Brexit and the waning days of the United Kingdom

[Tamas]

The idea that the EU should let fine upstanding British firms get special treatment is weird and quaintly Imperial.

It is also behind  the Leave sentiment and what I consider to be a distorted picture in many heads here on just exactly how much of the way Brits are treated in the world is their birthright.

[The Brain]

Yeah, do the Brits realize how their enormous entitlement BS comes across outside of their own little echo chamber? They don't seem to live on the same planet as the rest of us.

[Sheilbh]

The UK has had literally years to prepare for this. And the whole point of Brexit is the EU NOT being responsible for the UK, or parts thereof. The "I didn't bother studying for the test, can you PLEEASE give me a passing grade anyway?" line of argument is unworthy of governments or other organizations.

Ireland will do fine, it's in the EU. NI isn't in the EU and therefore not the EU's concern.

But this just isn't true. Both sides have treated Northern Ireland as separate and different from the very start. It's the only bit of the UK that is conditional on consent, they have a right to leave the UK and join Ireland at any time, it is acknowledged by the EU that in the event that consent is withdrawn leading to a united Ireland then Northern Ireland would be treated like East Germany in joining the EU. Similarly it's the only bit of the UK where there is cherrypicking.

Northern Ireland is in the UK single market and the EU single market, because it's different and both sides have taken responsibility to treat it differently to acknowledge its unique position. And both sides are meant to use their best endeavours to protect the peace and prosperity of Northern Ireland. It's quasi-in-and-out of the UK.

This isn't like Kent County Council asking for special treatment, not least because it's a post-conflict society that both sides of the negotiations have treated differently all the way through the negotiations (and still are - like all the current derogations and ongoing negotiations about the Protocol which, according to both sides is going quite well).

[The Brain]

The UK has had literally years to prepare for this. And the whole point of Brexit is the EU NOT being responsible for the UK, or parts thereof. The "I didn't bother studying for the test, can you PLEEASE give me a passing grade anyway?" line of argument is unworthy of governments or other organizations.

Ireland will do fine, it's in the EU. NI isn't in the EU and therefore not the EU's concern.

But this just isn't true. Both sides have treated Northern Ireland as separate and different from the very start. It's the only bit of the UK that is conditional on consent, they have a right to leave the UK and join Ireland at any time, it is acknowledged by the EU that in the event that consent is withdrawn leading to a united Ireland then Northern Ireland would be treated like East Germany in joining the EU. Similarly it's the only bit of the UK where there is cherrypicking.

Northern Ireland is in the UK single market and the EU single market, because it's different and both sides have taken responsibility to treat it differently to acknowledge its unique position. And both sides are meant to use their best endeavours to protect the peace and prosperity of Northern Ireland. It's quasi-in-and-out of the UK.

This isn't like Kent County Council asking for special treatment, not least because it's a post-conflict society that both sides of the negotiations have treated differently all the way through the negotiations (and still are - like all the current derogations and ongoing negotiations about the Protocol which, according to both sides is going quite well).

And until NI joins an EU country it is not in the EU. NI is in the UK, and not in the EU. The EU does not, and cannot, manage which products enter NI. The UK does. If the UK chooses not to have products entering NI comply with EU regulations then the Ireland/UK land border closes, that's all. If the UK thinks that keeping an open border is important then just have all the necessary checks on products entering NI. The UK has had more than enough time to prepare for this. The UK can of course (for whatever reason) make it its policy to starve the Irish, but that might not play well in the US.

If UK firms get special treatment then there are many other countries with very fine people who would love to have their products enter the EU market without proper checks.

One thing that comes close to UK tunnel vision regarding Brexit is the Irish idea that Irish troubles matter to people beyond that little piece of Atlantic Balkans. "Your ancestors were mean to my ancestors! I hate you!" doesn't carry much weight in the rest of Europe where many countries have suffered hundreds of thousands or millions killed by neighbors in living memory, and they still get on with each other today. The Irish should grow up and ditch the Balkans routine.

[Zanza]

I am not an expert on supermarket logistics, but from what I know, normally you have regional hubs that then distribute to the supermarkets. Do they seriously not ship in bulk, but commission trucks for single supermarkets in GB and then ship them via ferry?

Anyway, they could easily have built a regional distribution hub since last year, so what is their excuse for not adjusting their supply chain?

Higher cost is obviously not a relevant argument as they could ask for compensation from the 350 million GBP per week that the UK is saving now.

[Sheilbh]

I am not an expert on supermarket logistics, but from what I know, normally you have regional hubs that then distribute to the supermarkets. Do they seriously not ship in bulk, but commission trucks for single supermarkets in GB and then ship them via ferry?

Anyway, they could easily have built a regional distribution hub since last year, so what is their excuse for not adjusting their supply chain?

