The Davis Downside Dossier
Last updated 24 February 2021
In October 2016, David Davis, the then Brexit secretary, told the House of Commons that “there will be no downside to Brexit at all, and considerable upsides”.
On this page we list the ‘considerable upsides’ and also the downsides, as we embark on Brexit after the end of the transition period – with the best possible access that we’ve been able to negotiate with the EU.
At the moment there are plenty of downsides, though the upsides are more elusive. We recognise the upsides may not become apparent just yet, but as they do we will add them to balance things up.
We also maintain a list of ‘upsides’ that the government has claimed, which are in fact fake. We call this the Brexit ‘benefit’ myths. Each one is debunked with verifiable evidence.
If you know of any specific upsides or downsides, please email email@example.com with a link to a confirming story from a reputable source.
Note, as of 8 January, the latest up or downsides will appear at the top of the list instead of being in alphabetical order. This allows frequent visitors to more easily check the latest additions.
The ‘considerable’ upsides
10. Financial services. Almost 1,500 EU-based financial services firms applied for permission to operate in the UK, with around 1,000 of these planning to establish their first UK office, according to a Freedom of Information request by Bovill.
9. Bees: Some beekeepers argue that by banning the import of live bees, this will reduce the risk of bringing pests and diseases into the country by accident.
8. Fishing: The UK has decided to ban bottom trawling – a fishing technique where nets are dragged along the sea bottom – in the marine protected area of the Dogger Bank in the North Sea. DEFRA Secretary George Eustice said, “Now that we have left the [EU] Common Fisheries Policy, we are able to deliver on our commitment to achieve a healthy, thriving and sustainable marine environment”.
7. Air Traffic Control: Revised visibility & distance from cloud. As of 20 May 2021, the UK will revert to the rules on flight visibility and distance from cloud in class D airspace that existed up to 26 March 2020. This will be welcomed by many aviators.
6. Vehicle theft: Life will be harder for international bike thieves trying to move stolen machines through ports, according to leading vehicle crime expert, Dr Ken German. Gangs who had previously exploited the ease of access to mainland Europe through ports like Dover to move stolen machines quickly into new markets will now find it harder to do so post-Brexit.
5. Tax havens: Now the UK no longer has a veto, the European parliament is pushing for British overseas territories and crown dependencies, including the British Virgin Islands, Guernsey and Jersey, to be added to an EU tax havens blacklist after the conclusion of the Brexit deal.
4. Share trading. The UK will bring trading in Swiss shares back to London in the coming weeks, marking the first significant split from EU policy on financial services since the end of the Brexit transition period.
3. Advanced warning on goods: From July this year (2021), the UK will start receiving advance data on all goods coming from the EU into Great Britain, something which has not previously been possible under EU rules.
2. Fishing: Britain’s fishermen will increase their allowable catch from British waters over the next five years, although the precise amount is disputed and some in the industry claim the new trade deal represents a betrayal.
1. Gibraltar: To avoid a hard border, Gibraltar may join the EU’s Schengen zone and follow other EU rules, while remaining a British Overseas Territory. The agreement to look at this option was announced by Spanish Foreign Minister Arancha González Laya, just hours before the UK exited the EU.
102. Clearing. Brussels will allow US clearing houses operate throughout the EU in what could be a blow to the City of London’s largest clearing agencies. The move to allow American competitors to operate in the EU will be seen as a move by Brussels to clear the way to locking out the UK’s clearing houses next year.
101. Exporters. Almost one-in-four British exporters are planning on reducing their activity in the EU or eliminating it out entirely post-Brexit, according to a new survey from the British Chambers of Commerce/Moneycorp showed that 23 per cent want to “either reduce their activity in the EU or have no activity at all” in the next 12 months.
100. Northern Ireland. A survey of 1,000 GB retailers has found that almost two thirds of them plan to stop selling to Northern Ireland within two months because of the Irish Sea border.
99. Pet food. The UK’s pet food industry is struggling to export to the EU because of red tape, vet shortages and hauliers refusing to accept animal-based products in case they are stopped at the border. By mid-February, just a third managed to export to the EU in 2021.
98. Language students. Thousands of UK students hoping to spend the year abroad are caught in limbo after facing major disruption to their travel plans due to post-Brexit red tape and costs, in respect of which universities say they received inadequate guidance from the government.
