Continuation Brexit: Now What? 9 Below Zero

[Darat]

Originally Posted by ceptimus

What reasons, other than 'because we say so', does the EU give for wanting an alignment treaty for the UK to have a Canada-style deal, when the actual deal with Canada is subject to no such treaty?

Links to the information please.

[ceptimus]

Originally Posted by Darat

Links to the information please.

Yes.

[Lothian]

Originally Posted by ceptimus

What reasons, other than 'because we say so', does the EU give for wanting an alignment treaty for the UK to have a Canada-style deal, when the actual deal with Canada is subject to no such treaty?

Because the EU wants a deal with the UK that minimises disruption. Currently we have hassle free trade with the EU. Canada EU trade is subject to lots of checks and paperwork.

The EU would prefer to have easier trade with the UK than they do with Canada. If the UK decides that it doesn't want alignment, fine the EU will just treat UK imports like they do Canadian ones. Not great for UK exporters but cutting your nose off to spite your face runs through our brexit strategy.

[jimbob]

Originally Posted by Lothian

Because the EU wants a deal with the UK that minimises disruption. Currently we have hassle free trade with the EU. Canada EU trade is subject to lots of checks and paperwork.

The EU would prefer to have easier trade with the UK than they do with Canada. If the UK decides that it doesn't want alignment, fine the EU will just treat UK imports like they do Canadian ones. Not great for UK exporters but cutting your nose off to spite your face runs through our brexit strategy.

There is also the fact that the UK is a signatory to the Good Friday Agreement.

[Darat]

Originally Posted by jimbob

There is also the fact that the UK is a signatory to the Good Friday Agreement.

That was only important when the DUP votes were needed.

[Darat]

Originally Posted by ceptimus

Yes.

??

[ceptimus]

Originally Posted by Darat

??

Yes please, I want links to information why the EU thinks it needs to impose more rules for a Canada-style deal with the UK than it does for its Canada-style deal with Canada.

[Ziggurat]

Originally Posted by Mojo

How will they know whether or not the products have changed?

How do they know whether or not a product produced inside the EU has changed? How do they know whether or not a product produced in the US or China has changed? There is nothing different about the UK exit which changes that question.

[Ziggurat]

Originally Posted by Captain_Swoop

If the UK say's they aren't going to follow the rules why wouldn't you want to make sure they haven't changed anything?

That’s not how any of this works. For example, you can make products in the EU that don’t conform to the CE standards. You can’t generally sell them within the EU, but you can sell them in other markets. The UK is simply saying that for products sold in their market, future standards may diverge. But products destined for the EU market will still have to pass EU standards. The UK isn’t somehow giving them a pass to follow different standards. Products made outside the EU for sale within the EU don’t have to go through any different process than products made inside the EU for sale in the EU.

[Darat]

Originally Posted by ceptimus

Yes please, I want links to information why the EU thinks it needs to impose more rules for a Canada-style deal with the UK than it does for its Canada-style deal with Canada.

Right. I was asking for links that you used to understand the EU's position.

[abaddon]

Originally Posted by ceptimus

Originally Posted by Darat

Links to the information please.

Yes.

WT actual F?

[GlennB]

Silencing (elements of) the press? Seems to be right out of the Trump playbook:

"Political journalists walked out of No 10 Downing Street this afternoon in protest at the government planning to give a briefing on the EU only to selected reporters – banning The Mirror, i, Huffington Post, PoliticsHome, Independent and others from attending.

Reporters on the invited list were asked to stand on one side of a rug in the foyer of No 10, while those not allowed in were asked by security to stand on the other side.

After one of Boris Johnson’s most senior advisers, Lee Cain, told the banned reporters they must leave the building, the rest of the journalists decided to walk out rather than allow Downing Street to choose who scrutinises and reports on the government." link

Good for the rest of the journalists though.

[lomiller]

Originally Posted by Captain_Swoop

What's the surprise?

The surprise is that they actually realized it was impossible for them to not perform customs checks if Brexit progressed under current terms. They seem to be trying to claim it’s a negotiating tactic, even though the EU clearly understood from the start that the UK must perform customs checks if it wasn’t part of the common customs area.

[lomiller]

Originally Posted by ceptimus

Talking tough to try to secure a good deal. Negotiation 101. Something Theresa May was never prepared to do, but something the EU has done throughout, and will continue to do.

