The Irish Sea border needs to be fully operational on 1 Jan. No simplifications, no phase-in period. Everything needs to work.
The contract for TSS has only been awarded a few weeks ago based on a last-minute proposal and design (the entire tender process was rushed).
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TSS will have several functions. One of them will be to provide customs advice to traders.
For that it needs consultants – that’s why the Institute of Export is hiring ppl.
You might also remember that we have a massive national shortage of ppl with customs knowledge.
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The 50k customs brokers estimated by Gov.
And this gig might not be paid as well as some other private-sector ones. So just think about it – what are the chances of getting good specialists involved?
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In addition, there is only one organisation within the winning team that has actual, practical experience with customs and border formalities. Only one…
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TSS will also be an IT system: it needs a trader interface and needs to communicate with CDS (new CHIEF) and the system that allows hauliers to submit pre-notifications – the infamous entry summary declarations.
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What are the chances of creating an IT system that has so many functions and capacity to handle that many enquiries/transactions in less than 2 months?
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Here is another interesting point, Fujitsu is the company responsible for delivering the IT side of TSS.
If that name sounds familiar in the context of a large Gov-sponsored customs IT projects, that’s cause Fujitsu are the company behind CDS.
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Reminder – CDS is the long-awaited and delayed replacement for the current customs system CHIEF.
As per 👇National Audit Office report, HMRC planned to COMPLETE migrating traders to CDS in January 2019.
We're still nowhere near that.
/9
Another IRISH SEA BORDER update. Heads up for all NI and Irish businesses - on mandatory transit and clearance in NI.
This one is a bit technical but bear with me.
(h/t @tconnellyRTE for helping me look into this a bit deeper)
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Having spoken to a number of organisations including BIFA and BCC, most of us assumed that under the NI Protocol once the goods arrive in NI that's it:
goods at risk pay EU tariffs and they are cleared and can move south to the ROI.
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In hindsight, it was probably wishful thinking but it did seem like that was the point of having the "at risk" category in the first place.
Well, that's not how it's going to work. This will be much more of a hard border.
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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.
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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.
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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.
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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.
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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.
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