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
Two reasons why we're less ready than the EU
1⃣ The sheer scale of it all. Much less changed for the EU than for the UK: legislation, guidance, certification, IT systems, the Tariff...
And yes, it was the UK's choice but there was still so much to do in such a short time
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2⃣ There was a visible difference in how both sides prepared: EU's planning and prep by relevant departments vs UK's highly politicised, centralised and ideological approach to border processes (frictionless trade, taking back control and cutting red tape)
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To me, it didn't seem like the process was led by HMRC, DEFRA etc.
Can you imagine the EU hiring a team of ppl with close ties to the Commission to come up with "alternative arrangements" for the EU-UK border? Outside of the actual departments that deal with borders?
/6
So I think a lot of time was wasted on that whereby the Dutch, French, Belgian and Irish customs focused on planning and testing and providing clear guidance to their businesses. Combined with no 1⃣ no wonder we got guidance late and run out of time
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Thankfully we got the 6 months of simplification on the UK side (although lack of guidance felt here too).
So if you're a business how should you prepare for crossing the border and dealing with all these new processes?
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A very simple answer and not entirely Brexit related.
If you're importing into a market, you read the guidance and follow requirements of that market.
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If you're importing into the EU (UK exports), you read the EU guidance. UK guidance is important as far as it talks about how you get your goods to the port (i.e. Kent permit, GVMS requirements as they are introduced).
But to get the goods into the EU - it's EU guidance
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That goes both for hauliers and logistics providers as well as traders.
And yes, it's normally the importer's responsibility to worry about domestic requirements. But under the current circumstances when everyone is confused. It's also important for UK exporters.
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For example, the @TradeHelpdesk tool allows companies not only to understand rules of origin under the TCA but also other requirements that might be applicable (e.g regulatory or labelling requirements).
To come back to the borders, it's going to be a while until we figure things out on the UK side (I'm not even going to mention NI...😬) until then the EU guidance will be extremely helpful.
/end
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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.
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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.
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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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
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
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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
/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.