EU: “If you are not part of the common customs area, customs checks at the border are inevitable“
UK: “But we don’t want customs checks at the border! That will hurt our manufacturing sector”
EU: “the stay in the CCA”
UK: “But we don’t want to stay in the CCA! ”
EU: “Then implement customs checks”
UK: “don’t wanna”
EU: “You do whatever you want, but if you are not part of the CCA we have no choice but to implement customs checks at ports and borders”
UK: “Ha! We’ll show you! If you don’t give us what we want we’ll start doing customs checks on products centering the UK!!”
EU: “ummmm, ok”
Brexit voters: “Yeah! Get tough! This will show them!”

[Nessie]

https://www.bbc.co.uk/news/uk-51351914

"In his speech in Greenwich, London, the PM said: "We have often been told that we must choose between full access to the EU market, along with accepting its rules and courts on the Norway model, or an ambitious free trade agreement, which opens up markets and avoids the full panoply of EU regulation, on the example of Canada."

It would be handy to have an example of how the UK can sell a product or service in the EU, without following EU rules and regulations on that product or service.

What does Canada sell to the EU that does not follow EU rules and regulations?

[lomiller]

Originally Posted by Garrison

Yes, which is pretty much what the UK is going to have to do in all its trade negotiations however much Little Englanders stamp their feet and demand special treatment. If the EU, which actually wants a reasonable deal, is playing hardball what do you think the USA and China are going to do?

There are lots of things the EU would negotiate on, but this was never one of them. Without customs checks you can’t have Country of Origin rules. Without CoO rules it becomes almost impossible to negotiate trade deals.

What probabaly happened here is that the very first item that came up in their attempts to negotiate a trade agreement with the US was how to deal with country of origin, and the US said there was no possible deal unless the UK had customs checks that could document country of origin for items and subcomponents of items shipped to the US.

[Vixen]

Originally Posted by ceptimus

No. Exactly the opposite. I'm suggesting that we trade on the best possible terms on offer. If the offered terms are worse than WTO then we stick with WTO.
Remainers are now adopting a masochist stance where they want us to accept terms that will make things as bad as possible: they want the country Brexiteers to suffer just to prove that the remainers were right.

FIFY

[Vixen]

Originally Posted by abaddon

Amusing.

USA - Negotiations commenced April 2019.
Canada - Agreement reached after 10 years of negotiations.
India - Negotiations ongoing since 2007.
China - Negotiations ongoing since 2013.
Australia/New Zealand - Negotiations ongoing since 2018.
Mexico - Negotiations ongoing since 2016.
Japan - EPA in force since Feb, 2019.

But somehow, you think the UK will get it all done in under 11 months despite having no negotiators nor anything to negotiate with.

You're wrong. The UK has Dominic Raab...

I'll get my coat.

[Nessie]

According to this summary of the Canada deal, Canada does have to comply with EU rules and regulations when trading;

https://www.bbc.co.uk/news/business-45633592

"There is also co-operation between the two countries on standards, so a piece of equipment made in an EU country can go through all its safety and quality checks there, without needing to have them repeated in Canada - and vice versa."

"And it aligns Canadian rules in some areas of copyright and patents with those of the EU."

"Ceta protects EU "geographical indications", meaning for example that you can only make Parma ham in Italy and camembert cheese in France, and Canada can't import something that calls itself camembert from any other country."

I am quite sure that Canada did far more adjustments than the EU did, since the EU is far larger and able to dictate terms. So Canadian products will have adjusted to follow EU safety rules far more than vice versa and I would think Canada adjusted its copyright laws more than the EU did to get alignment.

That should not really be an issue in the UK, since we start at a fully aligned position, where UK safety and copyright is the same as EU, or at least acceptable for trading.

What gets to be called Canadian maple syrup, Danish bacon and Stilton cheese should not really be affected.

So, unless Jonson is planning on deliberately moving the UK out of product alignment with the EU, then I do not see what the problem is.

[abaddon]

Originally Posted by Vixen

You're wrong. The UK has Dominic Raab...

I'll get my coat.

You should. Somehow you have to transfer from being a Brit to being a Finn. Or vice versa as suits your various posts.

Perhaps a cloak might work better. I have a +6 Cloak of concealment for sale if you play RPG's.

