Dr Anna Jerzewska Profile picture
14 years trade/#customs /FTAs experience. @UK_TPO Associate Fellow. Consultant for UN @ITCnews, @britishchambers and others. Ex-big4. @TradeExperettes
Hugh #FBPE Profile picture Birger Leth Profile picture Lizzie_Bee🕷⚫️💛🇪🇺💙🇬🇧🌈 Profile picture Andy Squibb Profile picture John Case #FBPE Profile picture 7 added to My Authors
1 Jul 20
In all honesty, I’d like the Gov’s new shock and awe Brexit business readiness campaign to start in the following way:

“To all businesses, big and small,

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As of 1 Jan 2021, you will bear the full responsibility for your goods moving across the new border the UK erected with its main trading partner.

You will also be required to deal with the new barriers to trade with 3rd countries that result from us leaving the EU.

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This means all areas of international trade: customs, trade finance, meeting regulatory and testing requirements etc – it’s all on you now.

You will bear the additional costs as well as the legal liability.

Here is what we can do to help you navigate this…”

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Read 14 tweets
19 Jun 20
It’s been an interesting week for #rulesoforigin with the @Foodanddrinkfed and @nabim_flour proposal coming out.

Here is a longish 🧵on the proposal and on origin in general

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First of all, the paper is a brilliant piece of work. It’s clear, super well researched and the proposed provisions are well thought through.

Worth noting - it’s not common for an industry body(ies) to come out with a fully-fledged draft origin protocol.

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It’s sometimes very hard to get companies to engage when formulating sectoral RoO recommendations (trust me!) and industry input is really needed – so just want to commend the authors on this fantastic report.

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Read 24 tweets
18 Jun 20
On the one hand, this is good news. A deal would be welcomed.

On the other, it sounds similar to how the question of the Irish Sea border was dealt with - let's sign a deal now and worry about the specifics later

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And while it might help to break the impasse, the NI Protocol is a good example of why details matter.

What if a deal is reached while both sides have a slightly different vision of what divergence means or what the impact on EU tariffs should be?

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What if the UK diverges, the EU raises tariffs and the UK considers it unfair?
Dmitry's 🧵is spot on and while he and others are asking these Qs here on Twitter I'm a bit concerned that we'll have a repeat of the WAB/NI Protocol - details will be the price for the deal

/end
Read 3 tweets
8 Jun 20
This is a great summary of a number of unresolved logistics/ customs issues.

It demonstrates the difference between knowing what type of procedures will apply (leading to Gov's claim that companies/brokers/hauliers/ports had plenty of time to prepare)

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And understanding how the border will operate in practice.

The second point seems difficult to grasp for many officials. If you know what paperwork you need, where's the problem? Can't you just do what you do now for 3rd countries? It's just more of that.

Well not quite

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I sometimes compare it to instaling new equipment in your home. You plug everything in where it's supposed to go, follow the instructions, switch it on and.... start figuring out what you've done wrong and why it's not working

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Read 15 tweets
5 Jun 20
TL:DR
The UK Gov’s Command Paper on NI reveals some significant differences between the position of the UK and that of the EU with respect to operationalising the NI Protocol. These will no doubt spill over into the on-going future relationship negotiations.
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Some of the differences are more to do with positioning and may not be substantive. Others, such as re-interpreting the original wording of the Protocol of goods “at risk” to goods where there is “a genuine and substantial risk”, may be more substantial.
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The substantive differences concern which goods will be subject to checks, on which flows, and how the checks will be carried out to the satisfaction of both the UK and the EU; and relatedly, what infrastructure and institutions are needed.
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Read 8 tweets
4 Jun 20
On business engagement and Brexit.

On one side businesses have not been as vocal about the impact of no-deal Brexit as they could have been. Not in public.

It's been a constant source of frustration.

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The private sector has in general been quite reluctant to speak up on Brexit for a number of reasons: reputational damage, engagement in “politics”, guidance given by HQs in foreign countries etc.

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Why I fully understand these reasons, and have discussed them at length with a couple of companies, they are also the ones that will be most affected.
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Read 15 tweets
26 May 20
A couple of important points here.