97. Shellfish: Fishermen in Cornwall say some are at risk of losing their homes because of an overnight ban on exporting their product to the EU.
96. Flower industry: UK growers of flowers and ornamental plants have warned that millions of blooms will go unharvested this year after the multibillion-pound sector was not included in a scheme to admit overseas farm workers after Brexit.
95. Trees: Orders for almost 100,000 trees have been cancelled by Northern Ireland buyers because of a post-Brexit ban on the plants being moved from Britain, according to the Guardian. The Woodland Trust alone has cancelled an order for 22,000 trees destined for schools and communities as part of a Northern Ireland greening project.
94. Eggs: Ungraded eggs, second-class eggs that aren’t high enough quality to be sent to the packing center for grading, can no longer be exported to the EU. These unmarked industrial eggs are used for fish-bait farming, rendered, or used in composting.
93. Processed Animal Protein: Farmers have been hit by the loss of EU markets for animal by-products according to the British Meat Processors Association. Rendered meat by-products going into the EU “must have been processed in a region considered as posing a negligible” risk for BSE and “At the moment, [Great Britain] does not have negligible BSE risk”.
92. Trade: There are reports that selling into the single market is becoming financially unviable for some companies. Director of trade facilitation at the British Chambers of Commerce Liam Smyth said the extra time and cost of trade with Europe had resulted in an exodus of British business from the market, which he feared would increase as time goes on.
91. Animal feed: Peter Kersch, managing director of World Feeds, Thorne, Doncaster says his business is being hampered by new red tape brought in in the wake of the UK’s Brexit deal with the EU and fears it will hit hard. Mr Kersch says “We can’t get anyone to transport our products into the EU” due to so many vehicles and consignments tied up awaiting clearance for new red tape and documentation.
90. Silk Industry: Bennett Silks in Stockport says clients on the continent will not accept the extra customs charges and duties, and will simply switch to using EU-based competitors. “Our only chance to retain EU business is to create a distribution centre in France”, which will have the effect of taking jobs and economic activity away from North-West England.
89. Distilleries: Many small UK gin and whisky distillers and suppliers are struggling to ship products to EU customers under new post-Brexit trading rules, the industry has warned. Multiple distilleries told the Financial Times that confusion over paperwork for alcohol shipments was making it next to impossible to ship single pallets of spirits to the EU.
88. Airlines: British cargo, charter and leasing airlines are losing contracts and business to EU rivals. The carriers say they are severely disadvantaged under the new trade regime because the rules allow greater freedom and flexibility for EU-owned airlines to fly in the UK than UK carriers have in Europe.
87. Duty Free limit: Travellers returning from the EU will be restricted to 18 litres of wine (24 bottles), 42 litres of beer and 4 litres of spirits or liqueurs over 22 percent in alcohol – plus up to 200 cigarettes.
86. Chemicals industry: 25 business heads have written a letter to the government expressing concerns about current plans for a new £1bn system of chemicals regulation, and warned it would “hit UK industry hard across a range of manufacturing sectors”.
85. Tax avoidance: On 31 December 2020 the UK repealed the existing law on tax transparency and replaced it by implementing the less strict OECD rules, which may lead to greater tax avoidance and lower tax revenues.
84. Trade deal scrutiny: The government has rejected a Lords amendment to the Trade Bill giving MPs greater scrutiny of trade deals. It means MPs will have less power than British MEPs had in the European parliament for all EU trade deals when the UK was an EU member state.
83. Food exports: Ian Wright, chief executive of the Food and Drink Federation (FDF), has told MPs on the International Trade Select Committee that food exports to Europe have been cut by at least half since the start of January despite the deal.
82. Charity sector: Since January, exports to the EU from ECS Textiles in North Shields have ground to a halt due to border delays, piles of paperwork and confusion over post-Brexit rules, costing charities thousands of pounds in lost donations each week.
81. Trade diversion: A Belfast deli owner has told the BBC they are now bringing a lot of our stuff in from the Republic of Ireland saying, “We can place an order on Monday and it will be here on Tuesday morning. There’s nothing to fill in – not a form, nothing at all”.
80. Overseas payments: UK residents trying to send money to banks and companies in Europe are having their transactions blocked as Brexit continues to cause hurdles and headaches. Those trying to send money abroad now have to provide an additional layer of detail when making payments as the UK is now classed as a third country under European payment rules.