[Vixen]

Originally Posted by Ziggurat

That makes no sense. If the product hasn’t changed, why recertify? CE products from non EU states only have to certify once, why would the UK be different? And new or altered products need to be certified regardless as well. All that the non-alignment means is that NEW products for the UK market would be able to use different standards, that makes no difference to existing products.

Since you said this will be really simple, I went to GOV.uk to see how this would work. Despite glib reassurances by HM Government, it looks like it will be a headache for businesses importing EAA/EU goods into the UK after December as they will have to remove all CE labels and replace with the new UK bodies conformance stickers.

Thinking of Honda and their 350 trucks coming in every day from La Continong with car parts for its 14K strong workforce at the UK production line in Swindon, this will be a real laugh. I am sure.

[lomiller]

Originally Posted by Ziggurat

Why would they

The EU no longer has assurance that their important standards are being met. This is pretty much standard in all international trade. Everyone has this requirement and everyone enforces it, so the real question why you think the EU would make an exception in this case.

Originally Posted by Ziggurat

That burden applies to EU producers too

How so? The additional burden comes from maintaining duplicate standards and from import checks that products from the UK do not currently face. These are certainly not burdens that apply to products made and sold in the EU.

Originally Posted by Ziggurat

But now producers have a choice they didn’t have before.

UK producers get to choose whether they keep their customers or not. This is not the type of choice business want to make.

[Vixen]

Originally Posted by Ziggurat

That’s not how any of this works. For example, you can make products in the EU that don’t conform to the CE standards. You can’t generally sell them within the EU, but you can sell them in other markets. The UK is simply saying that for products sold in their market, future standards may diverge. But products destined for the EU market will still have to pass EU standards. The UK isn’t somehow giving them a pass to follow different standards. Products made outside the EU for sale within the EU don’t have to go through any different process than products made inside the EU for sale in the EU.

Well, they do, because cars (one of UK's biggest exports) for the EU market are constructed to different standards from the US market. Can't just make the product any old how: you have to agree standards in any trade deal. Implementing standards for a specific market costs and thus makes your product uncompetitive compared to others - who have been around longer - and in an elastic market where profit margins drive price, you could see your sales stagnate.

In any case, the UK is no longer a big manufacturing country as it once was in the golden industrial age of the late-nineteenth century. These days it is services that run the economy.

Now, to sell cars as a dealer, you need to offer attractive 'finance deals'. Hah! To offer banking or finance you have to obtain a licence from each of the countries you want to offer banking/loan facilities in.

This is just the start.

[Ziggurat]

Originally Posted by Vixen

Since you said this will be really simple, I went to GOV.uk to see how this would work. Despite glib reassurances by HM Government, it looks like it will be a headache for businesses importing EAA/EU goods into the UK after December as they will have to remove all CE labels and replace with the new UK bodies conformance stickers.

First, that guidance is outdated, since it was about a no-deal exit.

Second, they're describing the problems facing producers from outside the UK trying to import into the UK. But the problems previously described were of UK producers trying to export back into the EU.

Third, you've mischaracterized what would have to be done. Your own link says that CE labels will NOT have to be replaced with UK body conformance stickers for some period of time. Whether they ever do will depend upon any future UK legislation, but certainly the change will not happen immediately.

And lastly, of course, CE labels would never have to be removed, even if additional UK-specific labels had to be added.

[Ziggurat]

Originally Posted by lomiller

The EU no longer has assurance that their important standards are being met.

Again, that's not how standards work. The country of origin isn't what assures or doesn't assure compliance with any set of standards.

Quote:

Everyone has this requirement and everyone enforces it, so the real question why you think the EU would make an exception in this case.

That's precisely my point, it's NOT an exception. What you're proposing IS an exception.

[Vixen]

Originally Posted by GlennB

Silencing (elements of) the press? Seems to be right out of the Trump playbook:

"Political journalists walked out of No 10 Downing Street this afternoon in protest at the government planning to give a briefing on the EU only to selected reporters – banning The Mirror, i, Huffington Post, PoliticsHome, Independent and others from attending.

Reporters on the invited list were asked to stand on one side of a rug in the foyer of No 10, while those not allowed in were asked by security to stand on the other side.

After one of Boris Johnson’s most senior advisers, Lee Cain, told the banned reporters they must leave the building, the rest of the journalists decided to walk out rather than allow Downing Street to choose who scrutinises and reports on the government." link

Good for the rest of the journalists though.

