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1. The US-UK trade deal submissions are now closed, but shall we look at the trade deal preparations from the other side of the Atlantic?

(Thread)
2. Firstly, let’s look at the 2017 Impact hearing.

There was testimony to say that leaving the EU will disrupt the financial industry. That many US companies invest in the UK for the Single Market and may rethink their presence if this changes.
3. The capacity that the UK has to do all the things it needs to do will be stressed.

A messy divorce between the EU and the UK would disrupt US jobs, trade and investments while impairing our allies’ ability to meet the problems of the world.
4. A Cato institute representative suggested the US and the UK have many shared values and there is a better chance that the UK will open its markets to GM food and hormone treated beef.
5. Along with neutral commentators the hearing had a pro-Brexit contributor. His evidence was met with the suggestion it was romantic view of times past. A claim he strenuously denied through idealised WW2 imagery.
6. All respondents were, however, positive and subsequently the US began a public consultation. The submission process completed this week.
7. Starting with agriculture submissions:

The American Sugar Alliance would like to see USMCA provisions on Sanitary and Phytosanitary (SPS), Technical Barriers to Trade (TBT), biotechnology, geographical indications (GIs).

But Sugar and the sensitive SCPs should be excluded.
8. US grains say ‘No deal’ is looking closer and this will have a negative impact on the UK, the US, and the world.

Parties should consider domestic support with minimal or no trade or production effects.

With efforts to resolve outstanding SPS disputes.
9. The UK should drop the hazard based approach to pesticides.

The US should seek the elimination of tariffs on ethanol and the removal of any antidumping duty.
10. The UK should abandon its current risk process with regard to biotech.

It should allow Low Level Presence (LLP) contamination in the food it imports.

It should Recognise Plant Breeding Innovation

It should agree mutual recognition for safety determination.
11. The National Confectioners Association want the UK to abandon Meursing code

Rules of Origin should be value added and tariff heading based (with specific examples)

Remove originating status from Least Developed Countries (LDCs).
12. The NCA also want the UK to abolish warning labels on colours and mandatory labels on traceability. It also believes the US should open up the sugar market to the UK.
13. The America Farm Bureau Federation call for the elimination of all tariff and non-tariff barriers

Removal of SPS restrictions on Beef, Pork and Poultry

Change the UK authorisation procedure and except Low Level Presence

Removal of Geographic Indicators
14. The National Pork Producers Council want the UK to remove the ban on Ractopamine Hydrochloride, remove the requirement to test for Trichinae, and remove the ban on anti-microbial or pathogen reduction treatments.
15. They also want the UK to remove the Non-Commingling Requirement

The Pig Heart Incision Requirement

And should not implement planned legislation banning imports of live animals or animal products from any country that permits the use of antibiotic treatments.
16. The National Potato council ask for the removal of tariffs, the removal of the existing hazard based approach, and the acceptance of both genetic modification and Clustered Regularly Interspaced Short Palindromic Repeats (CRISPR)
17. The American Pistachio Growers requested that the deal ensures the UK diverge from its existing Maximum Residual levels. It also wants the UK to change their test procedures and relax their Aflatoxin limits.
18. The National Cattlemen's Beef Association want say that cannot continue to justify the continued application of non-science-based standards on U.S. beef, especially in the U.K. once they leave the E.U.

They also seek mutual recognition of safety standards.
19. The American Feed Industry Association wants the UK to reduce its restrictions on animal coproducts used for animal consumption.
20. Sanitary and Phytosanitary issues feature more than any other issue raised in the public consultation.
21. With Maximum Residue Limits being one of the more common issues cited.
22. In the area of alcohol, the Distilled Spirits Council is looking for a single set of label regulations
23. Moving on to services:

There is not much variance in service requests. With financial services and digital services dominate the submissions.
24. The Maritime coalition are seeking an exclusion for their domestic operations, but it’s not immediately clear if they expect the US to try to unilaterally open the UK market in maritime and maritime services.
25. The National Foreign Trade Council would like the deal to have a Delivery Services Annex.
26. There are requests for Direct Selling, a distribution service where companies outsource their sales and sales management teams.
27. In terms of the arts, Sound Exchange is seeking full national treatment for music artists in the UK. (The impact hearing suggests that this some political backing)
28. The Motion Picture Association of America wants the US to avoid any unnecessary cultural carve outs.
29. Various organisations representing the Antiquities field want to remove rules implemented to prevent looting in the Middle East and replace it with a self-certificate system.
30. The Air-Conditioning, Heating, and Refrigeration Institute wants the UK to change the way it adopts standards because the Vienna Agreement and the voting dominance of the EU gives the EU an advantage in the ISO and the IEC.
31. Some retail companies have requested stronger parallel import laws to control non-counterfeit products being imported from another country without the permission of the intellectual property owner.
32. Labour provisions do not appear much in the submissions, but there are requests for different visa regimes and even the suggestion of introducing freedom of movement from the Mercatus Center.
33. Geographic Indicators were unpopular amongst the respondents
34. Feelings were more mixed on Investor-state dispute settlement. (Due to it being particularly politically unpopular in Washington at the moment, it is likely it won’t feature in a UK-US deal)
35. I can’t do digital full justice in this thread, but needless to say it includes requests similar to the CPTPP provisions. (Force transfer, Data Localisation, Prohibiting Digital Customs Duties, Cross border data, cooperation etc.)
36. There are multiple submissions discussing trade facilitation, de minimis being a common concern.
37. The Express Association of America excelled themselves suggesting many facilitation improvements including convergence in Trusted Trader, Air Cargo Harmonisation, and a facilitation committee.
38. There are multiple requests for Harmonisation. A basic textual search produces this table.
39. There are multiple requests for Mutual recognition. A basic textual search produces this table.
40. Finally, the Trump trade war comes into play with multiple references to Section 232.
41. In conclusion, there are definitely some advantages to a future US-UK trade deal and the US companies are very clear what they want from it.
42. However, over a quarter of all the submissions referenced SPS with just one submission requesting that both sides were able to respect each other’s standards.
43. Now we know exactly what is being proposed by US industry, it’s time for the Department of International Trade to specify what they will, and what they won’t, negotiate in clearer terms than they have done so far.

/End
Incidentally, if you missed it, there is a similar thread on Australian submissions here.

Also, there were many submissions to the UK trade deal consultation that were almost identical to the submissions for the EU deal equivalent.

I recommend David Henig’s thread here.

(Some things may look more familiar now)

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