The importance of properly trained and experienced customs agents is massively underestimated.

It's not only about filling in forms, it's also about what to do when things go wrong (and they do)

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Customs agents are not customs advisors. It's not their job to advise on what to put on a customs decl.

But in a situation where ca 145k firms will be submitting customs decs for the first time - they will be the first point of contact and support for a number of firms

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Many firms won't seek advice from an actual customs advisor. For budgetary/time reasons they will try to classify goods themselves etc. Yet they will be liable.
In these exceptional circumstances, customs agents will often be the only ppl sense checking the documents.
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Read 10 tweets
20 May 20
On the NI Protocol document just published (ongoing thread with initial thoughts)

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assets.publishing.service.gov.uk/government/upl…
Well yes, but also no.
NI is an integral part of UK's customs territory but it's not enough to say that the Protocol "gives effect to certain aspects of EU law in Northern Ireland on a
provisional basis" and that it's just regulatory regimes that differ.
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This is a very clever upgrade from "NI will apply SM rules in respect of trade in goods"
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Read 20 tweets
20 May 20
Before we start reading the NI Protocol implementation document, a couple points on customs and trade facilitation from yesterday's FTA draft.

There is actually quite a lot there!

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assets.publishing.service.gov.uk/government/upl…
This is def not a standard trade facilitation Chapter. It's far more detailed and includes specific provisions that exceed what's in CETA, EU-Japan or any other recent FTA.

For an obvious reason - geography (which seems to matter after all)
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The text proposes establishing a Customs Committee.

FTAs normally do but such committees focus on origin issues. Seems like this one would be a proper customs cooperation body. A forum for both sides to work on reducing friction.
This would be very useful.
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Read 11 tweets
19 May 20
I'm looking at the origin part of the UK EU draft.

Art 3.3 to be precise, on cumulation of origin.

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assets.publishing.service.gov.uk/government/upl…
UK proposal is to allow cumulation of origin (treating inputs as originating) with:

-The EU (standard)
- Developing countries under GSP (😳)
- Other partners (🥴)

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The EU part is obvious. The GSP part less so.

Under the current EU GSP programme, you can cumulate origin for the majority of products (Chapter 25 onwards so no agri) with Norway, Switzerland and Turkey (conditions apply)

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Read 8 tweets
29 Apr 20
Indeed, Gove spoke about “relatively minor difference between an FTA and WTO terms” on Mon.

While what he said was factually correct, I find Gove/ Gov embracing these facts worrying.

It’s not that simple – FTAs can make a difference to border processes. Especially this one
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The fact that customs formalities and border paperwork are almost identical under an FTA and no deal is something I and others have been highlighting for a while (read more 👇 and as always there is this table).

And that’s still very true.

freetradeagreements.co.uk/publication/th…
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The purpose of an FTA is not to simplify/facilitate customs issues.

But they lay the foundations for that by encouraging customs cooperation.

Many FTAs have customs cooperation chapters. True, provisions in them are not binding and are often on “best endeavours” basis.
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Read 14 tweets
18 Mar 20
In case any UK supermarkets/shops are struggling to come up with measures to prevent the spread of #COVID19, I thought it might be useful/interesting to share some of the things my local supermarket is doing (and perhaps other shops in France and elsewhere).

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A dedicated checkout lane for medical professionals, the elderly and vulnerable.

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Allowing the elderly to purchase goods 1h hour BEFORE everyone else giving them priority access as well as ensuring they can shop in peace and less crowded conditions.

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Read 6 tweets
27 Feb 20
Gove again with "there will be no border in the Irish Sea" and "unfettered access to NI".

But If you don't have a border in the Irish Sea this means there is no border with the EU on that side.
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Since we need to have a customs border with the EU in order to "regain sovereignty" and "take back control of our border" this leaves us with the unanswered question in terms of trade with NI
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If a good moved from GB west, how do we distinguish between goods that go to NI (our own customs territory and according to Gove without a border) and goods going to the EU?
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Read 9 tweets
10 Feb 20
Freeports are officially back.

We talked about them extensively last year when the initial idea of opening 10 #freeports post-Brexit emerged.