So I'm not an expert either - my understanding is that supermarket distribution basically work with huge warehouses of which there are very few that takes everything in from suppliers and then distribute to regional hubs. So regional hubs in Northern Ireland wouldn't necessarily make a difference because the issue is about the number of different products on the lorry. If they were just shipping a lorry of one single good it would be manageable. Rather each supermarket would need to build one of their huge warehouses in Northern Ireland who can receive single product shipments from the producers.

But I think it is single supermarket basis because of the way just-in-time works in retail. Shops don't have a back-room and don't store excess produce (which used to be a thing when I was young and worked in a shop) because it's dead space that can be used for selling things. Every day they report what they need and order it and the lorry travels overnight or through the evening to be re-stocked that night. Everything the shop has is on the shop floor which gets re-freshed daily.

The excuse of the business is that it's not worth it. It would be a large cost for a a very small part of their business. So instead they're looking at reducing the products they offer, or shutting down their Northern Irish business.

And it's worth noting this is an entirely different issue than the one Johnson was using to justify the Internal Market Bill which isn't real and was largely about the UK's SPS regime in a FTA - that's the food blockade thing. It's been known since the WA was passed that there would be checks on food going into Northern Ireland the issue is how onerous they are particularly in supermarkets because of how they operate - it's not "trade" in the normal sense of sending a container of x product. It's a container of hundreds of products.

Higher cost is obviously not a relevant argument as they could ask for compensation from the 350 million GBP per week that the UK is saving now.

Subject to EU state aid rules (which apply in Northern Ireland)

One other possible solution could be the suspension of EU competition rules - this happened here for the last year to deal with covid. So the supermarkets could share information and work together to supply an area and particularly the vulnerable in an area, in normal times that would be anti-competitive. But maybe in the long-term you could allow the supermarkets to jointly buy a single super-hub that could receive goods from suppliers and then be used for distribution to multiple brands in Northern Ireland.

And of course in the long-run the brands with this infrastructure already on the island of Ireland - because they have a large Irish presence - will probably move into Northern Ireland and take over which will be another soft-step to unification. But even that would require time for them to build up their infrastructure in Northern Ireland.

One thing that comes close to UK tunnel vision regarding Brexit is the Irish idea that Irish troubles matter to people beyond that little piece of Atlantic Balkans. "Your ancestors were mean to my ancestors! I hate you!" doesn't carry much weight in the rest of Europe where many countries have suffered hundreds of thousands or millions killed by neighbors in living memory, and they still get on with each other today. The Irish should grow up and ditch the Balkans routine.

In living memory is a bit different from within my memory

We're not talking about the last war, there were still bombs going off in the 90s-00s. There's been assasinations and murders in the last 10 years related to the Troubles. Also whether you like it or not Irish troubles do matter to the EU because Ireland's a member state. Just like, annoyingly, Balkans issues and Cyprus matter to the EU.

If UK firms get special treatment then there are many other countries with very fine people who would love to have their products enter the EU market without proper checks.

Which is why it's quite limited: firms distributing sterling marked products from GB to their own premises in Northern Ireland.

[The Brain]

We're not talking about the last war, there were still bombs going off in the 90s-00s. There's been assasinations and murders in the last 10 years related to the Troubles. Also whether you like it or not Irish troubles do matter to the EU because Ireland's a member state. Just like, annoyingly, Balkans issues and Cyprus matter to the EU.

There are ethnic/religious assassinations and murder going on today around Europe. Starting/continuing an ethnic/religious war isn't the response of a grownup.

And if Ireland feels that being a member of the EU gets in the way of their petty ethnic squabbling then they are very free to leave the EU.

If UK firms get special treatment then there are many other countries with very fine people who would love to have their products enter the EU market without proper checks.

Which is why it's quite limited: firms distributing sterling marked products from GB to their own premises in Northern Ireland.

I'm sure all exceptions that will be granted thanks to the precedent will be limited in their way.

[Iormlund]

I really don't see what all the fuss is about. Contingency plans should have been in place years ago.

Who cares if this results in British firms finding NI an unattractive market? I'm sure Irish firms and supply chains will promptly fill the void.

[Sheilbh]

Who cares if this results in British firms finding NI an unattractive market? I'm sure Irish firms and supply chains will promptly fill the void.

No-one cares about the firms, people care about whether there are supermarkets with goods to sell the people of Northern Ireland.

I agree Irish firms and supply chains will fill the void - but it's not going to happen "promptly" or overnight. They need to find premises etc which will take time. I think that's the long-term answer, but it doesn't address the short-term issue of whether people in Northern Ireland will have easy access to all the goods and food they need. Especially in the context of a pandemic when no-one particularly wants people from, say, County Down, schlepping to County Louth to do their shopping - I think Ireland has banned travel outside of your county because they're in quite a strict lockdown.

