Richard North, 24/08/2018  

So, yesterday we saw the first 25 of the long-awaited "technical notices" on "how to prepare if the UK leaves the EU with no deal", issued by the Department for Exiting the European Union. And with it came a speech from the secretary of state, Dominic Raab (aka midair bacon).

Yet, for all the media hype, we're not much further forward. The notices are either so general in application or so narrow in focus that there is absolutely no sense to be gained of how the UK as a whole would fare in the event of a "no deal Brexit". Nor, indeed, will many of those who currently trade with EU Member States be any the wiser.

To that extent, it is difficult to ascertain whether Mr Raab is attempting to take us for fools, or whether the opaqueness of the notices is simply a reflection of the general incompetence of his department. But is it certainly the case that, by contrast with the Commission's Notices to Stakeholders, we are still far better off going to the EU for our information.

Crucially, if we accept that the most immediate impacts of a "no deal" Brexit will be on trade with EU Member States, and that the effects will vary significantly according to sector, one would have thought that Mr Raab's department might have followed the same strategy as the EU. And had that been the case, we would have seen sector-by-sector analyses, starting with those of greatest economic significance.

The first of the 25 notices, styled as an "overview" and headed "UK government's preparations for a 'no deal' scenario", starts well enough. It tells us that the notices "will set out information to allow businesses and citizens to understand what they would need to do in a 'no deal' scenario, so they can make informed plans and preparations".

In that document, though, we search in vain for any such information and have to content ourselves with such anodyne phrasing as: "We want businesses to be reassured that, even in a 'no deal' scenario in March 2019, the government will seek to do what it can to make the transition as smooth as possible and allow time to make significant changes".

One might say that this is fair enough for an overview – expect perhaps that the very generality of the document debars it from claiming to be a "notice". The Commission, when providing its own overview, provided a completely separate document, its COM(2018) 556 final, with a detailed annex.

Skipping this overview, we find the rest of the notices ordered in ten categories. These deal with: applying for EU-funded programmes; civil nuclear and nuclear research; farming; importing and exporting; labelling products and making them safe; money and tax; regulating medicines and medical equipment; state aid; studying in the UK or EU; and workplace rights.

All we have to do is look at the first category to see how what might be good intentions unravel. Although worthy enough, I would not have put at the top of my list, the government's guarantee for EU-funded programmes, Horizon 2020 funding or delivering humanitarian aid programmes.

One could say the same for nuclear research and civil nuclear regulation, mostly because the issues in this sector are not immediately germane to how the UK will manage in the first few days of a "no deal" Brexit.

Then we get to "farming" as the next category. If one expected detail on how agricultural goods might be imported and exported, prepare to be disappointed. We are regaled with detail on farm payments and rural development funding, issues which have been settled for some time and which remain roughly the same whether or not we have a Brexit deal.

But then we come to "importing and exporting", which offers four notices, respectively on: trade remedies; trading in general with the EU; classifying goods in the UK Trade Tariff; and exporting controlled goods.

The only notice that promises meat of any substance is the one on general trading with the EU. Putative exporters will be turning to this for the guidance they so desperately need, while the general population will be looking for indications as to how we will avoid logjams at the ports.

What we are confronted with is a document of nearly 3,400 words, approximately seven pages in length. But when it comes to specific detail on exporting goods to the EU, we find a mere 490 words – all of which are devoted to the minutia of the paperwork required to satisfy customs procedures.

If one was to take this notice at face value, therefore, the effect of a "no deal" Brexit is to expose exporters to an amount of paperwork. Nothing else is discussed. There is not the slightest clue of the problems confronting different sectors, from chemicals to medicines, motor vehicles and aviation parts, live animal exports (including racehorses), foods of animal origins, and the whole host of manufactured goods which require third party testing.

Doubtless some of the detail will come later, but given that this high profile launch of the notice series was being closely scrutinised by the media, one cannot help but wonder why there is nothing at all said about the massive impact a "no deal" will have on our exports to EU Member States.

On this blog and elsewhere, the effect of a "no deal" Brexit on imports has also been discussed – especially in relation to the inspection of food from EU Member States. But nothing of that controversy pervades the notice. The specifics on importing are covered in just over 500 words, and again the focus is entirely on customs procedures.

But when we move to the next category, on "labelling products and making them safe", this is where one really does smell the proverbial rat. Having skimmed over farming issues, one notice in this category returns to agricultural matters with a study on the production and processing of organic foods.

Of all the subjects that could be addressed in this series, this has to be way down the list on any scale of priorities one could imagine. Alongside labelling tobacco products and e-cigarettes and developing genetically modified organisms, these in the grander scheme of things, will have minimal impact on "no deal" Britain.

As we contemplate "complete and utter chaos" in event of "no-deal" Brexit, "labelling products and making them safe" might be the very last thing on peoples' minds. Yet, the Department for Exiting the European Union awards the issues an entire category in its launch presentation.

The "complete and utter chaos" quote, incidentally, comes from the World Road Transport Organisation (IRU), which has warned that this is what British and European lorry drivers face with a "no-deal" Brexit scenario.

"We're not divided on this issue in the industry, we all want the same thing. If [there is no deal] it’s going to be complete and utter chaos," says Boris Blanche, the IRU's managing director. "The logistics will suffer and you are going to have serious challenges to move goods, which would be a real pity for UK and for Europe", he adds.

Needless to say, transport does not feature on Mr Raab's list. Nor does aviation. Nor does the motor industry. Nor does the massive chemical industry. These things are not important enough to feature in the first tranche of his notices – or maybe, they are too important.

Medicines, however, do get a look in. We see notices on the batch testing of medicines, measures to ensure blood and blood products are safe, the registration of medicines, medical devices and clinical trials, regulatory information on medical products and the quality and safety of organs, tissues and cells.

If one was so minded, one could imagine that Mr Raab was having a huge joke at our expense. Having wound up the media to fever-pitch and put "no deal" firmly on the agenda, he has fed them a few inconsequential crumbs and stood back to enjoy the fun.

He has been amply rewarded with a headline in the Mail which has ministers admitting "online shoppers and tourists visiting EU could face millions of pounds in credit card charges... and we could even run out of SPERM". That's what a "no deal" Brexit really amounts to?

Even the Irish Times has swallowed the bait, gravely reporting this morning that "the publication by the British government of papers on a 'no deal' Brexit scenario only serve to underline how damaging such an outcome would be".

On the other hand, it only takes a brief run though the Notices to Stakeholders from the Commission to demonstrate just how trivial and superficial Mr Raab's version of "no deal" Brexit really is. On reflection, there can be little doubt that we're being played - taken for fools. What Raab is actually doing is taking the piss, right from under our very noses. This is daylight Raabbery.

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