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theguardian.com/politics/2020/…
Just as a reminder here is my freeports thread.

TL:DR good tool but so far the UK hasn’t found a way to use them in a meaningful way – hence we let the ones we had expire.
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Yesterday trade twitter exploded with good threads on freeports. One point I particularly liked and fully agree with from @DmitryOpines below.
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Read 11 tweets
6 Feb 20
Recently I posted on third country (MFN) tariffs as a way of arguing against a claim that the EU has "very high tariff walls".
Comments under the thread made me realise a lot of ppl are still confused about non-tariff barriers and how they work
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By now most ppl know that tariffs are not the main issue. Thanks to multilateral tariff liberalisation under the WTO rounds, tariffs are much lower now than several decades ago.
Non-tariff barriers to trade (NTBs), on the other hand, have not really been tackled
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That's one of the reasons why trade facilitation efforts and the WTO Trade Facilitation Agreement are such a big thing at the moment. One of the first coordinated efforts to address NTBs.

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Read 16 tweets
5 Feb 20
That’s 100% right (given the source, not really a surprise).

I've been trying to point it out for months using the example of the UCC and its implementation period.
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To me, one of the biggest Brexit planning mistakes is the lack of actual implementation period – a period when the final outcome is known, rules are clear, legislation is laid down and all parties have time to adjust
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By this, I mean businesses, border staff, Gov, various associations and departments, customs brokers and logistics providers both in the EU and the UK. As everyone will need to adjust to this fundamental change in the way we trade with the EU.
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Read 15 tweets
3 Feb 20
When compared to which country? Singapore? Perhaps.
But the US, Japan, Australia?
The EU doesn't have "very high tariff walls" in comparison to other countries
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Here are EU's MFN tariff (tariffs applied to imports from countries in the absence of a trade deal) for all HS6 product codes

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Australia's MFN tariffs
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Read 11 tweets
27 Jan 20
Was on BBC NI with Declan Billington this afternoon to talk about NI border and whether there will be checks on goods going from GB to NI.
Think it would be good to make a clear distinction between border checks and formalities
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First, the obvious bit, a reminder. Checks are a secondary issue – they result from new rules coming into force. Once we leave (end of TP) and there is a customs border in place, we will have border and other formalities. Checks are needed as a way to enforce compliance
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Checks can cause delays and impact lead time. They can potentially lead to additional costs - either logistics costs or costs related to actual goods (especially the case for goods of perishable nature).
Yet they really aren't the biggest problem.
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Read 8 tweets
20 Jan 20
Exactly, there seems to be this expectation that the EU will offer us a tariff-free, quota-free deal just because "it's also in their interest". Without asking for something substantial in return.
We need to understand just how unprecedented such FTA would be
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Two things here. First, FTAs don't usually come with TFQF access. As many ppl have also pointed out. More importantly, this would mean that the UK, having voluntarily left the EU, is getting a better deal (tariff-wise) than Norway and Switzerland
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Both of them have access to the SM (in different ways). Both have committed to alignment with EU regulation. And yet they don't have tariff-free access to the EU market.
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Read 8 tweets
7 Jan 20
An FTA with the EU that excludes services is definitely easier but it's also very very far from a Canada-style deal.

A goods only FTA doesn't mean just excluding services. It actually means much more
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Goods and services are obviously two key pillars of a comprehensive FTA. B
B there is also have investment, various areas of regulatory cooperation, mutual recognition, IP, government procurement, all the LPF including labour and environmental provisions, SME issues etc.
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Would a quick goods-only deal cover any of these? Unlikely. A pure goods only deal will be far from comprehensive and as such is a new even harder version of Brexit.
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Read 5 tweets
23 Dec 19
It's not really about "agendas". We will no longer be a member of the EU. All countries try to protect their own interests during trade negotiations. They look to get as much as possible while sacrificing as little as possible when it comes to their own sensitive sectors 1/2
The EU (just as a the US and Japan) is really good at this. We benefited from the EU's abilities in that respect for years. Now we will be on the other side of the table. That's all. That's what we chose. 2/2
Read 2 tweets