24
Examination of witnesses
Neil Johnston, Claire Sullivan and Jonathan Walsh.
Q17 The Chair: Good morning, and welcome to this public meeting of the Northern Ireland Scrutiny Committee. We are today holding the second and final public evidence session of our short follow-up inquiry on strengthening Northern Ireland’s voice in the context of the Windsor Framework. This follows the Government’s recent response to the committee’s last report, as well as their response to Lord Murphy of Torfaen’s Independent Review of the Windsor Framework.
We are joined by three Northern Ireland business representatives. Neil Johnston, who is with us in the room, is the director of the Northern Ireland Retail Consortium; Jonathan Walsh, who is online, is the director of Fortior Insight Ltd; and Claire Sullivan, also online, is the head of policy at CBI Northern Ireland. You are all familiar to us, and we are familiar to you. You are all very welcome, and we look forward very much to your evidence. We would be grateful if you would introduce yourselves briefly the first time you speak. Today’s meeting is being broadcast, and a transcript will be taken for subsequent publication, which will be sent to all the witnesses to check for accuracy. I refer to the list of members’ interests, as published on the committee’s website. This session can continue until 12.15 pm.
A warm welcome to you all. I will start with the first question. What are the key issues facing your organisation, clients or sector in relation to the Windsor Framework?
Neil Johnston: I am from the Northern Ireland Retail Consortium, part of the British Retail Consortium, which has over 200 members in the UK. About 100 of those operate in Northern Ireland. They either have physical stores in Northern Ireland or sell online or by other means into Northern Ireland. In this context, it is best known, I suppose, for all the food retailers—all the supermarkets, the Henderson Group and the Musgrave Group are members of the consortium. Our other members are very diverse, from Bensons for Beds to Greggs, Currys, Kingfisher plc and McDonald’s. Most of the folk that you would associate with British high streets, retail parks and shopping centres are our members.
Needless to say, in Northern Ireland I am often asked about the Windsor Framework, and it struck me last night—if you will pardon the expression—that it is a process of vicarious redemption or atonement, whereby the sinless individuals, in this case the retailers, take on the penalty that the sinful Governments cannot pay for themselves. Essentially, the righteous must suffer in the place of the guilty. We must fully and faithfully implement the Windsor Framework either to atone for the apparent sins of the previous Government or to re-establish the trustworthiness or bona fides of the current Government. I would maintain that, frankly, either proposition is slightly absurd and unfair on my members.
The retail sector has had to suffer a significant amount of pain as a result of the Windsor Framework. We have taken the pain so that others may gain. We understand the arguments about the need for the Windsor Framework for the greater good of Northern Ireland and indeed the EU, but there is no gain for retail, just pain. Significant bureaucratic complexities have been imposed, most recently the third phase of “not for EU” labelling in July last year and, from 31 December last year, import control system 2, ICS2, which is the updated safety and security declaration system for all goods entering Northern Ireland from Great Britain or countries outside the EU.
Consumers do not see the retailing swan pedalling furiously beneath the surface to maintain the shelves full of products. Members who live in Northern Ireland will not see much difference when they go into their stores but, in reality, an extensive range of products are not available in Northern Ireland in the way that they are in Great Britain. Specifically, the internal market has been compromised by the fact that many branded product suppliers are simply unwilling to separately label the small percentage of their output that goes to the Northern Ireland market as “not for EU”.
This pain is ongoing, substantial and costly. The costs run into millions of pounds per annum. As I say, we regard this as a problem created by a combination of the Government of the day and the European Union, but it seems that it is my members who are picking up the tab in terms of trying to solve these issues.
There are wider issues, which I will touch on briefly. There is divergence, which I am sure others have raised with you—specifically, the time lag between EU regulations, where we have decided to align. One that comes to mind is on tumble dryers. Members in this room will be aware of it.
The Chair: We are.
Neil Johnston: The EU decided to move last July, I think, and the Government decided to start a consultation last August. I believe the SI might have been moved this week to bring us in line. There is no real conflict about the direction of travel, simply about the time lag which means that products are not available in Northern Ireland. That creates huge problems for my members and, of course, consumers.
Similarly, engagement around the environmental legislation, which can have a big impact on retail operations, has been less constructive than in other areas. We still do not know what the situation is with regard to EUDR, which could result in significant numbers of products being “delisted”, as my members term it. As you will be aware, EU regulations on environment and product safety will continue to apply in Northern Ireland only, regardless of the reset. This is a matter of ongoing concern.
The reset will make a difference. We live in hope that it will bring an SPS agreement, et cetera, but we still do not know what might be required for regulations not covered by the UK-EU negotiations—for example, with regard to the movement of wines, spirits and fish into Northern Ireland.
The Chair: Thank you, that is very clear.
Claire Sullivan: Good morning, everyone. I am head of policy in Northern Ireland for the CBI. Thank you for the opportunity to appear before the committee and for facilitating me to dial in.
The CBI has a range of members across all sectors, operating across all of the UK and in Northern Ireland. Regarding the key issues facing our members across all sectors in relation to the Windsor Framework, we need to look at it in the wider context—at all the challenges that businesses are facing. We recently had a round-table session with a range of members from different sectors, and it is clear that cost competitiveness is a dominant concern. We are seeing the cumulative costs and pressures our members are facing across all sectors. They include increasing labour costs and energy costs and, in the world we are living in, increasing geopolitical issues, as well as the impacts of what is happening in the Middle East at the moment. Members are concerned about how costs will keep increasing and how they are going to absorb them.
