The UK Government is planning for Border Control Posts (BCPs) in Northern Ireland - what I had told FTA members in December is becoming reality: there will be SPS checks on goods coming from GB in NI ports. Still, there are lots of details to clarify 1/ bbc.co.uk/news/amp/uk-no…
BCPs will need to be big enough to handle new volumes - that's a question of space & resources. Industry will need to know what type of products they can handle (not all products can go through all BCPs) + their opening hours. 2/
That's critical to know which BCPs (& therefore which ports) to use. Controls at BCPs are only 1 dimension of SPS requirements. Exporters will need to have export health certificates, catch certificates or phytosanitary certificates. They will need to find enough vets etc... 3/
@AnnaJerzewska The #transport dimension of the agreement shouldn't be neglected. Without a solution for haulage & air freight in particular, I don't see disruptions being minimal or lasting just a few weeks. It will be equally critical for everyone to have been able to prepare adequately. 1/
@AnnaJerzewska What's at stake won't just be border delays, however problematic that might be. Those that won't have been able to prepare will NOT be able to send their goods or receive goods across the border. Boarding or access to the terminal will be denied without the right formalities. 2/
@AnnaJerzewska Preparing can only work if companies have the space, bandwidth & means to do so + depends on having clear processes & expectations defined. We're not there yet & will need to get there very quickly for the end of the transition to happen as smoothly as possible. 3/
@mossels6 Of course I've not heard about it now for first time! But you can't possibly compare what it means for deep sea & what it means for ro-ro through the Dover strait. Crossing times are widely different & the responsibility for accompanied ro-ro falls on multitude of hauliers.
@mossels6 ICS 2 is only being implemented now for limited number of transport modes (with start in 2021), not before a few years for road, and UK is - to the best of my knowledge - not planning to move to ICS 2.
@mossels6 As to the number of data elements required, it depends on the mode of transport. For road (which also applies for accompanied ro-ro), you're looking at over 40 data elements for entry summary declarations. Including data not available by the time the declaration will be needed...
Remember the 50,000 customs agents (intermediaries, not border force officials) needed to deal with post-transition customs formalities @pmdfoster@lisaocarroll@adampayne26@alanbeattie ? We checked this with members of our customs WG yesterday - over 20 companies... 1/
...from large logistics companies to smaller haulage firms & big retailers and manufacturers. They reckon that this number underestimates the needs, if anything. It's about right if you only consider the volume of new declarations required. 2/
But it does not take into account the need for safety & security declarations - which we've since learnt will most likely be required, trade agreement or not. Nor does it take into account the fact that the low value consignment relief will be abolished at the end of 2020. 3/
Sorry @afneil but even if the UK were to leave the transition period without an agreement, it would not have 'total regulatory freedom' as you claim. The UK has signed up to many international conventions & is thereby bound by rules which set global or regional standards 1/
Many of these rules constrain what the UK Government could do, from WTO most favoured nation principle to the ISPM-15 standard for pallets and the CITES convention for endangered species, AETR rules for professional drivers to the WCO Safe Framework and many, many more besides 2/
We all live in a globalised & rules-based world, and I don't think that many countries have full & absolute regulatory freedom these days. So let's not pretend it would be the case or that the only thing required would be to leave the transition without an agreement in place.
Tariffs are only 1 dimension of the costs associated with international trade. Non-tariff barriers matter & shouldn't be underestimated - from the cost of completing declarations to additional regulatory costs + adaptation of supply chains to mitigate delays (warehousing...) 1/
And I'm not even talking about training & recruitment costs, cost of stockpiling for multiple deadlines in 2019, consulting costs etc... which are perhaps more temporary. Also consider potential additional transport costs (drivers waiting time, restrictions making journeys... 2/
...less profitable for operators, etc). For customs alone, HMRC estimated in October 2019 that the cost of making declarations for UK businesses would be £7.5 billion. @jdportes@julianHjessop@lizzzburden@pmdfoster - hard to reconcile that with £8.3 billion savings figure /3
@jjzd@davidmcallister@berndlange@CHansenEU@EP_Trade For some of the things I’m suggesting, yes. Aviation agreements are quite common (eg with the US), AEO MRA has even been granted to China, for SPS, EU-NZ is probably 2d best option after Switzerland. For safety & security, it depends on what you call alignment.
