Thread by @CoppetainPU

Forgive me for being puzzled by this claim that the UK-S.Korea agreement provides “total” continuity.

This text is not available yet. But so far the agreements with major trading partners don’t seem to be “total”. Am I missing something?

Thread, 1/13

https://twitter.com/LiamFox/status/1137940003454164992

For a start, deals with Switzerland, & with Norway/Iceland, do not cover services.

The one with Switzerland is only “total” for goods during the Withdrawal Agreement’s transition, not if the UK & EU have no deal, and not beyond the WA’s transition.

2/13

tradebetablog.wordpress.com/2019/02/12/uk-…

What about Norway & Iceland? All the documents and a report to the UK Parliament are here: gov.uk/government/col…

These are some extracts of what the report to Parliament says. On services:

assets.publishing.service.gov.uk/government/upl…

3/13

Then there’s this on regulatory alignment (product standards, food safety, animal and plant health, etc)

assets.publishing.service.gov.uk/government/upl…

4/13

Or in more detail, this is what it says on technical barriers to trade (product standards, labelling, regulation)

assets.publishing.service.gov.uk/government/upl…

5/13

On food safety, and animal and plant health, maintaining continuity relies on an exchange of non-legally binding side letters, the report to Parliament says:

assets.publishing.service.gov.uk/government/upl…

6/13

What do those non-binding side letters say? Note words like “endeavour not to” and “if … checks are required”. (I don’t know if this changes current practice. Someone out there will know.)

assets.publishing.service.gov.uk/government/upl…

7/13

Then there’s this on government procurement

assets.publishing.service.gov.uk/government/upl…

8/13

And this on competition and state aid

assets.publishing.service.gov.uk/government/upl…

9/13

What about rules of origin (making goods eligible for free trade between the UK & Norway/Iceland)? The report to Parliament says both sides will continue to recognise products of “EU origin” for this purpose (eg, made in the UK but with EU content)

10/13

assets.publishing.service.gov.uk/government/upl…

I’m not an expert on rules of origin, so perhaps others can comment, but it seems to me that buried in the 40-page Annex IV of the 81-page agreement is a provision that would at least affect UK exports

assets.publishing.service.gov.uk/government/upl…

11/13

Finally on rules of origin, at the end of the agreement is a joint declaration. It seems to confirm that EU participation is needed for a complete roll-over of rules of origin (incl. trade with EU). The deal is a “first step towards this outcome”

assets.publishing.service.gov.uk/government/upl…

12/13

Ending, with a curiosity for fans of geographical indications. Apparently the situations in Norway and Iceland are not the same. Iceland has agreed to protect the names of UK products listed in Annex V. Norway may already do that.

assets.publishing.service.gov.uk/government/upl…

13/13

P.S. On rules of origin: even if the UK and Norway/Iceland recognise "EU origin" for their bilateral trade, if the UK and EU impose WTO-commitment tariffs on each other's goods, the costs will be higher. And could EU exporters circumvent this through processing in Norway/Iceland?

👇🏾

https://twitter.com/StevePeers/status/1138012613412098048

Back to UK-S.Korea. The UK has released nothing so far. The Koreans have. This 👇🏽thread is based on a Google translation:

https://twitter.com/CoppetainPU/status/1138145373183234048

And earlier today the FT published this ft.com/content/4e9e0b…

It says the deal is only temporary, 2 yrs. The FT highlights problems with rules of origin ie how goods currently enjoying free trade under the EU-SKorea deal will be affected if EU content is invalid for UK-SKorea

If @mcpete's thread with the Google translation breaks, it continues here

https://twitter.com/mcpete/status/1138117019658870784