🚨🚨🚨🇪🇺🇬🇧🚛🚒🇪🇺🇬🇧🚨🚨🚨 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/

The UK refusing to give full diplomatic status the EU's mission in London is baffling at at time when @BorisJohnson is trying to connect with @JoeBiden - because it recalls what Trump administration did to the EU ambassador back in 2019. Stay with

@JoeBiden The spat has been going for a while - we reported it in May, when the #Brexit trade talks were getting testy and - I assumed - it was the UK seeking a bit of leverage as the talks progressed. But we have a deal...and still no deal on the EU

@JoeBiden Essentially the UK government wants to treat the @EUdelegationUK as a "international organisation based in London" - and not accord it full diplomatic status, as almost every other country in the world does, including the United States /3

@JoeBiden @EUdelegationUK Indeed when EU formed it's External Action Service (EEAS) the UK supported the idea that EU representatives should be full ambassadors - a fact reflected in the Treaty of Lisbon which we signed - and which reflected on fact EU had a currency, made laws etc. /4

@JoeBiden @EUdelegationUK It took some time for everyone to recognise this, but after @BarackObama came to power in 2016 even the USA did the same....then along came Donald Trump and in 2019 surreptitiously downgraded the status of the EU ambassador @D0Sullivan /4

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So here it is. After the euphoria, the @FinancialTimes @FTMag long read of how @BorisJohnson did his Trade deal with the EU. Tl:dr...not so much “build back better”, more “build back the borders” - stay with me/1.

@FTMag @BorisJohnson The really under-appreciated part of this story is the extent to which the Johnson government, having won its 80 seat majority promising to "Get Brexit Done" then explicitly and actively chose the hardest possible version of #brexit in defiance of commercial interests /2

@FTMag @BorisJohnson Our story begins in January last year when David Frost commenced what Whitehall insiders call a "Star Chamber" process to strip away anything that might be considered more than a "Canada-style" deal - regardless of the fact that UK doesn't trade with EU like Canada! /3

@FTMag @BorisJohnson So what did that mean in practice?

Well, for example leaving EU aviation safety agency (EASA); Chemicals agency (ECHA), not getting a waiver of 'safety and security' declarations for hauliers, not seeking special arrangements for animal products...on and on it goes /4

@FTMag @BorisJohnson Didn't industry object? Well yes it did - but those who yelled too hard found themselves shut out of the door.

Did Whitehall object? Yes it did - Defra and Beis and Treasury all tried at some level to temper the revolutionary fury. But mostly failed. /5

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As #brexit talks drift towards the rocks, trade groups say plans for Irish Sea trade border after Brexit are ‘in a mess’ via, my latest via @FT ...this is an issue coming deal or no deal. Stay with me 1/


So to recap, under Northern Ireland protocol negotiated in the Withdrawal Agreement all goods going from Great Britain to NI must confirm with EU customs code. To avoid new border in Ireland, that means trade border in Irish Sea - new paperwork, new systems. Operational Jan 1/2

The problem is that because the FTA negotiations are stuck, the negotiations in the Joint Committee on how to implement the Protoocl (and @michaelgove is with @MarosSefcovic talking today) haven't yet born fruit. That means a LOT of uncertainty. /3

@michaelgove @MarosSefcovic How much uncertainty? Well, as @MichaelAodhan tells me, a lot. Research by the Northern Ireland Business Brexit Working Group (NIBBWG) found only 20% of members were ready. And its not their fault: need info on tarifs, computer systems etc. And are not getting answers /3

@michaelgove @MarosSefcovic @MichaelAodhan Now. The Government has earmarked £200m for the Trade Support Service run by Fujitsu and the Customs Clearance Consortium with @ShankerASingham @RobHardyFR8 to help business process new paperwork...BUT even it cannot answer lots of Qs, and won't help with animal/SPS issues. /4

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UK’s £35bn fashion industry warns of “decimation” from #brexit - big names sign open letter to @BorisJohnson urging action. Many of 50,000 SMEs on the rack due to VAT, customs and work permit issues. Stay with me/1


You can read the full text of the letter here, co-ordinated by Fashion Round Table @FashionRoundTab, but tl;dr it says that #Brexit has left a "gaping hole" in an industry that relies of free movement of professionals. It's a familiar cry /2



@FashionRoundTab The industry, already whacked by #COVID19, is now discovering that cross-border sales are a horror (VAT, Customs, long delays) and models, stylists, photographers that used to blat around Europe can't any more. They need permits, for themselves, for their gear /3

It is on one level amazing that this is only just fully dawning - as the musician industry found out recently - but fashion is not just big names and big companies. It's actually a mountain of small companies and sole traders often that feed into a huge (£35bn) industry /4

I've written about fashion models issue before (they need tier-5 sponsorship visas) and how that will erode London's status as a hub, but this goes so much wider than this - hence the #dontmakefashionhistory campaign - and comes down the lack of a mobility chapter in the deal /5

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:

There are a lot of Brexiters in the media this week making points about sovereignty, and about how the EU has not come to terms with the UK's independence.