Not being funny but I always suspected a covert Trump-Bannon-Johnson plan to move the country further away from democracy and - ironically -UK sovereignty.

No longer is the UK run by the people, it is a claque (to use the words of Dave Spart) of the far right Zionists whose aim is to lead it into a fascist dictatorship.

[Vixen]

Originally Posted by Nessie

https://www.bbc.co.uk/news/uk-51351914

"In his speech in Greenwich, London, the PM said: "We have often been told that we must choose between full access to the EU market, along with accepting its rules and courts on the Norway model, or an ambitious free trade agreement, which opens up markets and avoids the full panoply of EU regulation, on the example of Canada."

It would be handy to have an example of how the UK can sell a product or service in the EU, without following EU rules and regulations on that product or service.

What does Canada sell to the EU that does not follow EU rules and regulations?

Er, Canada Goose brand coats, fur-lined with real coyote fur...?

[Ziggurat]

Originally Posted by Vixen

Well, they do, because cars (one of UK's biggest exports) for the EU market are constructed to different standards from the US market. Can't just make the product any old how: you have to agree standards in any trade deal.

You're talking about what standards apply. But that's a different question then how you comply with whatever standards you've chosen. And a producer within the EU making a product for the EU has to go through the same compliance steps that a producer outside the EU making a product for the EU has to go through.

Quote:

Implementing standards for a specific market costs

Yes. And all products made in the UK for the EU have already paid those costs. They won't have to pay them again for existing products. And new products made in the UK for the EU will have to go through those same compliance costs just like they would have to if the UK stayed in the EU.

[Ziggurat]

Originally Posted by Vixen

No longer is the UK run by the people, it is a claque (to use the words of Dave Spart) of the far right Zionists whose aim is to lead it into a fascist dictatorship.

Next you're going to be telling me they've got protocols for this.

[Vixen]

Originally Posted by Ziggurat

First, that guidance is outdated, since it was about a no-deal exit.

Second, they're describing the problems facing producers from outside the UK trying to import into the UK. But the problems previously described were of UK producers trying to export back into the EU.

Third, you've mischaracterized what would have to be done. Your own link says that CE labels will NOT have to be replaced with UK body conformance stickers for some period of time. Whether they ever do will depend upon any future UK legislation, but certainly the change will not happen immediately.

And lastly, of course, CE labels would never have to be removed, even if additional UK-specific labels had to be added.

The document is not 'out of date'. It is dated Sept 2019. CE labels WILL have to be replaced by UK conformance standards (which hasn't even been set up yet!).

Quote:

Check whether you need to amend the label on your products. The UKCA
(UK Conformity Assessed) marking is the new UK conformity marking, indicating
compliance with the UK requirements, including (where applicable) assessment
by a UK approved body. The UK conformity marking for products placed on the
UK market replaces the CE marking for products being placed on the UK market,
but the choice will remain initially for compliance to be with EU law and products
to be CE marked accordingly. In addition to the CE marking, the UK will
temporarily recognise other conformity marks such as the reversed epsilon ‘Э’ for
aerosols and for measuring containers (for a time limited period to be
determined). The UK will continue to recognise the voluntary use of the e-mark to
denote compliance with the average system of quantity control for packaged
goods. From Exit Day, products exported to the EU will need to have the relevant
contact details of the relevant EU importer on product, where contact details of an
EU based importer are required.

This is just one paragraph in a 48-page document in so-called 'plain English'.

[Dave Rogers]

Originally Posted by Vixen

The document is not 'out of date'. It is dated Sept 2019.

And, of course, no significant events related to Brexit have occurred since then.

Dave

[The Don]

Originally Posted by Nessie

What does Canada sell to the EU that does not follow EU rules and regulations?

Part of the problem is that there have been comparatively few examples given of EU regulations as they apply to product specifications. The major issues, as they seem to have been described relate to things like

Government

• subsidy
• Preferential selection of local suppliers
• Employment rights in general and the working time directive in particular
• "unnecessary" EU environmental protections
• Corporate governance
• Financial regulation

The view is that a Canada-style deal would allow the UK to set up shop as a "Singapore of the North" but would still allow tariff and quota-free access to the EU. This would give the UK a considerable competitive advantage and allow UK businesses to increase trade with both the EU and worldwide.

The trouble is that in order to get tariff and quota-free access, the UK would have to operate on a level playing field as regards points like those above - which is where ceptimus' claim about the EU insisting on tighter regulation for the UK than Canada.

