Section one is genuinely one of the most embarrassing things I've ever read. Life is so unfair, if only I'd been listened to, if only the EU wasn't so mean.
Anyway, onto the substance.
Section 2 a fairly useful overview of what the UK has been doing to implement the protocol, and some of the challenges faced.
Although doesn't appear to mention that one of the reasons businesses struggled to prepare is that government wasted 6+ months pretending nothing to prepare for. (TSS not even put out to tender until the summer iirc).
Section 3 says the UK has every right to trigger Article 16 of the Protocol, but won't do it now. But might later.
Okay, onto the proposals. This is the one for customs, which seems ... a bit light on detail? (A constant EU criticism of UK proposals, fwiw.) It also kinda reads like ... a tweaked version of the existing TSS model?
Similar approach to food products, but with a few extras.
I suppose the argument here is that if the UK proposes absurdly maximalist solutions the eventual compromise will be closer to your preferred outcome? I dunno.
This is the proposal to deal with competing product standards. Labelling fixes all.
... and, let's have some more discussions.
I'm just slightly confused. I'm sympathetic to some of UK's arguments - and think further flexibilities on GB->NI border necessary (I've previously suggested extending "not at risk" approach into SPS sphere, medicines etc), but this proposal lacks both detail and realism.
But I also don't expect it to elicit a strong response from the EU side. See you all again in September, I guess.
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One of the big differences from the leaked draft(s) seems to be that during the transition phase importers would now not have to pay a CBAM levy, but instead just meet a list of reporting requirements:
The EU’s new CBAM regulation probably should fall within the scope of the NI protocol, in order to prevent carbon-intensive imports dodging the new levy by entering the EU market via NI.
However, it is not clear how this would function in practice.
AND … going off today’s leaked impact assessment, we assumed correctly.
These are some of the considerations/options that the EU will need to take into account in respect of its carbon-border adjustment mechanism (CBAM) and Northern Ireland:
So unless I’m misunderstanding the UK-Australia AIP, it’s not actually duty and quota free. Long-grained milled rice being the last bastion of protectionism:
A related story: When Raab banned UK officials from attending EU meetings in the run up to Brexit, Scottish officials kept going to some anyway.
On the UK presenting a united front thing, another related story: I remember witnessing a load of ERG MPs turn up in Warsaw in a last ditch attempt to convince the Polish government to veto any UK request to extend article 50.