79. Au pairs: Au pairs have been classified as skilled workers under new UK immigration rules and will now require a salary of at least £20,480 to obtain a work permit compared to the £100 per week plus free accommodation before Brexit, making the hiring of an au pair unaffordable for many people.
78. Motorsports: Motorsport UK says an ATA carnet will now be required to temporarily move motorsport vehicles and equipment into the EU. The carnets cost £330+VAT plus a refundable deposit of 40 percent of the vehicle’s value or a non-refundable insurance premium to cover the 40 percent proportion of the value.
77. Bees: A beekeeper trying to bring 15 million bees into the UK says he has been told they may be seized because of post-Brexit laws. Only queen bees can now be imported, rather than colonies and packages of bees. However, there is confusion over whether bees can be brought in via Northern Ireland. DEFRA is working with the devolved administrations to find a solution.
76. Investment funds: London’s smaller investment managers, who have not set up subsidiaries in the EU are struggling to negotiate new post-Brexit trading arrangements in order to continue serving European clients. Smaller funds have been hit disproportionately hard by the omission of financial services from the Brexit trade talks because they have been less able to prepare contingency plans.
75. Fashion: The UK’s £35bn fashion and textile industry is facing “decimation” as a result of red tape and travel restrictions thrown up by the new post-Brexit trade agreement with the EU.
74. Theatres: UK theatres have called for urgent clarification over post-Brexit touring provisions, warning of a major threat to the country’s previously thriving performing arts sector. They say, “even with a Brexit deal, significant obstacles have emerged that threaten our world-leading performing arts exports and imports, which also puts their economic, social and cultural contributions at risk”.
73. Shellfish: The European Union has told the UK shellfish industry that thousands of tonnes of oyster, mussel, clam, cockle and scallop exports are banned from the bloc indefinitely. British fishers, who had been told by government to expect the ban to last until spring, are warning this will be a fatal blow to their businesses. (See also item 25)
72. Ireland: Goods shipments from Britain to Ireland halved in the first month of post-Brexit trade. Despite the exceptionally low inflow of goods from Britain, hauliers were required to provide 760,000 import declarations of various types — more than 43 certified documents per truck — to gain entry to Ireland.
71. Driving: France is allowing UK residents using UK driving licences to continue to do so until the end of this year, but afterwards when the UK licence expires, as photocard ones do after 10 years or when the driver reaches 70 and every three years after, it cannot be renewed to a French address and cannot be swapped for a French licence. The only legal options will be to stop driving or take a French driving test.
70. Steel: Some steel products exported to the EU could face crippling post-Brexit taxes within months, the sector has warned. UK Steel said it was “likely” that for some products, export quotas – the amount allowed under the terms of the trade deal permitted to be exported tariff free – would run out in the first quarter of 2021, after which exports would face a 25 percent tariff.
69. Defence: The Ulster Unionist Party has said that, under the Northern Ireland protocol, the UK Ministry of Defence must now give 15 days’ notice and fill out customs declaration forms before it moves military equipment from GB to NI.
68. Delivery times: British factories reported the steepest increase in supplier delivery times in a survey published by IHS Markit last week for the UK, France, Germany, Japan, Australia and the USA. IHS Markitt say this is almost exclusively linked to both Brexit disruption and a severe lack of international shipping availability.
67. Japan: Nikkei reports UK car production at its lowest in 20 years “thanks to Brexit”, and coronavirus has added to the declining trend due to uncertainty over EU withdrawal. It is unclear if, after the proposed switch to electric vehicles, Britain will remain attractive as a production base. Toyota and BMW are reportedly reconsidering their optimal strategy and there is no guarantee the next models will continue to be made in the UK.
66. Banks: EU banking authorities have granted open-ended equivalence to US securities clearing houses allowed them to serve investors in the EU. It contrasts with the time-limited agreement granted to UK clearers and raises fears that UK banks will lose out, putting at risk London’s role as a dominant financial centre.
65. Steel exports: South Yorkshire and Derbyshire bosses brand the Brexit deal a ‘total disaster’ set to cost jobs and close companies. Some businesses have already lost customers after the UK left the EU, bringing new inspections, delays and swathes of declarations, tariffs, fees and VAT payments.
