Also probably worth pointing out that the UK Gov is hoping that these benefits will result from other, non-customs related, incentives and measures e.g. tax cuts and other simplifications.
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This is because customs-related benefits 1) are available under other, simpler procedures 2) would be extremely limited as per 👇analysis by @pholmes8
Still uncertain if/how these "additional" incentives could work and whether offering such simplifications and limiting them to freeports would make sense vs making them available to a wider category of firms
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In general, referring to freeports as one of the main, if not the main benefit of Brexit is a risky move
/end
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Important to remember that trade deals (FTAs) weren't designed with such a high degree of economic integration in mind.
So some of the standard RoO provisions will seem incredibly restrictive under the UK-EU deal.
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Minimal operations or insufficient processing is a standard part of an FTA. Most, if not all FTAs, include a provision on minimal processing – processing not considered sufficient to confer originating status even if rules of origin have been met.
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Not that directly impacts exporters. As we know tariffs are paid by importers, but it affects competitiveness.
2. Process
Is pretty much the same. Unless you need an origin certificate or there are other trade policy measures in place.
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But the process has to be the same. Part of non-discrimination. So the act of exporting is clearly defined.
3. Regulatory requirements
Here it's more about behind the border barriers and things like SPS controls. This is where the difference is.
And it's significant
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Borders
When compared to no deal the deal changes very little in terms of border procedures. All formalities and checks will still be required.
Reminder - we're not starting from 0 here – both our container ports and our ro-ro ports are already congested
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On top of that, all the issues related to border readiness: lack of capacity and space, IT systems not ready, shortages of customs agents, treader readiness – have not been solved.
Claiming origin.
Two ways for traders to claim origin under the EU-UK deal:
1⃣ Self-certification by the exporter (standard) – normally requires an authorisation, I’m hearing that might not be needed for UK-EU trade – waiting for guidance or more info
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2⃣ Self-certification by the importer (new(ish), in the EU-Japan deal and some continuity deals). UK importers have little experience with this one, but helpful guidance available given initial uncertainty around using this form of certification
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What normally happens is that a claim for preferential origin is made at the time of import i.e. certificate demonstrating that the goods meet rules of origin is presented with the goods.
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There are usually options to claim preferential treatment afterwords. Retrospectively. But only in special circumstances.
This is possible under domestic legislation (amending customs declarations)
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