So on origin, it’s getting a bit hard to keep up with all the rumours so here is where I think we are with this (correct me if I missed something)

/1 https://t.co/N5dDcbH7u7

Claiming origin.
Two ways for traders to claim origin under the EU-UK deal:

1⃣ Self-certification by the exporter (standard) – normally requires an authorisation, I’m hearing that might not be needed for UK-EU trade – waiting for guidance or more info

/2
2⃣ Self-certification by the importer (new(ish), in the EU-Japan deal and some continuity deals). UK importers have little experience with this one, but helpful guidance available given initial uncertainty around using this form of certification

/3
Retrospective claims.
For up to 3 years under each side’s domestic regulation – conditions, circumstances to be determined by both sides.

Careful here cause you might be required to have a good justification for why it wasn’t submitted at the time of import. Guidance needed
/4
Additional easements
On the UK side, this is part of the 6 months phase-in period– if you’re deferring a customs declaration you’re also deferring submitting an origin claim. If you're not deferring than origin documentation required at the time of import.

/5
Let’s be clear, this will be an area of risk for many companies ‼️

Advisors and customs practitioners will spend the next 6 months talking to companies about the need to meet rules of origin. Commercial risks here too.

/6
There is a question around the supplier's declaration.

Normally this is a document that you use if you're not the manufacturer of the product or if you rely on the origin of the parts and components you're using.

It's a way to track origin throughout the supply chain

/7
You normally need them before claiming originating status. Now we have a derogation, a simplification. And while that means more time for businesses and suppliers to understand what is needed - it's a massive area of risk.

/8
And I do not want to sound ungrateful - I'll take all the simplifications I can get but just not sure how this is going to play out in terms of compliance... It's hard enough to get these on time as it is...

/9
Interestingly the UK guidance covers EU side too. Which brings me to my last point - further simplifications on the EU side...? 🤷‍♀️

As far as I can see this is where we are for now.

/10
I keep hearing things... so this might not be over.

We still have 3.5 days left so plenty of time before all this is implemented.

/end

More from Brexit

Been waiting for 👇 🚨

Important story on what a “tariff-free” deal means in practice and why it’s not enough for two economies as closely integrated.

Tariffs are removed on goods that meet rules of origin. This is a complex and nuanced area of customs.

/1


Important to remember that trade deals (FTAs) weren't designed with such a high degree of economic integration in mind.

So some of the standard RoO provisions will seem incredibly restrictive under the UK-EU deal.

/2

Minimal operations or insufficient processing is a standard part of an FTA. Most, if not all FTAs, include a provision on minimal processing – processing not considered sufficient to confer originating status even if rules of origin have been met.

/3

It is standard procedure not to apply cumulation when goods have only been subject to minimal processing.

To be able to cumulate origin and consider the final product of UK origin, the processing carried out in the UK needs to exceed minimal operations.

/4

The level of integration between the UK and the EU means that this will have significant consequences for a number of industries.

For example, in supply chains where goods are brought into the UK from the EU and reassembled, sorted or repackaged and re-exported to ROI.

/5

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