64. Pigs: More than 100,000 surplus British pigs have been backed up on farms around the country by Brexit border problems. According to the Financial Times, UK farmers blame increased bureaucracy for a drop in exports as an influx of cheap European meat hits prices.
63. Fishing (Immingham): Delays due to new Brexit rules mean that Icelandic exporters are moving seafood to Europe through Rotterdam instead of Immingham, in North East Lincolnshire. Until December, Icelandic fish has been regularly shipped to Immingham, loaded onto trucks and driven to France and beyond. This is now going straight to the EU market in Europe via Rotterdam.
62. Fishing: Lough Neagh eel fishermen will have to find new markets for a fifth of their catch due to Brexit and the operation of the Northern Ireland Protocol. It means finding new buyers for 50 tonnes of eels, worth £500,000, just months before the start of this year’s season.
61. VAT: An engineering company is now being charged VAT at 22 percent on imported goods manufactured by its Italian sister company, which are then sold to another EU country, because it is a UK entity, adding 22 percent to their costs. Managing director David Lee said in a competitive market this is “an absolute killer.”
60. Yachtsmen. Almost 900,000 UK boaters are due to be hit by restrictions on how long they can stay in Europe after the Brexit transition period ends on 31 December 2020, a new survey by the Royal Yachting Association (RYA) has found.
59. Credit cards: Mastercard will increase fees more than fivefold when a British shopper uses a debit or credit card to buy from an EU-based company, sparking alarm among companies that rely on online payments and concern among MPs over higher consumer prices.
58. Fishing: Boris Johnson has unveiled a £23m fund to compensate the fishing industry for losses caused by Brexit red tape as Scottish seafood hauliers descended on Downing Street to protest.
57. Online retailers: UK retailers could abandon goods that EU customers want to return, with some even thinking of burning them because it is cheaper than bringing them home. They say the new EU trade deal has put costly duties on returns at a time when firms are already struggling.
56. Exporters: British-based exporters are being advised by the Department of Trade to register new entities inside the EU single market, from where they can distribute their goods far more freely while avoiding the extra charges, paperwork and taxes resulting from Brexit.
55. Wine: UK drinkers face paying up to £1.50 extra a bottle on many European wines while choosing from a reduced range, merchants have warned, as the burden of post-Brexit paperwork takes effect.
54. Dover: Residents feel “betrayed” and “trapped” by the “lies” of the government over Brexit after being told of a huge new lorry park capable of holding up to 1,200 trucks is to be built in a rural idyll which they say will destroy the quality of their lives and wreck the environment.
53. Business travellers: UK business people who intend to carry out paid work in the EU will now need to comply with a host of complex national rules including an ‘economic needs test’ in some cases. The new arrangements have been described as “fiendishly complicated” by Catherine Barnard, professor of EU and labour law at the University of Cambridge.
52. Hauliers: EU hauliers and transport companies are turning their backs on UK business because they are being asked to provide tens of thousands of pounds in guarantees to cover VAT or potential tariffs on arrival in Britain.
51. Artists: British performers will be unable to work in EU countries without a permit. Actors, musicians and comedians fear the new trade will severely curtail the ability of performers to tour in Europe, and will hamper the recovery of the arts after the devastating impact of the pandemic.
50. Horse racing: Relative to arrangements prior to 31 December 2020, the process of moving horses between the UK and the EU is considerably more administratively complex and time consuming according to the British Horse Racing Authority.
49. VAT: New rules mean goods shipped to EU countries are now liable for VAT when they enter the single market. Tax experts VAT IT estimate the levies could add £34bn ($47bn) to the cost of UK trade with the EU.
48. British expats: Britons living in the EU face financial headaches as European banks hike international payment fees and British banks close their accounts.
47. Galileo: Britain has lost access to the encrypted public regulated service of the Galileo global navigation satellite system and will no longer be able to play any part in the future development of it.
46. Ferries: Stena Line has redeployed a ferry, the Stena Embla, away from its intended Birkenhead to Belfast route to meet extra demand for direct shipments from Rosslare to mainland Europe, as traders change supply chains to avoid additional paperwork in Britain.
45. Aviation: UK airlines can no longer offer services between EU member states (eg London-Frankfurt-Warsaw) or domestic services within them (eg Paris-Marseille) and have lost the right to operate onward passenger services from EU member states to destinations in non-member states (eg London-Amsterdam-Bangkok).
