So on origin, it’s getting a bit hard to keep up with all the rumours so here is where I think we are with this (correct me if I missed something)

/1 https://twitter.com/AnnaJerzewska/status/1343606240107233283
Claiming origin.
Two ways for traders to claim origin under the EU-UK deal:

1⃣ Self-certification by the exporter (standard) – normally requires an authorisation, I’m hearing that might not be needed for UK-EU trade – waiting for guidance or more info

/2
2⃣ Self-certification by the importer (new(ish), in the EU-Japan deal and some continuity deals). UK importers have little experience with this one, but helpful guidance available given initial uncertainty around using this form of certification

/3
Retrospective claims.
For up to 3 years under each side’s domestic regulation – conditions, circumstances to be determined by both sides.

Careful here cause you might be required to have a good justification for why it wasn’t submitted at the time of import. Guidance needed
/4
Additional easements
On the UK side, this is part of the 6 months phase-in period– if you’re deferring a customs declaration you’re also deferring submitting an origin claim. If you're not deferring than origin documentation required at the time of import.

/5
Let’s be clear, this will be an area of risk for many companies ‼️

Advisors and customs practitioners will spend the next 6 months talking to companies about the need to meet rules of origin. Commercial risks here too.

/6
There is a question around the supplier's declaration.

Normally this is a document that you use if you're not the manufacturer of the product or if you rely on the origin of the parts and components you're using.

It's a way to track origin throughout the supply chain

/7
You normally need them before claiming originating status. Now we have a derogation, a simplification. And while that means more time for businesses and suppliers to understand what is needed - it's a massive area of risk.

/8
And I do not want to sound ungrateful - I'll take all the simplifications I can get but just not sure how this is going to play out in terms of compliance... It's hard enough to get these on time as it is...

/9
Interestingly the UK guidance covers EU side too. Which brings me to my last point - further simplifications on the EU side...? 🤷‍♀️

As far as I can see this is where we are for now.

/10
I keep hearing things... so this might not be over.

We still have 3.5 days left so plenty of time before all this is implemented.

/end
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