The government released the second tranche of technical notes last week about how we should mitigate the impact of leaving the EU without a deal (HERE). I am not convinced this is serious work. It has the appearance of an attempt to make it look as if preparations are being made when they're not. The notes are the equivalent of the inflatable tanks used by the Allies in 1944 to fool the Germans into thinking we had a lot more kit that we actually had. It worked then but won't work now.
One of the notes (HERE) is about trading with the EU after March 29th next year and with no transition period in place. It is not reassuring. In fact the advice on how to prepare looks like simply telling businesses they should start to prepare. There is little or no specific advice and nothing more than any business could have figured out for themselves in five minutes. The note says:
Trading with the EU if there's no deal.
In summary, actions businesses can take now to prepare include the following:
- Understand what the likely changes to customs and excise procedures will be to their businesses in light of this technical notice
- Take account of the volume of their trade with the EU and any potential supply chain impacts such as engaging with the other businesses in the supply chain to ensure that the necessary planning is taking place at all levels
- Businesses should consider the impact on their role in supply chains with EU partners. In the event that the UK and the EU does not have a Free Trade Agreement (FTA) in place in a ‘no deal’ scenario, trade with the EU will be on non-preferential, World Trade Organisation terms.
- This means that Most Favoured Nation (MFN) tariffs and non-preferential rules of origin would apply to consignments between the UK and EU. Further information on preferential trade under the UK’s existing trade agreements will be captured in the ‘Trade Agreement Continuity’ technical notice
- If necessary, put steps in place to renegotiate commercial terms to reflect any changes in customs and excise procedures, and any new tariffs that may apply to UK-EU trade, and familiarise themselves with the key processes of importing and exporting outside of the EU
- Consider how they will submit customs declarations for EU trade in a ‘no deal’ scenario, including whether they should engage the services of a customs broker, freight forwarder or logistics provider to help, or alternatively secure the appropriate software and authorisations
- Register to get EU Exit updates from HMRC
In other words the advice is to go and find out what you need to do, take account and consider and if necessary do something!
If I was a businessman I would be asking what is necessary? Businesses are not like governments. They don't spend money on hypotheticals or planning for things that might never happen unless they're forced to do it.
The last tranche was published yesterday including transport and aviation. Standby by for panic. I'll post something when I've had the chance to look through them.