Members are saying that the Windsor Framework is one of the costs that they are absorbing. We need to see it as an opportunity cost, because spending money on absorbing and making sure that they meet all the requirements under the Windsor Framework means that members cannot spend money investing, growing their companies and growing the wider economy in Northern Ireland. As you have heard from Neil and from speaking to people from other sectors, there will be other specific issues within other sectors, but for us it is key to see it as a wider issue around cost competitiveness.
Jonathan Walsh: Good morning, everybody. Thank you, Lord Carlile, and all the committee members, for the invitation to participate today and facilitating me to dial in. By way of brief introduction, I am a founding director of Fortior Insight Ltd, a strategic trade advisory established in 2016 specialising in customs, cross-border trade and regulatory frameworks, with particular depth around the Windsor Framework environment.
Many organisations that you have met and will meet during these evidence sessions represent businesses in policy discussions or lobbying on behalf of members. My role is slightly different in that I spend most of my time working directly with traders, trying to make the systems work in real supply chains. That means that the evidence I can offer today is based primarily on how the Windsor Framework operates in practice for businesses moving goods.
To go straight to question 1, one observation that I would make from working with businesses is that most of the friction that traders encounter arises not from the legal architecture of the Windsor Framework itself but from how the systems operate in practice and how clearly it is understood by businesses, especially in Great Britain. In my experience, the key challenges tend to relate to understanding the systems, operational implementation, data and compliance capability and fragmented guidance.
To put a bit more meat on that, we are five years in, and the understanding of “at risk” versus “not at risk”, especially with commercial processes, is just not there. I have regular conversations with companies where they will explain things to me. For example, I will ask, “Are you a commercial processor?” Yes. “Are you operating in one of the exempt areas, such as construction, charitable organisations, manufacturing products that are then given away, consumer products as in sandwiches direct to consumers or animal feed that has been used by yourself or sold to a further entity?” No. “Is your turnover over £2 million?” Yes. I will say to them that their goods are automatically deemed at risk as a commercial processor, because they do not meet the further eligibility criteria—and I have had this explanation given to me: “We bring in material and we do not sell those materials. We process those materials into a finished product, which is worth many times the value of the materials that we bring in—therefore, our goods are not at risk”.
The reality is that under Article 5 of the protocol, their goods were automatically at risk, so that understanding is not there. That is the biggest operational implementation element that I have seen in the past nine months or so since May last year, but in reality I have been in Westminster and have been talking about this for many years, and it is about the fast parcel operators.
Yesterday, I had an example of a trader coming back to me to say that when they had gone to their fast parcel operator and said that they wanted to use their waiver to offset the tariffs on their at-risk goods, the fast parcel operator came back and said that the UK Government have not set up a system that will allow companies to use their waiver. That is ridiculous. We have issues with that and operational implementation, and the data and compliance capability that companies are simply not getting from their suppliers, because there are no export declarations—no requirement for GB to NI export declarations or export safety and security declarations. They are not getting commodity codes or country of origin, and they are not getting the information that is required, because they are not getting commercial invoices.
That has changed a little bit as a result of ICS2, but I have still seen cases of companies not getting the information that they require to close declarations, or it is incorrect. On that fragmented guidance, I know from listening back to what has been said in a previous session—and no doubt points will be made on it today—that we have lots of different areas of guidance, but the guidance is not always specific. We have issues with that guidance not being the same guidance when you talk to different departments in the same UK Government group, such as HMRC. Those are the main issues that I am seeing.
Q18 Baroness O'Loan: I shall start with Claire Sullivan. What is your response to the Government’s announcement of a new Northern Ireland business stakeholders’ group? Does it differ from more informal previous fora, such as the Northern Ireland business Brexit working group?
The Chair: Mr Walsh, shall we start with you?
Baroness O'Loan: I actually said I wanted to hear from Claire first.
The Chair: Sorry.
Claire Sullivan: In response to your question, the Government’s announcement around the new Northern Ireland business stakeholders’ group is positive. I was not working for the CBI when the Northern Ireland business Brexit working group was established but, from what I can gather, it was set up to fill a gap at the time and was very useful, really helping in terms of engagement and feeding issues into government.
What is positive about the establishment of this group is that it has been expanded in terms of covering further trade bodies, and that will be good in terms of giving that breadth of sectoral expertise and feeding in issues across all sectors. The fact that it is being supported by government means that it will have the resources—and, in terms of supporting the work, there will be more support there. We all come from organisations with limited resources, so that will be positive.
The group has met on a few occasions. We were on a delegation to Brussels last week, which was really positive as an opportunity for us all to meet in person and get to know each other. What was positive was that we are gelling and showing this consistency across the issues and solutions that we want to raise. The point was made last week that, while the breadth and size of the group is useful, it also may mean that it becomes unwieldy, so we need to look at opportunities to set up sub-working groups or task and finish groups to look at specific issues. But it is a positive start, and we need to make sure that we maximise the potential of the group and keep it under review to see how we can improve its working.
