Explore supply chain optimization.

    Determine whether inputs from CPTPP members can count toward originating status under the CPTPP’s cumulation provisions—a structural advantage over the TCA’s bilateral-only rules of origin.

  • Review your tariff exposure.

    Compare the CPTPP and TCA rules of origin for each product and claim under the agreement offering the more favourable terms.

  • Assess procurement and services opportunities.

    The CPTPP expands government procurement access in both directions and opens new service sectors not covered by the TCA.

  • Watch for further expansion.

    Negotiations with Costa Rica concluded in May 2026, and other economies are exploring accession. As membership expands, so will the scope of preferential access for businesses in member states.

Gowling WLG teams in Canada and the UK advise on all aspects of cross-border transactions, investments, and projects. Whether you are navigating new market access under the CPTPP, structuring inbound investment into Canada’s priority sectors, or managing the interplay between the CPTPP and TCA, our integrated Canada-UK platform is well positioned to help.

If you have any questions, please contact one the authors or a member of our International Trade and Customs Group.