BC UK
Saved by @Jacobtldr

Better late than never. Here we go. What does this deal mean for borders, border formalities, customs & trade facilitation?

Long one. TL:DR very little at the moment but has potential

/1

 Borders
When compared to no deal the deal changes very little in terms of border procedures. All formalities and checks will still be required.

Reminder - we're not starting from 0 here – both our container ports and our ro-ro ports are already congested

/2
On top of that, all the issues related to border readiness: lack of capacity and space, IT systems not ready, shortages of customs agents, treader readiness – have not been solved.

The deal doesn’t help with that.

/3
Here is where we are:
☑️The UK will phase-in border formalities over 6 months (customs and SPS)
☑️The EU will introduce full formalities in 3 days (customs + SPS)
☑️Irish Sea border also fully operational in 3 days with some short-term SPS easements

/4
Pre-notifications (safety & security declarations) not initially required on the UK side, needed for imports into the EU.

So what's in the deal?

/5
Anti-smuggling and safety&security checks according to each side’s criteria but signs of cooperation and data exchange.

Not much of that going on on the UK's side anyway in the first 6 months.

/6
Customs cooperation
The text is actually very good. Covers standard provisions plus elements from the WTO Trade Facilitation Agreement. It’s comprehensive and encouraging.

Plus we have a Protocol on Mutual Administrative Assistance in Customs Matters

/7
(Side note - further case in point that a Mutual Administrative Assistance agreement is not the same as a trade deal and can be signed with or without one)

/8

https://t.co/QRsegE8Zm9
Non-committal language of the chapter in practice means that there is potential for deeper cooperation e.g. “consider developing joint initiatives” but no obligation.

This is in line with what we normally see in such chapters.

/9
For example 👇 from the UK’s initial proposal - a pilot for joint customs offices.

Again, plenty of scope for deeper cooperation but not initially.

/10
Ro-ro ports

Helpful language but less than in the UK's initial proposal. The EU did not commit to the proposed 2h time-limit for clearance.

/11
Pre-lodgement, advanced processing and exchange of information.

/12
Customs procedures
Full or simplified (deferred - UK). The key difference here vs no deal - no tariffs, provided that rules of origin are met. A quick explainer on how this will work below.

/13

https://t.co/Z4FJHbIebO
Simplified procedures
Interesting provision. Both parties already have simplified procedures and have previously committed to introducing the ones they don't currently have. So this is not technically new. But perhaps there is scope here for something more. Eventually.

/14
AEO and mutual recognition.
This is good. Still not that many benefits of having AEO but mutual recognition is helpful.
Commitment to allow SMEs to qualify but not many SMEs are able to given the current criteria.

/15
The only thing is, as I have often pointed out - to get mutual recognition our AEO programme needs to be compatible with EU's AEO.

Meaning total revamping of UK's AEO programme isn't happening. We can't diverge that much

/16
SPS
Little if any changes vs no deal in terms of what needs to happen at the border.
Not much on SPS in general. Read more 👇 from SPS expert.

/17

https://t.co/tWsjD2gHeF
Northern Ireland
Nothing in the deal but having a deal, in theory, means managing of the Irish Sea Border will be easier. With the new trusted trader programme and more than a light-touch approach to RoOs it should be easier.

/18
To sum it all up – in 3 days border procedures will look pretty much the same as they would under no deal. In terms of customs – obviously no tariffs (hello origin).

In the future, who knows, plenty of scope for deepening customs cooperation.

/19

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https://t.co/adPk9PsE0j

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