Jonathan Walsh: I am not directly involved, albeit that I am a member of some of the stakeholders involved, but I would share Claire’s comments that it is a very positive step. It formalises engagement and means that everybody from the group’s stakeholders is involved, which may not have been the case in the past. However, I would want to see it not be just a talking shop. My clients, the people I work with, will want to ensure that there is operational feedback from traders being relayed, and not just high level. We need to meet behind that, we need the examples and we need to know about the systemic issues being faced. It should not be just about policy discussion; real supply chain issues need visibility—but, overall, I think that it is absolutely positive that the group has been formed and it is working together.
Neil Johnston: I do not have much to add to what Claire has said. I was or am a member of the business Brexit working group and the stakeholders’ group. The business Brexit working group was very good, because it is quite small, and in Northern Ireland nearly everyone knows each other so it developed a very collegiate feel very quickly and has maintained it over the years, which is very beneficial. By its nature, this group is not that collegiate; it is bigger and there are a lot of people from England on board representing GB bodies and so on. That is great, because you get to hear their issues. As Claire says, you get the car retailers and the express parcels—there is a huge range of interests there now. It will be interesting to see how the group goes forward. I hope that the secretariat to the group will be well supported and can get the ears of all the various departments and drive things forward.
Baroness O'Loan: Is the Northern Ireland business Brexit working group still functioning?
Neil Johnston: Yes.
The Chair: Could you indicate what level of officials or other people you met in Brussels when you were there last week?
Neil Johnston: Is that question for me?
The Chair: Either you or Claire.
Neil Johnston: We met folks from the UK mission and from the EU, mainly the joint committee, and folks from the Cabinet Office and the executive office in Brussels, as well as the Irish permanent representation as well.
The Chair: So you met those groups separately?
Neil Johnston: Yes.
The Chair: Claire, what did you gain from the visit to Brussels that is applicable to your membership?
Claire Sullivan: I thought the meetings were very useful. It was director level in terms of a lot of the meetings, and it was useful to get some insights into the relationships between the EU and the UK at a higher level. There were also some practical updates around some of the work going on in the Cabinet Office on supporting businesses. I know that you are going to ask questions later around the one stop shop; it is always useful to get those. Then in meeting with the specialised committee, it was useful to be able to give our views from all our members’ perspectives on some of the key issues that they are raising with us and helpful to hear from the EU officials that Northern Ireland is still being considered when they make decisions.
Q19 Baroness Ritchie of Downpatrick: I welcome the witnesses, either in person or online. What has been your experience to date on engaging with the Government on issues related to the Windsor Framework? Reference has been made to the issue around friction. What practical measures could the UK Government implement in the existing Windsor Framework arrangements to reduce friction for businesses trading between Britain and Northern Ireland? Finally, what outcomes do you hope to see from the Government’s commitments to engage with business in relation to the Windsor Framework in future?
Jonathan Walsh: I have been very fortunate in that I have engaged with government departments from the outset. I have had a very good relationship with departments such as HMRC, from the days when Elly Patterson was involved right through to Hermione, Simon and Amy, even to director level, with Alex Pienaar. They have made themselves available and helped to work directly on trader issues in real time; they have stepped in when we had issues around things like moving goods that had both UK and EU tariff-free quotas attached, and they needed to get clearance to bring those goods in.
I have had the opportunity to meet other departments such as DBT and to engage with them in preparation for the general product safety regulations that are coming in. I am very grateful for those relationships, as are my clients. In terms of the UK Government themselves, I have had meetings and have been over in Parliament for discussions. I have followed up on those discussions and, to be honest, I did not get any responses a lot of times. I used a freedom of information request to try to get information that in reality I already had the answers to, but I wanted to highlight what we have seen in terms of issues around services such as TSS, and I was fobbed off. That was not just me asking questions for the sake of it; it was coming back because of the systemic problems that we are seeing with our clients and the companies that we support. Just to put that in context, I work from the one-man cross-border trader right up to the billion-pound companies, the multinationals that are known around the world. The issues are the same across the board.
In terms of government departments, there has been fantastic engagement, and they have worked hard to assist. I have met them regularly in person as well as having calls. At the outset of the trader support service, I had direct contact and had somebody assigned who worked through different changes; we had regular briefings, and I was able to give that support back to my members or clients, to support them. It meant that they were not getting bombarded by questions from multiple sources but dealing with somebody who actually knows and understands this. I have been in trade for nearly 30 years. I have been working in international trade and I have a background in this area.
To go forward, we welcome engagement, but that engagement with businesses has to work for businesses, because it is unproductive and unpaid time. We cannot just engage by filling in reams of questions online; businesses do not have the time to do that or to come over to Westminster and meet you. We rely on trade bodies to assist us and do that, but they do not, with all due respect—because they are working across so many different areas—have the level of knowledge that somebody who deals with these things on a daily basis has.
Neil Johnston: Northern Ireland Retail Consortium, which is part of the British Retail Consortium has regular ongoing engagement with a wide range of government departments—the Cabinet Office, Defra, DBT and the Northern Ireland Office, HMRC and the Northern Ireland departments. We are fortunate that in London we have a big array of policy officers. I am a mere generalist—they are the experts in the policy. Also, because some of our members are quite large concerns—I am thinking primarily of the food retailers here—they are able to dedicate the expertise and resource, so they all have people who understand these issues. I appreciate that that is not reflective of the entire economy; these are big retailers, such as Tesco, Sainsbury, the Co-op and the Lidls of this world. They have people dedicated to this who can make it work, although it may cost them money.