@jjzd@davidmcallister@berndlange@CHansenEU@EP_Trade Is a common approach alignment? For road, not many precedents beyond Switzerland for geographical reasons primarily (no need for one with Canada...) & lots of countries are covered by bilateral agreements instead some of which offer liberalised access
@jjzd@davidmcallister@berndlange@CHansenEU@EP_Trade And then of course you have global standards. EU approach & global or pan-European approach are often more aligned than you’d think. For instance, the UK will remain bound by AETR rules, which are aligned with EU driver hours & tachograph rules.
(trucks & vans) cld ever cross the border relying on a very limited number of ECMT permits (wouldn't even cover 5% of the traffic). The situation is just as serious for the island of Ireland since #transport is not dealt with in the Protocol part of the withdrawal agreement 3/
Frictionless trade is no longer a UK negotiating objective... not surprising based on previous declarations from the Chancellor but... 1. It raises a number of questions for NI-GB flows in particular & wld confirm what was in the UK Gvt WA bill impact assessment for GB-NI... 1/
...which was aligned with UKTF slides & what @MichelBarnier & his team said repeatedly. 2. What does this mean for the UK's negotiating objectives? No trade facilitation measures? Wld seem weird. Surely AEO MRA (or 'trusted traders' MRA) is on the table. Was in political decl. 2/
Would a safety & security agreement 'à la EU-CH' be on the table? Let's hope so, operators could REALLY do without entry & exit summary declarations - esp. for ro-ro. Surely an SPS agreement at least as good as EU-NZ is on the table? What else? And what about transport??? 3/
Disappointing to see #trade only mentioned in relation to anti-dumping & level-playing field measures + 0 tariffs & quotas in @MichelBarnier speech. Surely negotiators could do better, even in 10 months. Industry will need more than that, on both sides @StefaanDeRynck 1/
0 tariffs & quotas is important but not sufficient. You need to ensure industry can actually benefit from it (Rules of origin!). Something @Kommerskoll knows something about... Considering how prod & #supplychains are integrated, industry needs + than bilateral cumulation 2/
For #customs, a bare min. is to seek to retain the UK in the EU safety & security zone so that entry & exit summary declarations are not required. That's in line with the EU security coop objective & is vital for accompanied roll-on roll-off (Dover-Calais, Dublin-Holyhead...) 3/
Now in the drivers’ lounge - drivers will be able to check the status of their vehicle & whether they need to follow the green or orange lane upon arrival in FR on this screen @newsfromfta@newsfromftai
For the sake of clarity, #hauliers are NOT responsible for fulfilling the vast majority of #customs & #regulatory requirements needed to be admitted on board the ferry / in the port area to pick up or deliver goods. This is the responsibility of 1/ ft.com/content/0a37d1…
The #trader (acting as the 'importer' from an EU perspective). That task can be outsourced to an intermediary - of which there is a lack of in the UK so many companies are struggling to find the help they need. The #haulier needs to ensure his/her #driver is in possession of 2/
The biggest trap - on both the EU & UK sides - as contingency measures are adopted is to assume that this will make #NoDeal manageable. These measures are limited, will not last lg, and neither adopting them nor recruiting a bunch of customs officials is enough to be ready 1/
The UK myth of a 'managed #NoDeal ' & the EU myth of 'we're better prepared & it will hurt us less so we're alright' are both extremely dangerous. Adopting a few - welcome - but tporary simplifications & waivers or just repeating like a broken record that 'the UK will be... 2/
treated like a 3rd ctry' is shortsighted and naive. #NoDeal cannot be turned into an acceptable outcome, not least because the belief that contingencies & briefings provided are sufficient for industry is wrong. All these processes & principles need to pass the test of reality 3/
Shocked to see such a disingenuous story. If you had done your homework @DavidWooding@DominicRaab you would know that: 1. There's nothing secret about this, the contingency proposals were published on 19 Dec 2018; 2. It's not a deal but a set of unilateral temporary measures 1/
These measures cld be revoked unilaterally without much warning; 3. It's not agreed yet, @Europarl_EN & the Council need to agree & haven't even met yet, 1st meeting is tomorrow ; 4. The unilateral measures will expire after 1 year for aviation & 9 months for road transport 2/
While there's plenty of precedent for stand alone aviation deals, the EU refuses pt blank to consider a long term haulage agreement for aft the contingency expires. There's no solution for road haulage aft this year. Not great when you have to sign multi-annual ctracts 3/