And query if it will take a little longer for Irish firms to fill the void given that Ireland is the most affected EU country by Brexit so will probably be dealing with some economic shock that may impact whether the supermarkets like Dunnes decide to expand.

[Tamas]

Who cares if this results in British firms finding NI an unattractive market? I'm sure Irish firms and supply chains will promptly fill the void.

No-one cares about the firms, people care about whether there are supermarkets with goods to sell the people of Northern Ireland.

I agree Irish firms and supply chains will fill the void - but it's not going to happen "promptly" or overnight. They need to find premises etc which will take time. I think that's the long-term answer, but it doesn't address the short-term issue of whether people in Northern Ireland will have easy access to all the goods and food they need. Especially in the context of a pandemic when no-one particularly wants people from, say, County Down, schlepping to County Louth to do their shopping - I think Ireland has banned travel outside of your county because they're in quite a strict lockdown.

And query if it will take a little longer for Irish firms to fill the void given that Ireland is the most affected EU country by Brexit so will probably be dealing with some economic shock that may impact whether the supermarkets like Dunnes decide to expand.

I guess everyone understands the issue, their point is that all of this is British responsibility and a British failure to act if not addressed in time, not an EU one.

[Sheilbh]

So what was the action the British were meant to have taken?

I can see how the UK could re-imburse companies so they don't have additional costs to ship to Northern Ireland (but that would need to be subject to EU state aid rules because they apply in Northern Ireland). But what practical steps could the UK government take around the requirements for EHCs per product, per shipment and the need for a certain number of checks about that. That's about the operation of the frontier of the single market.

No amount of IT systems or physical infrastructure will change the issues for supermarkets specifically. I totally agree on the SPS standards and the operation of the FTA (the "food blockade" which Johnson talked about) which is made up and depends on the UK. But I'm just not sure and haven't seen any practical steps the UK could take to avoid or mitigate this - which makes sense to me because it's a single market issue so there's not much the UK can do, it's about how the EU applies the rules (and the checks vary across European frontiers anyway - 30% is the highest).

[The Brain]

Whatever steps they planned for dealing with this issue when they activated Article 50? The UK is a sovereign nation, they can solve their domestic problems any way they see fit.

[Tamas]

So what was the action the British were meant to have taken?

I can see how the UK could re-imburse companies so they don't have additional costs to ship to Northern Ireland (but that would need to be subject to EU state aid rules because they apply in Northern Ireland). But what practical steps could the UK government take around the requirements for EHCs per product, per shipment and the need for a certain number of checks about that. That's about the operation of the frontier of the single market.

No amount of IT systems or physical infrastructure will change the issues for supermarkets specifically. I totally agree on the SPS standards and the operation of the FTA (the "food blockade" which Johnson talked about) which is made up and depends on the UK. But I'm just not sure and haven't seen any practical steps the UK could take to avoid or mitigate this - which makes sense to me because it's a single market issue so there's not much the UK can do, it's about how the EU applies the rules (and the checks vary across European frontiers anyway - 30% is the highest).

But it's a "single market issues" only because the UK has decided to leave the single market. Why the single market work to resolve issues that its existence present to companies/countries which are not a member of it? The UK is not the only country that is facing economic disadvantage due to  not being single market members.

[The Brain]

The UK idea that it's the EU's job to fix the UK's self-inflicted wounds has appeared to be a constant these past years. Surely the UK understands that no one in the EU cares?

[Sheilbh]

But it's a "single market issues" only because the UK has decided to leave the single market. Why the single market work to resolve issues that its existence present to companies/countries which are not a member of it? The UK is not the only country that is facing economic disadvantage due to  not being single market members.

But that's factually wrong - Great Britain is leaving the single market, both sides agreed that Northern Ireland would continue to be in the single market. The UK is both in and out of the single market. This issue doesn't occur if there's a hard Irish border or if GB also stays in single market.

Both sides agreed that one of their priorities was to prevent a hard Irish border and to protect the peace process. That means that Northern Ireland is a weird (even more weird) lacuna of EU and UK law which is the responsibility of both sides because EU law continues to apply and it's still in the single market to this part of the UK.

We're not talking about a country facing economic disadvantage due to not being single market members, we're talking about a country that is still in the single market and facing possible hardship because of how that frontier operates within the UK.

Whatever steps they planned for dealing with this issue when they activated Article 50? The UK is a sovereign nation, they can solve their domestic problems any way they see fit.

But the UK isn't sovereign over Northern Ireland. European law continues to apply, the single market still applies, there are rules around how EU and/or UK legislation will apply in Northern Ireland.