Just as a reminder - without a freeze/ implementation period or some sort of derogation - no business on either side will be able to use the UK-EU FTA to avoid paying tariffs on 1 Jan even if we get one tomorrow.

It's already too late.

/1
Businesses simply won't have enough time to familiarise themselves with rules of origin, figure out whether their products meet them (larger companies have hundreds of SKUs) and understand what the certification requirements are.

/2
It is expected that companies would be able to self-certify origin under the UK-EU FTA but that is not always that straight forward and sometimes requires prior steps.

/3
So for most businesses, Jan means tariffs if nothing else is agreed.

Both sides should consider introducing some easements or simplifications in the short term.

/4
Otherwise, companies would need to reclaim the tariffs they paid at a later stage. That is possible but requires additional forms and takes time.

/5
Imagine HMRC, on top of all the extra work they are already doing with various authorisations etc, receiving duty reclaim forms from every single business that had to pay tariffs for imports from the EU in January

/6
So simplifications needed otherwise we will make it very hard for both businesses and HMRC to cope.

/end
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