, 14 tweets, 9 min read Read on Twitter
In response to @Jim_Cornelius' tweet a longish one on @GregHands interview on Newsnight last night (and the proposal in general).

TL:DR I get what they are trying to do but I have some genuine questions/concerns /1
@Jim_Cornelius @GregHands On the proposal and the integrity of SM – yes the proposal protects it in theory, on paper. But 1) smuggling will be hudge problem - how will the revolving patrol know if the car they stopped is an SME who is exempt from customs procedures and tariffs or a smuggler?
/2
@Jim_Cornelius @GregHands 2) Requires the EU to agree to unprecedented derogation from the UCC. Both in terms of how existing procedures work & exemption for SMEs. Think of it this way – customs declarations thresholds are going down in general.
/3
@Jim_Cornelius @GregHands How will SMEs trading across other EU borders respond to the fact that they have to pay duties and declare while SMEs in NI don't? E-commerce trade also at a disadvantage here.
The SME exemption was welcomed but might be problematic for that reason.
/4
@Jim_Cornelius @GregHands Onto other issues. In general, some differences between what Greg is saying and what’s in the proposal. Number of points he mentioned clearly to be worked during the TP – so this at this stage, not part of the actual proposal just of the AAC plan.
/5


gov.uk/government/pub…
@Jim_Cornelius @GregHands The aim is to make customs formalities more like a business transaction/income tax/VAT returns. I get that and this is hopefully where customs is heading BUT 1) Putting the horse before the cart, not in line with what the EU is currently doing on its borders, derogation needed
/6
@Jim_Cornelius @GregHands Also, VAT returns/income tax are retrospective. Here we’re talking about pre-lodged declarations. I.e. businesses need to complete additional customs formalities BEFORE. Not quite the same as just making a business transaction and no system available that
/7
@Jim_Cornelius @GregHands gathers all customs info when biz transaction is made. Restricts businesses especially those that move goods across the border several times a day. Gov might be planning to postpone the payments of tariffs but unless declarations can be aggregated too it's still admin burden
/8
@Jim_Cornelius @GregHands AND Aggregating #customs declarations would mean more risk from EU's perspective and even bigger derogation from the UCC
/9
@Jim_Cornelius @GregHands On the no infrastr bit, to which they’re clinging on by their fingertips – “other designated places” =some sort of customs centres inland. Needed for traders not authorised to do so on-premises. Traders should have somewhere to go to speak to a customs officer and get help
/10
@Jim_Cornelius @GregHands All of the technology is def not in place- we have sys to submit declarations but def not to track goods moving. This we don’t currently do. New sys (could be based on existing tech) needed to enable tracking goods in transit without scanning the barcode at the border
/11
@Jim_Cornelius @GregHands Same discussion we've been having with the AAC for months- would appreciate it if they would just simply say - "no such solutions at the moment cause they weren't needed before but we think we can make it work using existing tech" rather than "it's all in place" - it's not
/12
@Jim_Cornelius @GregHands (Trusted trader scheme obv is not “technology” but customs programme.)
Greg keeps saying there will be no checks but from the proposal and even PM’s speech yesterday it’s obvious there will be some, risk-based checks.
/13
@Jim_Cornelius @GregHands Finally, on the GFA it’s down to how you interpret it and the term hard border.
Seems like the exam question was "how to eliminate border infrastructure" not "how to make it as seamless as possible for businesses". I would have opted for the latter
/end
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