One more thing to point out re EU vs UK border readiness is that HMRC used to be really good at this sort of thing (communicating with traders, providing guidance)

/1
A couple years back when the EU’s customs legislation was changing and MS needed to implement it HMRC was doing really well and provided clear info on time.

/2
Only a couple years back HMRC had a number of helplines and services helping traders and consultants like me to understand the official interpretation of the legislation (customs can be highly contextual).

They had amazing experts.

/3
There have been some changes in recent years – e.g knowledge drain, cuts, closures of regional offices and centralisation.

But I still think there is strong expertise within HMRC.

/4
My guess would be the delays result from HMRC not being allowed to do what they should have done rather than anything else.

(h/t @InfraNeka for asking bout it last night)

/ends

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More from @AnnaJerzewska

29 Oct
An all-day webinar today with the Belgian, Dutch, French, and Irish customs authorities (as you might have noticed by my earlier tweets).

You know these traffic management systems we're trying to build in the last few months of this year? The have them ready.

/1
New customs officers, hired and trained.

New veterinary stuff needed for SPS checks? No problem, already hired.

Oh and Border Control Posts for SPS controls already built.

/2
Ports ready and processes in place.

Guidance for traders available for months. Direct comms sent to traders. Helplines! They have helplines!

Clear answers re forms and requirements.

/3
Read 7 tweets
27 Oct
Cause the last few years of CDS delays taught us nothing...

This will come as a shock to very few ppl but a couple of months is not enough time to build a new IT system, test it, train ppl and deploy it.

/1
"Haven't been given enough time and information" is the main problem everyone in the private sector faces.

It's the current mantra of companies and intermediaries

/2


It's not that preparing for Brexit was impossible, it's not even that trading under WTO terms is impossible (way more expensive and cumbersome but not impossible), it's just how insanely late we're with pretty much everything.

/3
Read 4 tweets
24 Oct
A border is not something you can decide to have or not depending on what suits your political goals- it's what separates and divides two independent, sovereign territories.

/1
NI will have a dual-status which makes that border unique and perhaps you could even argue that the whole of NI will be the border (semantics, I know) but the reason I think this tweet from an official account is irresponsible is this:

/2
We have just over 2 months to go and we're still missing crucial info about this weird, non-existing, asymmetrical border. I'm not even talking about the operating model.

/3
Read 10 tweets
24 Oct
NI Protocol explicitly prevents the creation of a border on the island of Ireland. As a result, it creates one in the Irish Sea.
If you don't agree with that - do tell where is the border between the EU and UK in Ireland - two sovereign territories - there must be one
It's possible to have a border with asymmetric formalities (very rare but nonetheless) and the NI Protocol does just that.
It provides for a range of controls to ensure the border can be diluted as much as possible.
Or at least it was supposed to cause we still don't have proper guidance, BOM or info from the JC.
Read 4 tweets
20 Oct
Short 🧵on the Trader Support Service – the Gov sponsored customs support for NI. What it is and what it will do.

The system goes live on 21 Dec (yes… 4 days before the deadline).

/1


gov.uk/guidance/trade…
I always thought of TSS in the context of Art 5 point 6 of the NI Protocol – as a way for UK Gov to reimburse, waive and compensate companies in NI for the extra admin costs.

It was to be an alternative to using a customs broker, provided for by the Gov and free for users

/2
We were initially told that the service will cover customs as well as safety and security declarations and will be available to NI traders for GB and ROW trade as well as GB traders who export to NI.

/3
Read 14 tweets
13 Oct
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)

/1
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.

/2
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.

/3
Read 11 tweets

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