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David Henig @DavidHenigUK
, 15 tweets, 6 min read Read on Twitter
This is the best explanation of "Super-Canada" to date - as it should be, given both were written by @DCBMEP - but there are a few issues to be aware of on top of the oft-discussed Ireland border issue 1/ brexitcentral.com/super-supercan…
Firstly, with regret, no chance it could be negotiated in 18 months, when CETA itself took 8 years from launch to implementation. We'd need a longer transition period 2/
Next, can we achieve full tariff and quota free trade? What is stated as an ambition is typically not fully achieved in a trade agreement, but it is certainly possible that there would be no tariffs or quotas in an EU-UK free trade agreement 3/
This though I'm afraid is incorrect. 100% tariff free doesn't mean no customs checks - indeed as @AnnaJerzewska has pointed out, for an FTA you need more checks than no-deal to make sure goods are compliant with rules of origin 4/
On services this is also questionable - that the services single market doesn't exist. In many areas it does, and typically access is much worse in an FTA than as a member of the EU 5/
Also not quite right on double testing - the clauses aren't comprehensive - or negative lists, where substantial areas of market access are not covered 6/
This is fine on customs, but there could still be delays at the border when compared to the current situation 7/
On Mutual Recognition of Professional Qualifications, FTAs typically only contain a framework within which professional bodies can discuss - this is obviously far less than the equivalent within the single market 8/
Good to recognise that Canada wouldn't do enough on financial services 9/
Interesting (and right) that EU will insist on GIs - even though this will be a problem for the US 10/
Regulatory coherence would be tricky in a UK-EU FTA. We can sign up to discussion mechanisms, but ultimately we are likely to have to sign up to specific areas we will maintain - it's not about starting with 100% compliance, but our proposed destination 11/
On dispute settlement I'm not sure sure why you want a standing court, and doubt the EU would accept this for an FTA, as it would challenge the primacy of the ECJ 12/
I'm not an expert but I'm imagine on EU programs they get a say as well as us saying what we want... 13/
It will be interesting to see what the EU will want to do on investment provisions, but I'm sure they will want some, question whether they will want us to sign up to the Investment Court System (ICS) 14/
My conclusion - it's CETA plus a bit on tariffs, and a bit on regulatory cooperation. It wouldn't be frictionless trade, or as much access as we have now, but of course it is an option - just the EU want us to sign up to an Ireland backstop before negotiating 15/ ends
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