I have some questions, which it might well be fruitful to ask them. 1/9

1. How do you understand the concept of sovereignty? What are the circumstances in which you might agree to make binding commitments to other independent states or trading blocs? 2/

2. What sort of commitments are you prepared to make in order to get trade deals with other states/blocs? And, to what end (why not trade on Australian-style terms with the wider world)? 3/

3. Do you accept that the EU has the right to impose its own rules as a condition for access to its market? Given the UK's involvement in the single market, and in the creation of its regulatory infrastructure, this feature should not come as a surprise. 4/

4. Do you accept that there is a need for borders (which were not needed while the UK was part of the single market) between states/blocs with different regulatory regimes? 5/

The chart-topping band of @ChrisGiles_ @jimbrunsden (me on drums) have a piece up about the Brexit level playing field stand-off. But here's the thing: the opacity surrounding these (as so many) trade talks is making things much worse. Quick 🧵

One of the things that struck me talking to experts about this was a lot of hedging about "this is what I think the EU means" and "this is what the UK appears to believe". There's lots of jargon (non-regression, ratchet, equivalence etc) capable of multiple meanings. (2/n)

And even if the negotiators have been clear with each other about what they mean, they certainly aren't being transparent with their domestic constituencies: the EU member states and Westminster MPs aren't being given full details about exactly what's being proposed. (3/n)

There's an unhelpful culture of secrecy around almost all trade talks. Few texts are released along the way. The standard reason is so not to give away negotiating positions to the other side. This is, to use a technical WTO term, obvious bollocks. (4/n)

If you're not telling the other side what you're proposing, you aren't negotiating, are you? Duh. The function of secrecy is actually to hide from the public what's going on. But how are you supposed to build domestic consensus around a proposal no-one can see? (5/n)

This is the second time in one week that I have to engage with something written by a British academic on their assessment of Brexit & Ireland. In this case @HelenHet20 in @NewStatesman 🧵

1. @HelenHet20 Europe’s vaccine crisis has revealed the true nature of the EU?? Ireland has been a member state since 1973, has had more refs on EU topics than any other country & thus its political & administrative elite knows & understands EU @BrigidLaffan

2. Said elite & electorate never idealised EU-small states are acutely aware of limits of their power & deploy capacity with care-the Swedes coined the term smart states. Small states understand they have to be smart. @BrigidLaffan

3. Since 24th of June 2016 Ireland has been shown unstinting solidarity from 26 EU states & EU institutions. During this time, its nearest neighbour tried to power it off the diplomatic pitch & kept thinking that It could peel Ireland off from EU solidarity. @BrigidLaffan

4. On the vaccine debacle & it was one the lesson the Irish will take is that having a seat at the table & voice matters-it took an Irish Taoiseach & Foreign Minister a couple of hours to sort this out. @BrigidLaffan

It's OUT! My latest #Brexit Briefing for @FinancialTimes - examining @BorisJohnson
"buy now, pay later" Northern Ireland Protocol, why the EU-UK trust deficit is killing it, how that can be restored - because it needs to work. /1

@BorisJohnson The danger here is that lingering animus over the opportunistic nature Johnson's Faustian bargain - dividing his Kingdom in order to 'get #Brexit done' and win an 80-seat majority - is clouding judgement on both sides of the Channel /2

@BorisJohnson The facts of the Protocol are no less true for Johnson's constant denial of them - that there would be checks, that there really is a trade border that now prevents plants and pets from travelling freely from Bedford to Ballymena as M.Gove reminds us. But these are other facts/3

@BorisJohnson Firstly, NI remains part of UK, even if it is now has EU customs rules.

Secondly, NI remains politically divided and fragile; the Good Friday Agreement is a constant work in progress.

Thirdly, both the EU and the UK agreed to this unsatisfactory arrangement jointly. /4

@BorisJohnson Fourthly, therefore, they have a joint responsibility to make it work because

Fifthly - and most importantly — there is no alternative to it. /5