44. The Falklands: The Islands are excluded from the UK-EU trade deal. Products coming from the islands to the EU may now face tariffs. It’s a major concern for the economy of the islands, which exports 90 percent of its fish to Europe.
43. Price rises 1: Ford has raised the UK list prices of some of its models, blaming post-Brexit rules of origin tariffs according to Autocar magazine. The Fiesta ST Edition went up by £1,695 between Dec and Jan, with Puma ST getting £1,920 more expensive.
42. Spanish tax increases: UK-based owners of Spanish properties now have a 24 percent tax rate on income. This compares with a 19 percent tax rate previously, before the transition period ended. It is due to Britain becoming a third country. Spanish tax authorities will also no longer allow any expenses to be deducted, which means gross income is taxable.
41. Mobile phone roaming: The UK’s trade deal with the EU does not rule out additional costs for UK customers using their mobile phones in EU countries. The biggest UK operators have said they do not plan to reintroduce roaming charges, but the BBC says it may not be that simple in the coming years.
40. Lorry parks: The government has built a 2,000 truck capacity lorry park on compulsorily purchased land just off Junction 10A of the M2o in Kent, against the wishes of local residents in the village of Sevington.
39. Share trading: The three biggest venues in London that handle European shares saw almost all of this business (about $5bn daily) shift into the EU on the first trading day after Brexit. Chief executive of Aquis Exchange Plc told Bloomberg that 99.6 percent of its European stock trading moved to Paris, described as a “spectacular own goal” for Britain post-Brexit.
38. Food 3: A raft of red tape plus new checks at the border could add £3bn in costs for food importers, according to the UK’s Food and Drink Federation. That’s about an 8 percent increase – some of which could work its way down to prices paid at checkouts.
37. Tech start ups: For the very first time, the European Union will become a direct shareholder in startups. This will be possible via the creation of one of the biggest investment funds in Europe. Brexit Britain will not be eligible.
36. Amazon: Amazon will no longer transfer UK sellers’ goods to the EU in a move set to have major implications for merchants both sides of the border. Amazon has informed its UK sellers that “pan-European FBA (Fulfilled by Amazon) inventory transfers will stop between the UK and EU” on January 1 2021.
35. Architects: As a result of Brexit, architects from the UK will have to demonstrate compliance on a state-by-state basis before calling themselves and operating as architects. See also Professional Qualifications below.
34. Business travellers now face fines of up to €20,000 if they fail to obtain special permits for visits to conferences or exhibitions in the EU after Brexit, as there is no Brexit deal for the service industry.
33. Chemicals industry is now required to operate a separate registration system for the near 5,000 substances made by UK companies, details of which are currently held in the EU REACH database, at an ‘immediate cost’ of about £1bn.
32. Consumer safety: UK loses access to EU RAPEX rapid alert system (also known as Safety Gate)a notification system used by Trading Standards to share information about unsafe products found on the marketplace meaning more dangerous goods and toys could now enter the UK internal market.
30. Customs declarations: An additional 250 million customs declarations will now be required annually, needing an estimated 50,000 form fillers at a cost of about £7bn.
29. Erasmus: The British government has decided not to participate in the student exchange scheme know as Erasmus, for financial reasons. It will create its own cheaper alternative.
28. EU family members of British citizens no longer have the automatic right to join them to live in the UK and now have to comply with entry criteria including income requirements.
27. Exporting meat products: Exporters of food products of animal origin to the EU are now required to pay for an export health certificate for each consignment costing around £200. This also applies to ‘exports’ to Northern Ireland.
26. Exports 1: At least 50 major UK retailers, including Marks and Spencer and Tesco, are in the process of going through their products lines, to establish how many of them will now be subject to tariffs from the EU. River Island and H&M have both confirmed to ITV News they expect to pay penalty tariffs on some clothing sent between their UK and EU businesses.
25. Fishing 1: The shellfish industry now faces a bureaucratic mountain, with a wave of form-filling, certification and tariffs to deal with. Traders who sell live crabs and lobsters into the EU now expect delays caused by bottlenecks and new rules.
24. Fishing 2: The Yorkshire Post has learned Whitby fishing crews “will be worse off in 2021 than before they left the EU”. DEFRA Secretary George Eustice, Michael Gove and Boris Johnson were accused of “betraying” fisherman worse then before because they “knew exactly what they were doing when they devastated coastal communities”.