We have good ongoing relations. At one point we had a weekly call with Defra every Friday morning without fail, and all the major retailers were represented on that call to try to iron out the real-time problems that were arising. So we are very fortunate that we have those resources at BRC level and in those main, big food retailing members. I would worry that the smaller members do not have that level of expertise; they are perhaps struggling more to come to terms with it.
To go forward, we need the UK Government to liaise as closely as possible with the EU so that developments that may affect retailing are flagged with the trade bodies. We have a large number of bodies in that stakeholder group. A lot of the Northern Ireland ones are not hugely resourced; some of them have backing from their parent groups in London, but the sooner we can get some sight of what is coming down the line, the better.
When there is a decision to align, coming from the UK Government, we need to do it rapidly—rather than having a situation whereby companies that prefer to deal on a UK-wide basis and in an ideal world would sell the same products in Scotland, Wales, Northern Ireland and England, have a timeline saying that this time next year they would all be aligned but in the meantime they have to do something completely different. That is very problematic for my members, obviously. If the Government decide that on whatever issues we are not going to align, they need to work closely with the trade bodies to develop pragmatic solutions—quickly, if at all possible.
Claire Sullivan: On a personal level, I have very good relations with a range of contacts across all departments, both those based in Whitehall and the Northern Ireland departments. I work hard at maintaining those relationships so that when issues arise from members, I can reach out to my contacts. Sometimes they are unable to help but they can point me in the right direction or forward on my query, and we can get help and assistance for members.
Like Neil, I am part of a UK-wide organisation, so I can also link in with and reach out to contacts that my colleagues in other parts of the business have. There is an issue of turnover and movement of staff, particularly in the UK Civil Service. You build relationships and then people move jobs, so it is constant and evolving and you have to work hard at keeping your contact lists up to date.
On the wider Government, I have been in this role for almost four years, and I have been here through some very large changes. We have always said that we need clear, timely and accessible information from government so that businesses can prepare for changes. We have in the past seen information being published late, so, going forward, we need to build on what we have learned. We need to ensure that the guidance is issued in a timely manner, that businesses are engaged appropriately early in the process and that the Government work with businesses to identify potential issues and look at solutions. I know from speaking to officials in the Civil Service that they are open to that and are looking at how we can build it into the process.
I know that it has been raised previously, but divergence will be a big issue moving forward. We need to make sure that engagement with businesses happens early, at an appropriate time. Overall, I find that my engagement with UK officials has been very positive and helpful.
The Chair: Baroness Goudie, let us cross the channel now.
Q20 Baroness Goudie: By way of comparison, what has been your experience of direct engagement with the EU on the Windsor Framework issues? Do you feel that your views have been listened to in relation to the support services available to business in navigating the Windsor Framework and some of the different kinds of portals that you can look at?
Claire Sullivan: Obviously, I have more limited engagement with the EU than I do with the UK Government, but I have found that, where I have reached out, officials have been open to speaking to us. The CBI is fortunate that it has an office in Brussels. We have a director in Brussels, who has a lot of engagement across various EU bodies. I can utilise that and reach out to them. We have also had ongoing engagement with the update on the work programme. One of the challenges with that is that it is at a very high level, so it is a question of how we bring it down to our members’ interests and identify what will impact them. That is where there are opportunities for more work.
We were in Brussels last week talking to Northern Ireland officials based in the executive office about how, when they identify things coming down the line that will have an impact on Northern Ireland businesses, we get that information out there to the right people and shared with not just government officials but businesses. We need to look at how we can improve that information flow and build on what is there going forward.
Jonathan Walsh: Most NI businesses interact primarily with UK authorities rather than EU institutions—that is the norm. On a personal level, I have been in Brussels and engaged with EU officials at a high level. In terms of EU members, I have a very good relationship with Irish government departments, including Irish Revenue and the Department of Foreign Affairs. For example, the second-hand motor vehicle payment scheme for VAT is very relevant for a number of the clients that I work with. It concerns vehicles sold in Northern Ireland to Irish consumers and businesses that have been imported or moved into Northern Ireland from GB under UKIMS, the UK Internal Market Scheme, for sale within the internal UK market. We engaged with HMRC and the Institute of Export and International Trade, and I engaged with Revenue. We needed that three-party participation of different organisations because it is a case not just of how a sale is treated in Northern Ireland but of whether a consumer is able to then register the vehicle in Ireland. The support from Revenue was fantastic and very helpful, as was, of course, the support from both HMRC and the Institute of Export and International Trade. We were able to square the circle, so that was very useful.
For normal engagement, we go to our own Government—the UK Government. We know that there are EU resources there, including the general product safety regulations and the TARIC database, for when we are looking at tariff rate quotas. We automatically go to the UK’s Northern Ireland-specific tariff schedule and things like that, which I have to say are more user friendly. We know that the context is Northern Ireland and businesses here, rather than EU wide, but the engagement has been there, especially at member level.
