Brexit discussion thread XIII (Please read OP before posting)

Capt'n Midnight

peter kern wrote: »

but in this case high road mentions it seems an eu product goes to uk and then tariffs applies when it goes back to eu. so there is no tariff country involved.

Under the agreement, if more than 40% of the pre-finished value of a UK firm’s product was not British, it would attract tariffs.

this makes total sense for products from outside the eu as you mentioned, but to me it makes little sense with a product made in the eu, especially if the export land is NI or Ireland it only seems to increase cost for this island or will result in less choice .

Did the UK not read the EU documents they signed or did they put fishing* front and centre ?

With all the trade deals they are doing with the rest of the world the rules of origin might just have popped up.


"The VAT hits when the product reaches the port,"

If a UK firm buys a consignment of Irish mushrooms and turns them into a vegetarian lasagne, that product can still be sold back into Ireland tariff free.

That is because the TCA accepts "cumulation", ie, the ability for a company to count as British components that are sourced in the EU (and vice versa), so long as there is an acceptable level of processing involved.

The problem with the chocolate product coming from the Netherlands to a distribution hub is that there is no processing involved. The products are simply re-packaged and spun off again into the EU (Ireland).

No doubt there a lot of UK civil servants are muttering to themselves "I did warn them".

GazzaL

There seems to be huge issues for British exporters. Who would've thought that leaving the customs union and introducing reams of bureacracy and paperwork would cause such a problem? Despite the fact that it was the British who voted for this, and they knew what they were voting for, they seem to be blaming the EU for this :pac:

I'd say quite a few British products will no longer be available in Ireland. You'd wonder how many British SMEs will be able to exploit the sunny uplands when they can't or won't even fill out the paperwork to send goods over the Irish Sea.

Capt'n Midnight

The UK spent a lot of political capital to take back control of fishing. But it's getting hammered by red tape.

"These businesses are not transporting toilet rolls or widgets. They are exporting the highest quality, perishable seafood which has a finite window to get to markets in peak condition," said Donna Fordyce, chief executive of Seafood Scotland.

"If the window closes, these consignments go to landfill."

sondagefaux

View wrote: »

In fairness, the trade agreement was only published after most people had “left the office” in order to enjoy Christmas. They weren’t going to ruin their holidays just because Johnson et al insisted on delaying everything to the last minute.

In fairness, every trade agreement in the world that doesn't create a customs union includes Rules of Origin.

In fairness, you'd need your head examined if you didn't realise that a trade agreement between the UK and EU was never going to allow tariffs to be abolished on goods produced in China.

GazzaL

Capt'n Midnight wrote: »

The UK spent a lot of political capital to take back control of fishing. But it's getting hammered by red tape.

So Kent is full of piss and ****, and Scotland is full of rotting fish?

sondagefaux

GazzaL wrote: »

There seems to be huge issues for British exporters. Who would've thought that leaving the customs union and introducing reams of bureacracy and paperwork would cause such a problem? Despite the fact that it was the British who voted for this, and they knew what they were voting for, they seem to be blaming the EU for this :pac:

I'd say quite a few British products will no longer be available in Ireland. You'd wonder how many British SMEs will be able to exploit the sunny uplands when they can't or won't even fill out the paperwork to send goods over the Irish Sea.

There are barriers to trade on the import side too.

A UK company that exports to the UK might be ready and willing to deal with export procedures.

That's no good to them if their EU customers can't be bothered to deal with import procedures.

Akrasia

Sam Russell wrote: »

I think it is more likely that we import 'Scotch' whisky from India or some such place and sell it on. [Actually, it is a bad example as we make plenty of Irish Whiskey so why sell a lesser product!]

We sell Cheddar cheese that has no relationship to the Cheddar Gorge, so that might be an area where we could sell Irish Stilton, or Irish Red Leicester.