23. Food 1: The EU-UK food chain will be “slower, more complex and more expensive for months if not years” according to Shane Brennan, chief executive of the Cold Chain Federation.
22. Food 2: There is no equivalence agreement on sanitary and phytosanitary (SPS) measures to reduce or eliminate checks on agricultural goods, like the EU offered to New Zealand and Japan.
21. Football: UK football clubs can no longer sign under-18s and are restricted to only three overseas signings under the age of 21, and only six foreign players per season.
20. Freedom of movement ends: British people have lost the automatic right to live and work across 26 nations of the EU (excluding Ireland).
19. Freight costs: The cost of moving freight from France to the UK surged to more than four times the usual level, after Brexit and a virulent new strain of the coronavirus complicated supply chains.
18. Manufacturing: After 1 January 2022, manufacturers will need to meet two different standards and will have to label products UKCA for the home market, and CE for those exported to the EU, adding costs to certification, manufacturing and stocking.
17. Meat exports: Government guidance on Brexit, updated on 28 December, states that UK producers of “chilled meat preparations”, are “prohibited” from exporting their goods to Europe as of 1 January. This includes chilled raw sausages, chilled mince, ungraded eggs, and some unpasteurised milk.
16. Medical insurance: UK holidaymakers travelling in the EU now need medical insurance cover. Failure to take out the necessary insurance could result in hospital bills of £2,000 for food poisoning or £14,000 for a heart attack.
15. Mutual recognition: There is no mutual recognition of conformity assessments any more. British authorities are unable to certify goods made in the UK meet EU standards adding costs to domestic manufacturers and suppliers.
14. Netflix: Because the UK is no longer part of the digital single market, cross-border portability of online content ceased to apply from 1 January. UK users travelling to the EU will be unable to access the UK streaming library.
13. Northern Ireland (Irish Sea) customs border: Collectively, traders now need to file 11 million new customs declarations for goods moving from Great Britain to Northern Ireland.
12. Packaging 1: All wood packaging materials including pallets must now be heat-treated and marked according to the ISPM15 international standard. Any business that does not comply could face shipments being rejected and, in some cases, fines.
11. Passport queues: Britons are no longer allowed to use fast lanes at European airports and Eurostar terminals.
10. Pets: To visit the EU, dogs now need to be microchipped and vaccinated against rabies, with a health certificate issued by a vet 10 days before the visit. They must go though a designated TPE (travellers point of entry).
9. Professional qualifications: There is no mutual recognition of professional qualifications any more, which means professionals with UK qualifications no longer have the automatic right to practice or work across the EU27.
8. Road hauliers: UK operators are now only able to conduct one cabotage trip in the EU, while EU trucks have the possibility of doing two cabotage trips in the UK after a loaded inbound movement, according to the Road Haulage Association.
7. Rules of origin: To avoid tariffs, British exporters to the EU need to comply with complex rules of origin to provide evidence of sufficient local content to qualify for tariff exemption.
6. Safety and Security declaration: Around 250 million safety and security declarations now need to be made by UK hauliers, adding extra costs to 50 percent of our exports.
5. Second home owners: UK citizens with second homes in the EU are now only allowed to spend 90 days there, in any 180 day period.
4. Seed potatoes: The EU has banned the import of seed potatoes, in a move which will be a “disastrous Brexit outcome for Scottish farmers”, First Minister Nicola Sturgeon claims.
3. Sky streaming services: We are no longer entitled to stream Sky TV outside the UK using Sky Go, Sky Kids, Sky Sports, Sky Sports Mobile TV and Sky Sports Box Office apps. Some Sky apps allow you to download your favourite shows and movies over WiFi before you leave home to watch offline while you’re abroad. This also applies to other streaming services (see Netflix above).
2. Trade 1: Over 150 UK and EU firms have dramatically changed plans due to Brexit, including many who now refuse to supply goods to the UK. The list was compiled by Edwin Hayward, author of Slaying Brexit Unicorns.
1. VAT: EU exporters to the UK are expected to collect the tax at source, and pay to register for the scheme. Most won’t, unless we form the bulk of their market, so “we do not ship to UK” will become more common. This could provide a small boost for UK operators, if they can fill the gap, but it limits consumer choice. (Also see Trade 1 above)