“work on the Northern Irish border arrangements is far from over. A newly established Joint Committee will negotiate the practicalities of implementing the Withdrawal Agreement.”
There is a lot not yet known or decided.
From @AnnaJerzewska
blogs.sussex.ac.uk/uktpo/2020/01/…
There is a lot not yet known or decided.
From @AnnaJerzewska
blogs.sussex.ac.uk/uktpo/2020/01/…
“goods shipped from Great Britain (“GB”) to Northern Ireland (“NI”) will be subject to EU tariffs if they are “at risk of subsequently being moved into the Union, whether by itself or forming part of another good following processing”
“What that means has not been fully defined within the text of the Agreement. Article 5(2) clarifies that all goods will be considered to be “at risk”, and thus subject to EU tariffs unless it is established that they will not be subject to commercial processing in NI”...
“...or they are otherwise exempt. This is one of the areas where the Joint Committee will need to introduce practical ways of implementing the agreement.”
So NI trade bodies are complaining
Duty will apply according to where the goods end up.
How is this to be determined?
So NI trade bodies are complaining
Duty will apply according to where the goods end up.
How is this to be determined?
Special customs procedures, such as Inward Processing/warehousing, are a way to suspend customs duty at the time of import. The goods are then processed/stored & the final amount of duty is calculated once it becomes clear whether the goods are re-exported/entered onto the market
“Each product traded internationally needs to have one of the existing customs product codes (tariff lines) assigned. Product codes need to be included on every customs document. One way to determine ‘risk’ would be to divide goods based on their tariff lines.”
“The Joint Committee would need to conduct an in-depth analysis of the current GB-NI-ROI trade flows and trends to determine which tariff lines are at risk of entering the Single Market (entering ROI).”
“There are a number of challenges with this approach. 1st, this assessment would need to be periodically reviewed as trade flows change. 2nd, because when the Joint Committee sets the rules it’s in general terms, this would have to be done on the lowest common denominator basis.”
This approach would resemble current origin certification under a Canada-style trade agreement. Each time a company sends goods from GB to NI, it would have to declare (not necessarily at the border) whether they are destined for NI or ROI markets.
. the company responsible for bringing the goods into NI) and the importer that would need to be liable for the potential customs debt as they have the oversight of where the goods end up.
The method would provide limited traceability.
The method would provide limited traceability.
Companies importing goods into NI would not necessarily have any visibility as to where the goods are sold to, beyond the first sale, which might not necessarily be the last. It would also be quite difficult to enforce given no controls between NI and ROI.
What would stop a NI company from selling a product initially imported into the NI market onwards to the EU to take advantage of tariff-free access?
How could this be policed effectively. It certainly makes a market less attractive.
Then there is the “by company” method.
How could this be policed effectively. It certainly makes a market less attractive.
Then there is the “by company” method.
Companies wishing to import goods into NI could register with customs authorities. Registered companies would be able to suspend duty when goods arrive in NI (a customs guarantee might be required).
“The suspension would be available for a limited period of time, as with most special procedures. After that period of time, the importer would submit a document to the customs authorities demonstrating where the goods ended up: the NI or ROI markets.”
“Such reconciliation would be similar to the current bill of discharge used under the Inward Processing procedure. The final duties would then be calculated and collected.”
This burden is unlikely to be attractive to companies and could well inhibit trade.
This burden is unlikely to be attractive to companies and could well inhibit trade.
The 3 methods differ in terms of the administrative burden placed on companies & the degree of visibility and certainty they provide for customs authorities. With all three methods, there would be some degree of non-compliance as no checks would be conducted on the NI/ROI border
The Joint Committee is going to have its work cut out and that balancing act is going to provide ample room for dispute.
Are Johnson’s repeated claims (even yesterday) a signal that the U.K. has no intention of complying with the WA at all or a signal that he is a liar & eejit?
Are Johnson’s repeated claims (even yesterday) a signal that the U.K. has no intention of complying with the WA at all or a signal that he is a liar & eejit?
I have just seen that Anna has done her own thread so I add that here.