I'm not saying we should drink that muck ourselves, we use some spare capacity in a our distilliaries, get some malted barley and make some 'Loch Guinness Scotch Whisky' and sell it off to the french or yanks in bulk. The Scotch market is 10 times bigger than the Irish Whiskey market. We can stick our toes in the Scotch market and it would be worthwhile, but the scottish couldn't really reciprocate because they'd be trying to muscle in a much smaller market

France is the worlds biggest export market for Scotch Whisky, Now, Irish whiskey producers could sell a brand of scotch into France, but a scottish whisky producer could not legally sell a brand of Irish Whiskey into France.

sondagefaux

Sam Russell wrote: »

I think it is more likely that we import 'Scotch' whisky from India or some such place and sell it on. [Actually, it is a bad example as we make plenty of Irish Whiskey so why sell a lesser product!]

We sell Cheddar cheese that has no relationship to the Cheddar Gorge, so that might be an area where we could sell Irish Stilton, or Irish Red Leicester.

Nope.

Protected geographical indication (PGI)
PGI emphasises the relationship between the specific geographic region and the name of the product, where a particular quality, reputation or other characteristic is essentially attributable to its geographical origin.

https://ec.europa.eu/info/food-farming-fisheries/food-safety-and-quality/certification/quality-labels/quality-schemes-explained_en#:~:text=Protected%20geographical%20indication%20(PGI),attributable%20to%20its%20geographical%20origin.

The EU has a list of such products (eg. Parma Ham, Clonakilty Black Pudding); the UK also has its own list of such products.

The trade agreement includes recognition of each others' lists, so Scotch whisky etc are protected in the EU.

Cheddar cheese had been made outside the Cheddar Gorge area for decades before this system was adopted.

The EU does this in all its trade agreements. It also recognises products from countries that reciprocate for EU products, even without a trade agreement.

For example, Chinese products are listed in the EU, and EU products are listed in China.

sondagefaux

schmoo2k wrote: »

Small electrics come to mind, swap out power supply to UK compatible one and then sold onto UK / Ireland

Most electrical goods are zero tariff anyway under the WTO's International Technology Agreement.

https://www.wto.org/english/tratop_e/inftec_e/itaintro_e.htm

sondagefaux

Sam Russell wrote: »

My understanding (which might be wrong) is that sweets made in the EU are sent in bulk to the UK to be packaged for sale in UK and Ireland. The process of packaging means they are no longer the same product and now attract tariffs.

I am surprised that a 'zero tariff, zero quota' deal ends up like this, but there you go.

It is wrong. Goods produced in the EU and further processed in the UK, even if just repackaged, are exempt from tariffs, and vice versa.

Gerry T

sondagefaux wrote: »

Nope.



https://ec.europa.eu/info/food-farming-fisheries/food-safety-and-quality/certification/quality-labels/quality-schemes-explained_en#:~:text=Protected%20geographical%20indication%20(PGI),attributable%20to%20its%20geographical%20origin.

The EU has a list of such products (eg. Parma Ham, Clonakilty Black Pudding); the UK also has its own list of such products.

The trade agreement includes recognition of each others' lists, so Scotch whisky etc are protected in the EU.

Cheddar cheese had been made outside the Cheddar Gorge area for decades before this system was adopted.

The EU does this in all its trade agreements. It also recognises products from countries that reciprocate for EU products, even without a trade agreement.

For example, Chinese products are listed in the EU, and EU products are listed in China.

Something in the back of my head is saying that the EU did protect it's GI's but the UK didn't in the talks, I might be complete wrong on that so someone might correct me.

breezy1985

Akrasia wrote: »

I'm not saying we should drink that muck ourselves, we use some spare capacity in a our distilliaries, get some malted barley and make some 'Loch Guinness Scotch Whisky' and sell it off to the french or yanks in bulk. The Scotch market is 10 times bigger than the Irish Whiskey market. We can stick our toes in the Scotch market and it would be worthwhile, but the scottish couldn't really reciprocate because they'd be trying to muscle in a much smaller market

France is the worlds biggest export market for Scotch Whisky, Now, Irish whiskey producers could sell a brand of scotch into France, but a scottish whisky producer could not legally sell a brand of Irish Whiskey into France.

