Thread by @pmdfoster

🚨🚨🚨🇪🇺🇬🇧🚛🚒🇪🇺🇬🇧🚨🚨🚨 serious #brexit story alert - companies now starting to see penny drop on what rules of origin does to supply chains (food for example) but Brussels seems deaf to both EU & U.K. pleading. A bellwether? 😬 Stay with me. 1/
on.ft.com/2JOIlMP

So first the problem: its a tad complicated but basically goods that are imported into UK and then 'hubbed' onwards into Ireland or other parts of the EU are facing full EU tariffs - this is particularly bad for food stuffs, which attract high tariffs. Why is this? /2

It's a function of the Rules of Origin clauses that mean that goods have to sufficiently "originate" in the UK to qualify for zero-tariff entry to EU (and vice versa).

But to qualify, you have to do something to the goods - process them or add value - not just punt them on /3

The brilliant @AnnaJerzewska does a better job than me of explaining, but the important thing is that this is a nightmare for companies that 'hub' /distribute products through the UK - and that's both EU and UK companies /4

@AnnaJerzewska So both the @Foodanddrinkfed and EU groups like @CAOBISCO_EU (chocs etc) say they want the EU Commission to fix this with a derogation/waiver that takes into account proximity and interdependence of EU/UK supply chains. /5

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU Because as @AnnaJerzewska points out, in a usual FTA (say with Japan or Canada) good don't arrive from the EU customs territory (or vice versa) and then bounce straight back across the border. It's a pretty unique situation. /6

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU It's also tough on Ireland that gets a lot of goods via UK. As Paul Kelly, director of Food Drink Ireland @FoodDrink_Irl the main lobby group for the sector. “Companies are beginning to raise this across the industry." /7

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU @FoodDrink_Irl Now. It is true that goods could "transit" through UK to Ireland/EU - so they aren't imported into UK, they're just 'passing through' - but that, it seems, is not how the system currently works. /8

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU @FoodDrink_Irl According to both @AnnaJerzewska and @SamuelMarcLowe the Commission could - if it wanted - apply a derogation/waiver sorting this out, based on previous precedents. Per Mr Lowe: “If the EU wants to resolve the issue, it could do so pretty easily with an extra clarification." /9

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU @FoodDrink_Irl @SamuelMarcLowe So what did the EU tell my colleague @Sam1Fleming when he asked officials whether this was going to be sorted?

“You can’t expect Brexit not to have consequences. The UK won’t be a distribution hub for the EU any more. EU businesses will need to stop relying on UK hubs.” /10

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU @FoodDrink_Irl @SamuelMarcLowe @Sam1Fleming So to translate from the Bruxellois, that means "touch". Brexit means Brexit mon brave. etc etc.

Not exactly clear how you quantify the impacts of this - am told clothing industry also hugely impacted on this - but the EU position seems pretty stark. /11

@AnnaJerzewska @Foodanddrinkfed @CAOBISCO_EU @FoodDrink_Irl @SamuelMarcLowe @Sam1Fleming We shall see over next year or two whether those who reckoned the barebones deal @DavidGHFrost negotiated is really something to "build on" but this doesn't feel that encouraging! ENDS