Neil Johnston: Like Claire, I would say that, compared with our engagement with the UK authorities, our engagement with the EU has been more formal and limited. We engage with all relevant officials and liaise with the office of the Northern Ireland Executive in Brussels and the UK mission when appropriate. We understand that, at the end of the day, EU officials are primarily concerned with the protection of the single market, but we fear on occasion that their approach is not pragmatic enough and is disproportionate to the risk of our retail products being put on the market and somehow getting into the single market. My members have very strong supply chains and track-and-trace capabilities. The risk to the single market is small. Sometimes, when people are employed to enforce regulations, they do so perhaps without taking into account the realities of the working world, to be honest.
In the Windsor Framework the EU acknowledged the need for the UK to protect the operation of the internal market. The arrangement is a compromise, and it should be a two-way street. That street is perhaps not as two-way as we would wish. At the retail consortium, we recognise that, for many other sectors, not least the agri-food sector, from which you heard previously, there are strong economic imperatives in maintaining access to the single market, et cetera. But for UK retailers, it is essentially all pain and no gain, as I mentioned previously. Obviously, we hope that in the future—
The Chair: We will come to the future in a moment. Lord Thomas has a supplementary question.
Q21 Lord Thomas of Gresford: Claire, you said that divergence will increasingly be a problem. Obviously, firms require advice on all those matters. The committee recommended that, in addition to the one-stop shop, the public and businesses should be able to understand the regulatory landscape and laws that apply to Northern Ireland, with something on the government website that shows where the divergences arise. The Government rejected that recommendation and indicated that, if they wish, stakeholders can have a look at the EUR-Lex website, which contains that information. Have any of you used that website? If so, have you found it sufficient for advising people?
Neil Johnston: Many moons ago and more recently, I have looked at EUR-Lex, and I have to say that it is not for the general public, and I am not even sure that it is for public affairs. It may be useful to lawyers, but I am not sure that it is of great use to anyone else. It is difficult to maintain a database of divergence because sometimes these things are not initially apparent and develop only over time. I do not suggest for a moment that that would be easy, so that may not be much of an answer. I am not too sure how we crack this nut other than early engagement with the EU and trying to establish it on a case-by-case basis.
Lord Thomas of Gresford: The alternative is that you have to look at the whole thing on a particular issue and advise whoever is consulting you for advice.
Neil Johnston: Indeed. I am very conscious that a lot of my members have legal departments and employ legal people who can devote their time and energy—
The Chair: Those are your big members?
Neil Johnston: Yes, my big members.
The Chair: It does not apply to someone who is way down the supply chain but maybe a brilliant entrepreneur with a great idea.
Neil Johnston: Absolutely. Really, when you think about it, my big food retailer members, but also the others, are a conduit for goods into Northern Ireland. The food retailers can guide people who want to supply food into the GB or Northern Ireland market, so perhaps they are performing a function there and helping people, but for the wider economy there is a dearth of information and understanding.
The Chair: Can we pause there and come back to this question, just to keep within the structure that we set out? Baroness Sanderson has a question that delves into the supply chain in real terms.
Q22 Baroness Sanderson of Welton: As one of the new members of the committee, it is nice to meet you all. Mr Johnston, I shall start with you. Now we come to the one-stop shop, and perhaps you could tell us a bit about your priorities for it and how the Government have engaged with you on it. I do not mean as part of your general wider engagement; is there a specific engagement plan for the co-creation of this very important service?
Neil Johnston: We are still in the early days on that. We had a briefing on it on our recent trip to Brussels from the folk who are trying to develop it. It is a very ambitious programme and very welcome but, to follow on from the point I was making a moment ago, my members are perhaps the ones who need it less in some regards, as they have dedicated resources at their own expense to make this work. I strongly support the one-stop shop because there are a lot of smaller members. Again, going back to the previous point, a lot of suppliers out there in the GB economy have not a notion, and it is very difficult to get information. The briefing that we had was useful. I am happy that they are going to have various prongs to it that rely on AI, and hopefully over time this will get off to a successful start and it will provide answers to general questions, but I am conscious that we need to have a system where, if you cannot get what you need—and this does seem to be under planning—you will be able to get through to a human being if you have a specific issue to which you cannot find the answer at the one-stop shop.
Baroness Sanderson of Welton: You make the point, which was made last week as well, that it is on the GB supply side—it is not just a Northern Irish issue but is more about the mainland. You have had a briefing but, if this system is to be co-created, is there the outline of a plan for how everyone, including your members, will feed into it as we go on?
Neil Johnston: It is early days, but I think some other organisations have been more involved. Those representing smaller traders, for example, have been more involved than we are.
Lord Thomas of Gresford: Do you think that a government-sponsored one-stop shop should provide a definitive interpretation of a particular set of rules or regulations? Your trade body can only advise, and Jonathan advises—that is his business. Equally, the CBI advises but cannot actually produce a solution. Do you think a government-sponsored one-stop shop should definitively give the answer?
Neil Johnston: It needs to be the repository of all the relevant information, and it needs to work across government. Unfortunately, the nature of government is that it largely works in silos, no matter what Governments try to do to stop that happening, so we need to get all that information into one place. There are a lot of standard questions that people can be directed to, which can help them to progress. I think it will be difficult to get to a situation where someone is able to give individual definitive advice.
The Chair: We may be able to shorten this a little by referring to what happened in our session last week. The discussion then about the one-stop shop included the suggestion that it should start as a triage system and AI—which I think Lord Elliott is well informed about—should be part of it, because it may be able to answer the preliminary inquiries in triage, but that there should be individuals who are able to answer traders’ questions without the necessity of them all having to use their representatives at the CBI or the British Retail Consortium or even a private consultant. Does that make sense?