What put Scotch to the top of the pile in the first place was Irish independence and our loss of access to the empire which decimated the Irish industry and led to the few remaining major distillers coalescing in middletown. So for the EU market at least Brexit could have the reverse effect

Capt'n Midnight

sondagefaux wrote: »

It is wrong. Goods produced in the EU and further processed in the UK, even if just repackaged, are exempt from tariffs, and vice versa.

No. There has to be significant processing.
https://www.rte.ie/news/2021/0108/1188595-tony-connelly-brexit/

If a UK firm buys a consignment of Irish mushrooms and turns them into a vegetarian lasagne, that product can still be sold back into Ireland tariff free.

That is because the TCA accepts "cumulation", ie, the ability for a company to count as British components that are sourced in the EU (and vice versa), so long as there is an acceptable level of processing involved.

The problem with the chocolate product coming from the Netherlands to a distribution hub is that there is no processing involved. The products are simply re-packaged and spun off again into the EU (Ireland).

schmoo2k

sondagefaux wrote: »

Most electrical goods are zero tariff anyway under the WTO's International Technology Agreement.

https://www.wto.org/english/tratop_e/inftec_e/itaintro_e.htm

I have loads of examples on Amazon.co.uk which are subject to the import tax?

Capt'n Midnight

breezy1985 wrote: »

What put Scotch to the top of the pile in the first place was Irish independence and our loss of access to the empire which decimated the Irish industry and led to the few remaining major distillers coalescing in middletown. So for the EU market at least Brexit could have the reverse effect

Actually the US market should be good while the US keeps tariffs on "Scotch" whisky. Good thing the UK has third country trade deals up the wazoo :rolleyes:

Like fishing, it's another fine mess the UK has gotten Scotland into.

https://www.forbes.com/sites/felipeschrieberg/2020/12/17/scotch-whisky-trump-tariffs-might-end-thanks-to-mini-uk-trade-deal/

The Scotch Whisky industry has been hit by a 25% tariff on Single Malt going into the US. The tariff has been in place since October 2019, and Scotch Whisky exports have fallen by 30% Likewise, American whiskey distillers have now had a 25% tariff in place on their exports into the EU for two years, which has meant that their exports have fallen by a third in that time.

https://www.drinksindustryireland.ie/irish-whiskey-in-new-us-trade-tariffs/

“Over 99% of Irish whiskey exports to the US are excluded from the current tariffs imposed by the US” stated Drinks Ireland|Irish Whiskey Association’s William Lavelle, “We are disappointed that a small number of Northern Irish single malts have been subjected to tariffs.

sondagefaux

Gerry T wrote: »

Something in the back of my head is saying that the EU did protect it's GI's but the UK didn't in the talks, I might be complete wrong on that so someone might correct me.

All GIs on the EU's list as of 31.12.2020 (including the UK ones) are protected.

https://www.gov.uk/guidance/protected-geographical-food-and-drink-names-uk-gi-schemes

sondagefaux

schmoo2k wrote: »

I have loads of examples on Amazon.co.uk which are subject to the import tax?

I don't know how Amazon.co.uk works these things out, but the WTO International Technology Agreement has legal force in the UK and EU.

If the goods are produced or dispatched from a country that's not party to that agreement, they may be subject to tariffs.

Some examples of items sold on Amazon UK but sold by Chinese sellers are shown in the €22 Amazon thread in Bargains.

You've got to triple check where goods are coming from and where they're produced when using Amazon.

Ebay is much clearer about where goods are sent from, although I've bought stuff from ebay.co.uk where the seller has lied about where the stock is held, i.e. it was sent from China even though the listing said UK stock.

sondagefaux

Capt'n Midnight wrote: »

No. There has to be significant processing.
https://www.rte.ie/news/2021/0108/1188595-tony-connelly-brexit/

Aha, I have read elsewhere that this rule only applied to non-UK and non-EU goods. I suspect this will be challenged as the trade agreement specifically permits bilateral cumulation for UK/EU-produced goods.

peter kern

Nody wrote: »

It makes total sense period; this is standard set up for any third party country for a FTA. That UK companies are to lazy to actually add 60% value to a product is not an EU's problem; that's UK's problem. If UK companies wishes to fix that they have two option; either add more value, or the more common approach, relocate the whole thing into an EU country instead. The second option is what many companies are now doing because while it was easy to do such trade chains while in EU it will no longer make sense and the low value (by definition) step in UK is then simply removed. Let me give you an example outside of EU on how this plays out.

