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1/ Articles like this explain a very niche and technical topic to a wider audience. Which is fantastic. But it may be bit misleading so in the spirit of clarification a couple of points. Happy to hear other views @instituteforgov instituteforgovernment.org.uk/explainers/rul…
2/ #rulesoforigin do not affect free movement of goods as when you have free movement of goods you don’t need rules of origin. At a time when most people are still trying to figure out what free movement means this might be an important distinction
3/ Preferential and non-preferential #rulesoforigin are so different summarising them both in one article can lead to confusion. The article jumps from one to the other without clarifying which point refers to which type
4/ When talking about outweighing the benefits it can only refer to pref rules as non-pref origin is not optional. All goods need to have an origin declared on import declaration and for other purposes
5/ Last substantial transformation rule applies to non-pref origin. Dealt with slightly differently in preferential rules
6/ Main criteria for substantial transformation under pref origin are: change of classification (can be on different levels not only heading), value added and specific processing. Minimal processing is part of general rules.
7/ PEM is incredibly important for a number of industries with integrated supply chains involving e.g. Turkey. Cannot be dismissed so easily. PEM is being updated at the moment and if successful the consequences of not being a part of it after Brexit could seriously hit the UK
8/ Re diagonal cumulation both @uk_tpo and @SamuelMarcLowe @CER_EU talk about diagonal cumulation with 3rd parties. But diagonal cumulation requires identical #rulesoforigin (see even the WCO on this). So all 3 FTAs would need identical rules.
9/ Sam uses an example of EU-JP #FTA. But this is an example of cross /3rd party /extended cumulation which exists and does not need identical rules. I think this is what we’re talking about here re #Brexit
10/ I wrote about the possible application of cross-cumulation for #Brexit here. Though it's not diagonal, I still completely agree with @SamuelMarcLowe that this is a) a partial solution b) most likely not politically possible. e15initiative.org/publications/b…
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