EU trade deals require a potentially bruising process of ratification by all member states, a key opinion at the European Union's highest court said, with possible consequences for Brexit.
Britain hopes to win a fast-track trade deal with Europe after it negotiates its divorce from the EU but today's opinion, if followed by the bloc's highest court, could cripple that plan.
The view of the European Court of Justice's top advisor pertained to an EU-Singapore treaty signed in 2013.
In her opinion, Advocate General Eleanor Sharpston found that the EU-Singapore trade deal "can only be concluded by the EU and the Member States acting jointly," said a statement from the court summarising the decision.
In denying the commission's view, Sharpston said several parts of the agreement fell strictly under national competence, including "fundamental" norms involving the environmental policy.
The ECJ is not obliged to follow the advocate general's rulings when it hands down its final decision but it frequently does.
A verdict by the ECJ is expected early next year and will stand as key jurisprudence for future trade deals including any deal with Britain.
The opinion comes just months after the tiny region of Wallonia almost killed off a huge EU-Canada trade deal after years of talks.
That tussle highlighted the dangers of a marathon ratification process that involves votes in more than 30 national or regional parliaments.
The European Commission, which handles trade negotiations for the EU, saw the Singapore deal as a new standard that reflected bigger powers won by Brussels in the Lisbon treaty that entered into force in 2009.
In the commission's big plans, the Singapore deal would have only required the greenlight of the European Council, which groups officials and ministers from the EU's 28 governments, and the European Parliament.
"We are closely analysing (the opinion)," a spokesman for the European Commission said.
British Prime Minister Theresa May has insisted that Britain could negotiate its departure from the European Union and a new trading arrangement within two years.
The EU-Canada took seven years to negotiate.
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