We produced the raw product materials in Russia in one of our factories, exported it to Poland to be made into the final product. Tariffs paid for export from Russia to Poland. From Poland we shipped the final product to Switzerland because they owned the distribution channel it was suppose to go into and their warehouse was in Switzerland. Tariffs paid to export from Poland to Switzerland. Switzerland then send the product to Belgium to be packaged into a gift basket kind of deal with other products we sell. Tariffs paid to export Switzerland to Belgium. Gift basket sent back to Swiz warehouse. Tariffs paid to export Belgium to Switzerland. In the end the truck cost about 100k USD in tariffs making the whole supply chain impossible for obvious reasons but the procurement people who planned it and thought it would be a great idea did not know that when they sent the first truck (and we only found out about it when we got the invoices for the first truck and could ask Procurement where they wanted the cost charged to).

What UK is now experiencing is not something new; it's standard. The only time you get to export it back tariff free is if you ship the same goods type and can show your export volume vs. import volume from same destination basically. But why would you ship back exactly the same product in the first place? Often there's been some kind of work done to it and that will change it into a new product category and hello tariffs.

good detailed reply, thanks !
but does it answer my main question how this is going to be good for irish consumer?

sondagefaux

peter kern wrote: »

good detailed reply, thanks !
but does it answer my main question how this is going to be good for irish consumer?

Because Irish importers who have just relied on buying stuff from the UK because it was the closest and easiest rather than the cheapest or better quality will now be forced to buy from other EU countries if they want to remain competitive. And buying from 26 other EU countries means far better choice and range of prices than just buying from the UK, as individual Irish consumers are finding out.

EG: https://touch.boards.ie/thread/2058148203/1/#post115862410

schmoo2k

peter kern wrote: »

good detailed reply, thanks !
but does it answer my main question how this is going to be good for irish consumer?

Its not - while this thread is basking in the "they got what they deserved" mentality, the fact is that things are now worse for us and we have to get used to it.

Preemptive comment - If we left the EU things would be so so much worse.

In my home office I will be installing some European styled plugs so I don't have to deal with the hanging off the wall adapters...

Gerry T

sondagefaux wrote: »

All GIs on the EU's list as of 31.12.2020 (including the UK ones) are protected.

https://www.gov.uk/guidance/protected-geographical-food-and-drink-names-uk-gi-schemes

That link has the following

The UK GI schemes protect registered product names when they are sold in Great Britain (GB) (England, Scotland and Wales).

The EU GI schemes protect registered products names when they are sold in Northern Ireland (NI) and the EU.

All product names protected in the EU on 31 December 2020 following successful applications to the EU GI schemes are protected under the UK and EU GI schemes.


I've no expertise or knowledge in this area but the first two paragraphs suggest the UK protects it's GI's in the UK and the second paragraph suggests the EU does the same for EU GI's in the EU.
The third paragraph suggests that EU GI's will be protected in the UK but there isn't a paragraph doing the same for the UK, that is protection of UK GI's in the EU.

I might be taking that up wrong, but to me that suggests an Irish whiskey producer could start selling Scotch whiskey in the EU ?

yagan

schmoo2k wrote: »

In my home office I will be installing some European styled plugs so I don't have to deal with the hanging off the wall adapters...

I'd never really thought of that as I've usually just used an adapter, but having googled the options I can see wall sockets that take both UK and EU plugs becoming the norm in Ireland.

sondagefaux

The 'landbridge' across Britain is being abandoned.