Neil Johnston: Absolutely. There has to be a human at the endpoint. Again, and I know that others have mentioned this, unlike my members and most of the people who supply them, who are now aware of this, there is a vast array of people in Great Britain who are completely oblivious to this issue. Why would they not be? It has not come across their desk. So the danger is not so much with my members and their suppliers but with the wider economy.
The Chair: Baroness Sanderson mentioned the point about GB. Maybe Mr Walsh, as a consultant who consults for people in GB wanting to trade in Northern Ireland, would like to add something.
Jonathan Walsh: There are a couple of points that I would like to make, and I am just being honest when I say this. First, there appears to be a view that larger businesses have a better handle on all this than smaller ones, but my experiences do not support that. I have worked with both small and large businesses that have the resources to work on this on a daily basis. As I explained to someone once, doing it wrong and doing it right takes the same amount of time. A lot of the larger businesses that have come to me have been bamboozled by the information that they have been provided with.
That leads directly into the idea of the one-stop shop. For me, the concept is a good one, and it offers great potential value. I listened back to your session last week, and I heard AI mentioned and it made me cringe. The reality—and I am thankful for it, because I work in this space—is that AI does not understand the Windsor Framework. I purposely do not call myself an expert. I am a specialist who works day by day on this, and I have learned because of the mistakes that we have experienced and what we have seen when we are working through things. The idea of having a triage service is a great one, but I echo what Neil has said: we need that knowledge in GB. We need it up stream. The issues start where you do not get the right information from your suppliers, or the goods are moved in ways that are not in line. I am back on-site with a very large engineering company tomorrow, and for the last week we have been going back and forth about the customs paperwork that is being completed for the movement of at-risk construction goods via Northern Ireland that ultimately went to Ireland.
The purpose of the responses that have come back to the logistics company, which is a well-known large logistics company, is to blame it on Brexit and tell them, “The systems are there and we have ensured that you do not need to do anything”, but at the same time, “The terms mean that you are responsible”. They are trying to bamboozle them.
We need to have a resource that is actually manned and has people who can look at the terms around what is actually happening and how it is moved. I will give a working example. On the island of Ireland we have InterTradeIreland for businesses that trade cross-border. It provides a telephony service, which is essentially a triage service, and I am one of its service providers. The process starts where people go online. They have the ability to ask questions and access resources, but in most cases, especially in business, people want an answer quickly, so they put in their question and it is sent out to one of the service providers who have some knowledge in that area. Sometimes the question is simple. I dealt with one the other day: “I am moving goods from Turkey into Northern Ireland. What VAT do I pay?”. My answer was, “You pay UK import VAT on those goods, you declare them at risk and then they can move into the EU”. At other times you will find that they need tailored one-to-one support, and we have the capacity and capability to do that. We need that service UK wide.
I know that last week Stuart mentioned the support and the work that they are doing with chambers. I have been involved in that via Invest Northern Ireland—we have been providing webinars and going through it—and we are getting very good questions from companies that want to trade with Northern Ireland. Sixty per cent of all the goods that come into Northern Ireland come from GB. It has not fallen. For those who have removed themselves from the process, we need people to understand that opportunities exist here and that Northern Ireland can be a conduit, a bridge. So the concept is good, but it needs people who know the subject. Unfortunately, with TSS and others, we have tiered support but I do not think some of the people providing that support could pick Northern Ireland out on a map, let alone tell you about the services that are provided and the rules that apply to us here.
Q23 Lord Dodds of Duncairn: I wanted to come in on the earlier question to Neil, which I will come back to, if I may. On the issue of the one-stop shop, I worry about the talk of AI all the time. My experience of any of this stuff is that it becomes very difficult for ordinary people to navigate. What is your knowledge? Claire has had some experience of engagement consultation on this subject. How many staff is it going to have?
There is a massive range of issues that come up under the Windsor Framework. I was speaking to a business last Thursday night in Craigavon—a man and wife who run a craft business. They are sitting with 100 supplementary declarations to fill in, and it takes half a day to fill in one of them because they cannot get product codes or origin-of-product stuff. She is tearing her hair out. It is disgraceful what they are being put through. How is the one-stop shop going to solve her problem?
The Chair: Claire Sullivan, would you like to come in on this?
Claire Sullivan: On the one-stop shop, we have only had initial engagement first. I think we had one online call with officials to discuss it at the initial stages and then we had the briefing in Brussels last week, so it is positive that they are starting the engagement but at this stage they are not yet clear on the nuts and bolts, and they are still working that out. One of the points that I raised last week was that this needs to be a trusted source. When they are building this out, they need to ensure that they have constant monitoring to ensure that it is giving accurate advice and that people are benefiting from it. If it happens that someone goes on to it but they get incorrect advice or it does not help to resolve their issue, they are not going to trust it and will not want to go back to it. This goes to your point about the balance between AI and having a person. That is something that we are making sure that we are feeding into this process: there has to be the correct balance, and it has to be a trusted source of information.
We also need to make sure that this does not duplicate what is already out there. We hear from businesses all the time that they are busy running their businesses and dealing with all the issues that come across their desks. They do not have time to go out and source all the information. If they are members of the CBI or other trade bodies or business organisations then they depend on us to provide them with what is happening and to point them in the correct direction, or if they use organisations like Jonathan’s, they depend on their advice and guidance.