Of course where Canada does not have a level playing field with the EU - the dairy industry for instance - Canada does have tariffs and/or quotas.

IMO it's another example of the UK wanting the benefits of membership (tariff and quota-free trade) with none of the responsibilities (following the rules). The government likely expect that those in favour of Brexit won't understand the key differences between the Canada deal and what the UK wants and will continue to think that the EU are just a bunch of rotten rotters who are jealous of our new freedoms and want to spoil our fun.

Of course the Canada deal largely ignores 80% of the economy, the service sector, which generates a healthy trade surplus. Instead one of the five red lines is going to be allocated to the fishing industry 1/1000 of the economy

[Ziggurat]

Originally Posted by Vixen

The document is not 'out of date'. It is dated Sept 2019.

And it addresses a no-deal brexit. Which isn't what happened.

Quote:

CE labels WILL have to be replaced by UK conformance standards (which hasn't even been set up yet!).

First, once again, CE labels never have to be replaced. I can find CE labels on a bunch of stuff here in the US, even though it's meaningless here. The CE label can stay. An additional UK-specific label may eventually have to be put on, but that's only pending future legislation. Your link's use of the word "replace" refers to which standards will be required. The requirement for a CE mark may in the future be replaced by a requirement for a UKCA mark, but only pending future legislation. But you can have as many marks to indicate as many requirements you comply with as you want, if you've satisfied all of them. No country ever prohibits products from carrying marks like CE, even if they don't matter.

[Vixen]

Originally Posted by Ziggurat

You're talking about what standards apply. But that's a different question then how you comply with whatever standards you've chosen. And a producer within the EU making a product for the EU has to go through the same compliance steps that a producer outside the EU making a product for the EU has to go through.



Yes. And all products made in the UK for the EU have already paid those costs. They won't have to pay them again for existing products. And new products made in the UK for the EU will have to go through those same compliance costs just like they would have to if the UK stayed in the EU.

But don't you see, if cars exported to EU countries is no longer profitable, with the added 10% tariff driving up the price for the consumer, you'd have to sell those cars to a different market. Problem is, you still need to conform to the standards of that market.

There is talk in the papers today of (UK) Nissan ceasing export to the EU (NB the best-selling Micra is made in France) and just concentrating on the domestic UK market. It has a 4.5K strong workforce in Sunderland (note the irony here!). Nissan say this is just one of their economic models but it sounds like business suicide to me.

[GlennB]

Originally Posted by Ziggurat

First, that guidance is outdated, since it was about a no-deal exit.

The Withdrawal Agreement is not a 'deal'. Perhaps this is at the root of your misunderstanding?

Recent spoutings by Johnson strongly suggest he's hell-bent on 'no deal' in Dec this year.

[ponderingturtle]

Originally Posted by Dave Rogers

And, of course, no significant events related to Brexit have occurred since then.

Dave

Has the UK decided to allow the EU to dictate its product standards now by having them control the CE marking and accepting it? Or does it still think it will have its own regulation like the document said?

This issue seems no more resolved than it was when that was written. And unless they are part of the regulatory framework of europe they need to have their own markings and standards.

[Vixen]

Originally Posted by Ziggurat

Next you're going to be telling me they've got protocols for this.

Sorry, I should have put the phrase in quotation marks to signify common vernacular.

[lomiller]

Originally Posted by ceptimus

USA, Canada, India, China, Australia, Mexico, Japan, New Zealand, and many other countries all choose not to be members of customs unions. Now the UK is doing the same.

It will also it will take just as long to negotiate trade agreements, require the same customs checks, require the same types of import rules/restrictions and same type of product standards validation, etc.

[Mojo]

Originally Posted by Ziggurat

How do they know whether or not a product produced inside the EU has changed?

Because there are unified standards that are supposed to be enforced across the EU. If those standards are no longer being enforced by the UK, the. They will need to be enforced by the EU at point of entry.

[Ziggurat]

Originally Posted by Vixen

But don't you see, if cars exported to EU countries is no longer profitable, with the added 10% tariff driving up the price for the consumer, you'd have to sell those cars to a different market. Problem is, you still need to conform to the standards of that market.

No. The problem is the 10% tariff, not the standards.

And for something like cars, the important cost of conformance isn't the administrative overhead of certification, it's the actual manufacturing requirements to meet that standards.