Quick point on why is there so much confusion around NI-GB / GB-NI checks, formalities, “minimal targeted interventions” and “minimal administrative processes” under the new #BrexitDeal. Two reasons with some background to follow
/1
Reason no 1. The Gov isn't able to give one answer as they don’t know. This issue has not yet been decided and will need to be negotiated with the EU. The UK side knows what the requirements are (see point 2) but are hoping to change that.
/2
At this point, the UK side is expressing what they think it could look like/ what they are aiming for - hence the discrepancies. They know there will need to be a balance between enforcing the border and maintaining the illusion of no hard customs border within the UK
/3
Reason no 2. UCC will apply in NI. The legislation is very clear on what the import/export process looks like: safety&security decl, customs dec etc. The UK would be aiming for a derogation. There might be some problems with that.
/4
This is something @BastidonPauline heard as well - the UCC is clear on the process
There is a possibility to eliminate safety&sec decl between the UK and the EU (e.g. NO, CH) but there is no precedent (as far as I'm aware) for having only these decl and no customs decs.
/5
@BastidonPauline Another point is that if you have an export dec from GB - you then have a corresponding import decl in NI. If you have exit safety&ec dec in NI, you'll have a corresponding entry dec in GB. That's not only under the UCC and EU borders just in general.
/6
@BastidonPauline You also don't usually have different processes for dif directions of travel - requirements are usually the same when moving goods both ways.
So what does it mean for NI-GB / GB-NI?
/7
@BastidonPauline By default - without a derogation from the UCC - the expectation is that you will need a full set of forms. Whether submitted electronically or not doesn't really matter in terms of the burden on biz to prepare and provide the info
/8
@BastidonPauline It's also expected that they will work both ways NI-GB/GB-NI. There are some simplifications possible within that but again - that will need to be negotiated.
The reality, however, is that both NI and GB businesses can expect extra paperwork
/9
@BastidonPauline Lastly, on checks - as soon as you have a requirement to submit paperwork and any incentive not to comply you need a system to enforce it. It doesn't need to be done at the border but you will need to have a verification mechanism.
/10
@BastidonPauline Think of submitting your tax return if there was no way for HMRC to ever check it. So there will need to be some checks for the goods that attract tariffs / required decls.
/11
@BastidonPauline Reminder- if we want to sign trade deals etc we will at some point need to know what goods are moving between EU / UK. Not only is that an international requirement but it will be needed to comply with rules of origin under any other FTA
/12
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