This comes back to the point I made earlier about it being clear, timely and accessible. As we go through the process of developing the one-stop shop, we will be pushing hard to make sure that that is what the end product is and, as I say, that it is under constant review and they monitor it. When we were having the discussion last week, we made the point about the difference between advice and guidance. They should make sure that the information they provide is clear, and indeed, whether it is advice or guidance. The question came up of whether they are going to put in a system to look at the issues that are constantly raised so that they can monitor what those issues are, and maybe then they can look at how to tailor the advice to businesses.
In response to all the questions that have been asked about this, we are at an early stage in the process. I am positive that the government officials are keen and willing to engage with business through the various bodies, and I hope that this will be an ongoing process so that we make sure that what comes out of it will be beneficial to us all.
The Chair: Baroness Sanderson, did you want to ask anything else?
Baroness Sanderson of Welton: No, that was perfect.
The Chair: I thought that was a helpful response. We are at the beginning of the one-stop shop so we cannot expect it to be fully formed yet.
To go back to Lord Thomas’s earlier question about the EU EUR-Lex tool, are we correct that in reality EUR-Lex is for the specialists, not really a tool for the down-the-supply-chain supplier, because it is just much too complicated? Is that a fair comment?
Neil Johnston: Yes, I think so. I am not sure what the others think, but in my opinion it is for lawyers and maybe those who live and breathe European bureaucracy. It is certainly not for the faint-hearted.
The Chair: You are surely not suggesting that lawyers live and breathe European bureaucracy, are you? Do not answer that question. Are there any other comments from Claire Sullivan or Jonathan Walsh about EU EUR-Lex? No.
Lord Thomas of Gresford: To what extent, Claire, do you think the EU should be bound by advice given by a one-stop shop that is UK Government-supported? Can you think of a design that would permit that to happen?
The Chair: I think there is an easy answer to that question. I think both witnesses want to come in.
Claire Sullivan: I can honestly say that I have never used the EUR-Lex tool. In fact, it was only in advance of this appearance that I actually went online yesterday to have a look at it, and I agree with Neil: I think you need to have specialist knowledge to use it. That is part of the conversation that we have been pushing for: we need to look at how we can make this information accessible for businesses. It is difficult for businesses to have the bandwidth and the expertise to look at what is coming from the EU and how it could potentially impact them. Any ways in which we can look at how the UK Government can work with their counterparts in the EU to provide advice or guidance on what is coming would be most welcome. Again, it is going to be an ongoing process, and we need to see how we can do it in a way that suits all needs.
Jonathan Walsh: I have used EUR-Lex and other EU law databases. They are excellent legal resources, but they are not practical for SMEs. Businesses need operational guidance; they do not need primary legislation. They do not need to try to pull through all these elements. I have to say I have found the GOV.UK website very good in the resources that it has, and it has been fine-tuned as it has gone along. I have seen that with the UKIMS guidance and its application process. They have taken on board comments and where something has been described as overkill or confusing, they have refined it.
I refer to Lord Dodds’s comment about the company in Craigavon with 100 outstanding supplementary declarations. The Trader Support Service was set up to provide a free-at-source service to allow companies to clear goods movements from GB to NI themselves, rather than having to use customs agencies, freight forwarders or whatever to do it. I am neither a freight forwarder nor a customs agent; I am a consultant who advises companies around trade. I want to mitigate risks for companies while maximising the opportunities that I genuinely believe our dual market access provides. For those companies, we have the new UKIMS internal market movement information records, if their goods are “not at risk”. But, as Lord Dodds rightly said, they need to be able to get information, such as commodity codes and countries of origin.
You talked about who is held liable. I put up a post yesterday. This is not about bashing; it is about the realities for companies. There are three separate issues. I am working with a very large and successful all-island trading company that is doing a lot of work in Great Britain. The people there were talking to me about the construction exemption, which allows them to bring in materials from Great Britain that will form a permanent structure within Northern Ireland—not within the United Kingdom but within Northern Ireland; that is the legal text—and declare them as “not at risk” under the UK Internal Market Scheme. They sought advice from somebody in the Trader Support Service and were advised that the goods are not at risk if they are moving into Northern Ireland and will be used in projects within the United Kingdom. That is wrong. The advice was wrong and it caused a compliance issue. It was written advice; I have it and I have highlighted that.
We also had a grouping issue with another all-island, EU and UK trader—that tends to be the type of company that works with me; they work across borders and jurisdictions. It had used supplementary declaration assistance—which, hopefully, would be open to that company in Craigavon, Lord Dodds—and it listed all its products separately. It had the commodity codes and the country of origin; it had all that information. I carried out a compliance audit. Somebody had got the company to group the products together and declare them all as “at risk” under its waiver, despite the fact that they come from multiple countries of origin. They cannot be grouped together, because country of origin can determine risk in any case, and there are anti-dumping duties and other safeguarding tariffs.
