The time to express concern over the range of new non-tariff barriers and be vocal about the fact what an FTA means for the private sector was when we opted for an FTA.
While NTBs may be a surprise for SMEs, MNCs must have known about a lot of these changes.
/2
This is simply not true. The fact that goods need to originate to be traded tariff-free under a tread deal is part of *checks notes* every single FTA out there.
Like every single one of them.
/3
While I fully understand that many SMEs just didn't realise that (Gov's rhetoric not helpful here) but MNCs?
Seriously?
I know some of the custom specialists that work for these companies. They are excellent. No way they would have failed to give the business a heads up
/4
I have often pointed out the fact that the UK Gov issued guidance incredibly late making it very difficult for businesses to prepare. There was a lot of uncertainty up until mid-December.
But it's a two-way street.
/5
If you're a large business (with a customs/int trade team) and you're surprised that this FTA still comes with a range of non-tariff barriers then I think you haven't done your homework and you probably should have.
/6
On the other hand, big business being so vocal about what non-tariff barriers mean would have been helpful a few years back.
Not saying it would have changed anything, but that was missing from the debate.
/7
Again, fully understand why that was impossible for many companies to engage in the Brexit debate (shareholders/stakeholders/politics etc) but it just sounds a bit wrong when you raise issues that you should have and could have known about a few years back.
/end
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First though, in the run-up to Jan, I was often asked about the likelihood of border distributions and kept pointing out the multitude of actors and processes involved. (Also how I start most of my presentations). Borders are complex!
/2
Everything needs to be synchronised. Especially since UK's border points are well... ports.
It's all obviously doable but it requires planning, synchronisation and coordination. And all this requires time.
So why is Shane saying the BOM is what UK Gov "hopes" will happen?
/3
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.
/2
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.
/3
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.
/2
This is because customs-related benefits 1) are available under other, simpler procedures 2) would be extremely limited as per 👇analysis by @pholmes8
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.
/2
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
/3
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
/2
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.