Rosslare Harbour
@RosslareHbr
There have been 1,148 freight units carried on 18 direct sailings between #Rosslare & #Dunkirk & #Cherbourg in #France with DFDS and Stena & to Bilbao in #Spain on Brittany Ferries between January 2nd and 7th compared with 197 units on three services last year" #Wexford #Ireland

sondagefaux

Gerry T wrote: »

That link has the following

The UK GI schemes protect registered product names when they are sold in Great Britain (GB) (England, Scotland and Wales).

The EU GI schemes protect registered products names when they are sold in Northern Ireland (NI) and the EU.

All product names protected in the EU on 31 December 2020 following successful applications to the EU GI schemes are protected under the UK and EU GI schemes.


I've no expertise or knowledge in this area but the first two paragraphs suggest the UK protects it's GI's in the UK and the second paragraph suggests the EU does the same for EU GI's in the EU.
The third paragraph suggests that EU GI's will be protected in the UK but there isn't a paragraph doing the same for the UK, that is protection of UK GI's in the EU.

I might be taking that up wrong, but to me that suggests an Irish whiskey producer could start selling Scotch whiskey in the EU ?

UK GIs were EU GIs until 31.12.2020.

So any UK GIs on the EU's GI list as of 31.12.2020 are still protected under both GI systems.

sondagefaux

schmoo2k wrote: »

Its not - while this thread is basking in the "they got what they deserved" mentality, the fact is that things are now worse for us and we have to get used to it.

Preemptive comment - If we left the EU things would be so so much worse.

In my home office I will be installing some European styled plugs so I don't have to deal with the hanging off the wall adapters...

Not true at all. UK-based distributors have been ripping off Irish customers for years. Most Irish companies have been using these UK distributors until now because it was easier rather than necessarily cheaper or better quality.

That's no longer feasible in many cases and Irish consumers can easily buy online from the EU if Irish importers don't get their act together and turn away from UK distributors.

Check out threads in Bargains, Cycles etc for links to EU sites that are cheaper than UK sites.

There's an example in one of my previous posts.

sondagefaux

yagan wrote: »

I'd never really thought of that as I've usually just used an adapter, but having googled the options I can see wall sockets that take both UK and EU plugs becoming the norm in Ireland.

You can get USB ready wall sockets easily enough.

And Woodie's sell 'Uk Eur' adaptors with USBs.

https://www.woodies.ie/diy-building-materials/electrical/plugs-adaptors-timers

fash

Gerry T wrote: »

Something in the back of my head is saying that the EU did protect it's GI's but the UK didn't in the talks, I might be complete wrong on that so someone might correct me.

In the withdrawal agreement. Of note even then the EU was never going to "deregister" UK GIs - as the EU takes a philosophical position on this that GIs are good. So given that, why would they remove recognised GIs?

sondagefaux

This is the same Daniel Hannan who claimed that "absolutely nobody is talking about threatening our place in the Single Market" during the referendum campaign.

https://www.independent.co.uk/news/uk/politics/eu-consumer-worker-protections-brexit-b1783331.html

Sam Russell

schmoo2k wrote: »

Its not - while this thread is basking in the "they got what they deserved" mentality, the fact is that things are now worse for us and we have to get used to it.

Preemptive comment - If we left the EU things would be so so much worse.

In my home office I will be installing some European styled plugs so I don't have to deal with the hanging off the wall adapters...

There is a thread debating the various plug types.

This is a bit off topic, but the EU came up with a very good design for a universal power plug for use in the EU, which was rejected by every country - except Brazil.

I have approx. 50 double sockets in my house, and about 50 plugs on various appliance, some plugged in always, some sometimes and some never. It would cost a significant amount to change over to a new system of plugs and sockets, and that is before rewiring my house to use a different wiring system required by these new plugs.

You need to be careful in replacing plugs from one system with another as it can be dangerous. Wiring design and capacity, fusing, earth leakage breakers, design parameters - all of these are a total system, and should not be mixed.

You could fancy driving on the right hand side of the road just because most other countries do that, but I suggest you wait till everyone else in Ireland does the same - it could be quite dangerous.

Back on topic - I agree, leaving the EU would be a disaster for Ireland.