New: the U.K. is claiming victory over the EU in the Brexit talks. Let's take a closer look... 1/

🚨🚨🚨🇪🇺🇬🇧🚛🚒🇪🇺🇬🇧🚨🚨🚨 serious #brexit story alert - companies now starting to see penny drop on what rules of origin does to supply chains (food for example) but Brussels seems deaf to both EU & U.K. pleading. A bellwether? 😬 Stay with me. 1/


So first the problem: its a tad complicated but basically goods that are imported into UK and then 'hubbed' onwards into Ireland or other parts of the EU are facing full EU tariffs - this is particularly bad for food stuffs, which attract high tariffs. Why is this? /2

It's a function of the Rules of Origin clauses that mean that goods have to sufficiently "originate" in the UK to qualify for zero-tariff entry to EU (and vice versa).

But to qualify, you have to do something to the goods - process them or add value - not just punt them on /3

The brilliant @AnnaJerzewska does a better job than me of explaining, but the important thing is that this is a nightmare for companies that 'hub' /distribute products through the UK - and that's both EU and UK companies /4

So both the @Foodanddrinkfed and EU groups like @CAOBISCO_EU (chocs etc) say they want the EU Commission to fix this with a derogation/waiver that takes into account proximity and interdependence of EU/UK supply chains. /5

@SpecCoffeeHouse @NicholasTyrone I think you have missed the essential point that we have now passed peak Brexit. From now on only the disastrous reality will come at us from all sides. 57% already were Remainers on the day we joined. Soon a huge majority will hate Brexit. I expect poll tax riots response level

@NicholasTyrone Already the biggest vote winner, fish , has turned out to be a disaster. We’ve ended up with a FTA smaller than the UK itself. Gibraltar joined Schengen, Falklands shafted. UK regions never wanted It. #BrexitReality . #Brexitbenefits , there are none. #Brexitears from now on

@NicholasTyrone Remember too, this was a Tory internal civil war foisted on an uninterested country that they only won because of the #Austeridiocy policy falsely foisted after the financial crash. It was a protest vote. There are no benefits to Brexit. It’s a #ToryBrexitShambles .

@NicholasTyrone There will only be one direction of travel now, back towards the EU. We are currently effectively a vassal state and #Whatsovereignty ? We have only lost it. We have also become a sprat in a puddle not the leading big fish in the big bloc, the EU. This was always a fishy affair

@NicholasTyrone Oh yes. We’re also one of the biggest jokes on the planet, and will take centre stage as the worlds biggest Buffoon departs.... #Brexitisntworking #brexitleavesbritainnaked

As the transition period ends, the #BrexitDeal applies from tomorrow. But there's also a parallel significant legal change - most of the rest of the withdrawal agreement starts to apply. A thread on the legal issues in the rest of that agreement.

The citizens' rights provisions of the withdrawal agreement (on EU citizens who moved to the UK, and UK citizens who moved to the EU, before the end of the transition period) start to apply.

Annotation and detailed analysis of those provisions here:

After today, UK citizens newly moving to the EU, or EU citizens newly moving to the UK, are in principle governed by national law (partly harmonised by the EU, on the EU side).

However, the #BrexitDeal contains some provisions on visas for service providers.

The #BrexitDeal also refers to the matching unilateral decisions of the EU and UK to waive a visa requirement for short tourist visits. Analysis of the EU law on that issue here:

UK citizens resident in the EU on the basis of the withdrawal agreement (or who move to EU in future) should be covered by the EU law on long-term resident non-EU citizens, which provides for a limited form of mobility between Member States. Analysis here: