1⃣ Has no simplifications, full processes as of 1 Jan
2⃣ Is politically sensitive
3⃣ Border operating model hasn't been published
4⃣ Not given sufficient attention as considered "not a border" and politicised
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)
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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.
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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).
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.
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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.
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:
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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.
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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.
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
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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.
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