Notice that unfettered access is only for NI-GB movements.
For GB-NI it's "best endeavours to facilitate trade".
Trade facilitation means making border processes more efficient but not removing formalities and checks.
/3
The Art mentions trade facilitation in accordance with applicable legislation and there is no commitment there from the EU to not apply the border formalities agreed elsewhere in the Protocol.
/4
The last bit is interesting - recommendations from the JC to keep controls to a minimum.
In my view, that's simply about the % of checks unless like for some SPS controls, the % of checks is defined in the legislation.
/5
One example of how this has been done was the UK Trader Scheme. The JC recommended an authorisation system for UK traders importing into the NI minimising controls on goods at risk.
/6
The PM also talks about free trade between GB and NI. Again, free trade doesn't mean no controls, no formalities, no border procedures.
We have free trade - we have the TCA.
/7
Basically, nothing in the Protocol prevents normal border controls and formalities resulting from legislation.
The commitment to facilitate trade can mean making procedures paperless, making some of the formalities more efficient, minimising the burden on traders etc.
8/8
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Indeed ROI would be "paying the price" for ensuring there is no border between north and south.
I'm not sure what the tangible impact would be on trade between ROI/EU but any costs and delays would now be for the EU MS to absorb. Significant transfer of responsibility here.
/2
And difficult to imagine this being introduced without any further consequences for the UK as it would normalise UK's unwillingness to implement the Protocol. A document the UK:
✅negotiated,
✅signed and
✅promoted domestically as a massive success.
/3
Turns out the supplementary customs declarations due this month (from this month onwards) are also a problem for the customs industry. Risk of a backlog.
/1
Traders unprepared and often unaware of the obligations.
Brokers lack capacity, often don't communicate with traders due to lack of time. Or they wrongly assume that traders know what's required.
/2
You need special authorisation to be able to submit these supplementary declarations and not every broker has one. The application process is complex.
/3
So I have a feeling many companies are in for a rude awakening this month - the first round of supplementary customs declarations for companies importing from the EU
/1
Thanks to the UK Gov's easements there was an option to defer customs declarations for the first 6 months and submit the bare minimum of data at the time of import (usually done by the carrier, logistics provider)
/2
This was to be followed by a full, supplementary declaration up to 175 days later.