First thoughts on the new version of the Border Operating Model
Nothing has changed – it's all additions to the previous version.
We’re getting a lot more info on infrastructure – sites for transit, SPS checks etc.
/1
This is helpful as it will allow businesses and intermediaries to plan for their trade lanes. Especially for businesses planning to use transit or needing additional checks
/2
Nothing on NI - but we knew that in advance.
New info on so-called multi-functional inland infrastructure sites - their function (on 1 Jan as well as 1 July) and location.
/3
More info on a number of important topics :
- Delayed customs declarations
- Liability
- Poor compliance history (definition for the purpose of deferment account applications - important!)
- Bulk declarations
- SPS checks from July
/4
Also new info on what HMRC refers to as "the artist formerly knowns at the Smart Freight System" - the new "check an HGV is ready to cross the border" system.
This will be important for Kent permits - AFIK this will be the system responsible for that
/5
On the whole, this looks like it's going to be helpful.
Unanswered questions remain but HMRC/Gov well aware of that.
Still, particularly the info on sites should help biz to better plan which goods need to go through which post/ site/ exit/entry point. That's important
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The point (TL:DR) of this longish thread was this – it’s not about becoming a hub for trade deals. It’s not about signing as many FTAs as possible – that by itself has never worked for any country. This is step 1 – creating opportunities.
Even at the most basic level, there is a second part to this - ensuring that companies can use these opportunities, they know about them and have the possibility to use them. Creating access to these opportunities.
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And this is where the Gov does not have a very good track record – i.e. communicating with biz regarding upcoming changes and ensuring that biz are prepared for them.
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There is also an interesting point around the benefits of being a free trade hub (a country that has a high number of trade deals). It's different from being a hub for trade or manufacturing and doesn't always translate.
/2
Let's say we sign all these deals, and let's put aside their relative impact on the UK economy vs impact of leaving the EU debate for a moment - we will never be a global manufacturing hub given the cost of UK labour and where we sit in the global value chains.
/3
Unfortunately, that's a "no" on cumulation. Although not unexpected. The EU was never going to agree to this although I must say if there was one industry where I thought it could be possible - it was the auto sector.
/1
So there is only one route to cumulation that remains open for the UK - and only with some countries. The good old Pan-Euro-Med agreement. Seems like the only option for anything above bilateral cumulation with the EU
/2
On the plus side, the long-awaited upgrade of PEM rules has finally been achieved.
Meaning then PEM should now be a much more attractive option for the UK than beforehand.
/3
Was thinking about UK-EU post-Brexit customs cooperation earlier today, prepping for a presentation on obstacles to trade facilitation and implementation of FTAs in Africa.
Oddly enough a lot of the same points and challenges remain. Whether it's AfCFTA or the UK-EU deal
/1
In both cases, when all is said and done and the agreements signed and ratified, trust will be what determines the level of success
✅ Between customs authorities
✅ Between customs authorities and traders
/2
The level of confidence you trading partner's customs authorities have in your traders and your own processes determines how they treat your goods at the border.
In reality that often has less to do with the trade deal and more with the dialogue between the two countries
/3
For exports, information is generally provided in advance. You get a purchase order, you pack the goods, you submit and export and exit declarations in one and you send your goods away. Simples.
/2
With last-minute orders, there might be a bit more pressure but it's still doable.
Worth mentioning - trucks don't normally show at the border with no paperwork and hoping to export goods.
/3