SME chapters very rarely (if ever) include provisions that really require an FTA - it's mostly things both sides could and should do (irrespective of a deal).
Our ports haven't changed, it's not like we have less space in Dover now than we did 5 years ago.
The nature of ro-ro traffic or logistics involved haven't changed.
The customs/SPs procedures for non-EU members haven't fundamentally changed.
/2
If you had asked someone in 2015 to outline the risks related to moving fresh products from the EU to the UK under an FTA/no-deal, they would have told you.
/3
Quick background: upgrading CHIEF (current system) to CDS predates Brexit. Introducing EU's new customs legislation in 2016 meant that new functionality required. CHIEF was also getting old and generally needed a revamp.
/2
So CDS was supposed to be ready in 2018. HMRC announced it will launch it in August 2018 and gradually move traders from CHIEF to CDS batch by batch.
that stood in the way of a compromise. Perhaps it was just the Brexit myth (sovereignty etc) or once again an example of this Gov talking itself into a corner.
I'll be very interested to see whether the UK will indeed "cave".
/2
As smn tweeted yesterday.
We've known for a while that there will need to be some movement on both sides for a deal to be reached - it's not possible for both sides to keep their current red lines.
/3
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)
/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).