Those are two examples. Who is responsible for this? I will tell you something that amazes me. In its terms and conditions, the Trader Support Service states that its liability is £100—so the risk is to the company, which takes this advice in good faith. The company has a compliance review and finds that it is non-compliant. I know that HMRC and the UK Government have said no penalties will be applied, but there are indirect penalties. If the company has declared goods as “not at risk” and they were at risk, duty is then calculated. Because the CDS does not recognise or cannot see or understand movements from more than 12 months previously, or it cannot put them into the system, it puts the date of movement as the date when the reconciliation or change was made. So, in the case of that very large company, if it is using its waiver allowance and is suddenly told, “You declared £100,000-worth of duty as not at risk. It is at risk, but it’s okay, you can use your waiver”, that comes out of the company’s account that day.
The Chair: Mr Walsh, I am going to pause you because you have made your point very powerfully, and I know that Baroness Ritchie has a follow-up question about the Trader Support Service, which is highly relevant to what we have been discussing.
Q24 Baroness Ritchie of Downpatrick: Thank you; it absolutely is. In view of the fact that there is now a new operator for the Trader Support Service, how should the service be improved? We know that, in earlier days, there were a lot of problems and challenges for those involved in business.
Claire Sullivan: Obviously, in my role I have not had any direct experience of the Trader Support Service, but member feedback is mixed. Some members find it useful; others have issues with it. On the new contract, we have seen the operators reach out; they are willing to engage and speak to people about what they are doing and to look at how to resolve issues. Interestingly, a member at an event last week, who had raised an issue with the Trader Support Service, was not aware that the contract had changed. It was a large Northern Irish company that operates not just across Northern Ireland but elsewhere on these islands. It goes back to my point that sometimes there is an assumption that businesses know what is going on in the wider environment, but they do not always know. The company was having issues with the service, but it found it useful to talk to one of our other members, in peer-to-peer learning. They talked to each other about their experience and issues, and were going to follow up on that.
Some members have in-house expertise that they use. Again, that tends to be the larger companies. Some of them are using external resources such as accountancy companies and companies like Jonathan’s. There are mixed experiences. Going forward, we need to look at building on the positives and where changes have been made, and not assume that everything is perfect. We need to keep constantly monitoring, reviewing and making improvements where required.
Neil Johnston: I concur with Claire and defer to Jonathan. My members—the bigger ones—are doing an awful lot of this in-house. The only point I will make is that, if small companies in Craigavon have an issue, imagine the scale of what my members are having to do in terms of declarations, when you consider the variety of products in the back of your average 40-foot truck coming to Northern Ireland. They are hugely diverse, so there is a massive amount of work to be done, and there is huge expense, running into millions, involved in doing this and trying to keep it right on an ongoing basis. As Claire said, some of our members have good experiences with the TSS while others have very little experience of it because they are doing it all in-house. Perhaps Jonathan is the one with the greater experience in this area.
The Chair: Mr Walsh, you have given the TSS a good right hook and identified some problems. Perhaps you could suggest some solutions.
Jonathan Walsh: It is not my aim to give it a good right hook, as such, to be honest. I have worked very closely in the past with some exceptional people in the Trader Support Service, but I will not gloss over it either. I cannot paint a picture that is not a fair reflection of what my clients are experiencing.
In defence of the Trader Support Service, at least there is an ability to have some ownership. We can compare that with what happened with fast parcel operators, which are completing import declarations on behalf of traders using EIDR. Dealing with multiples, they are all approaching things completely differently, and they are not providing the proper feedback.
In terms of the new set-up, I have no direct relationship with the new consortium. As far as I can see, apart from one notable exception, the vast majority of the new consortium were involved in the old consortium as well. I believe that there is an attempt at more engagement, and that they are attempting to work with companies and highlight declarations that are late; they are putting more emphasis on getting those closed off. But the reality is that, as in the very good example that Lord Dodds gave, if you do not have the information then you cannot close the declaration. I can make it up, but it will be wrong. If you do not have commodity codes or countries of origin then you do not have that.
My recommendation to them is to listen to people who are actually involved in this, talk to them and get out there and engage with them. As I have said before, consultations need to work for businesses. They need to find that it will mitigate risks going forward for them and that it will make things simpler. So many people have come to me and told me, “There are systems that can do this for you and they can make it easier”. AI, machine learning and all these technologies are fantastic, but the reality is: rubbish in, rubbish out. You need to have the correct information and it needs to be provided. Yes, there is the ability then to duplicate it and copy it over as we go along thereafter, but it is putting unbelievable pressure on small businesses. I complete declarations for a small number of companies. I do not want to because it is a very clunky system, and it can take you hours to close a declaration because you have to go line by line by line and put all that information in. Engage, listen and get feedback from people who actually know these systems.
Baroness Ritchie of Downpatrick: A short question to Jonathan: have you met the new operator and consortium that is dealing with the Trader Support Service?
Jonathan Walsh: I spoke to them at the very outset but have had no engagement with them since. I have been asked by HMRC and the Institute of Export and International Trade if I wanted to participate in consultations, but I am not going to participate in consultations where other consultants are getting paid for it and I am not. That is the reality of it.
Baroness Ritchie of Downpatrick: That is honest.
Q25 Lord Dodds of Duncairn: On the issue of the new UK-EU reset, especially the SPS agreement and so on, I want to ask the witnesses where differences might happen as a result of such an agreement that are positive. Neil mentioned at the start that it does not cover everything, so where will it help and where will it not? Just so we are clear.
As a supplementary to the question that I referred to earlier, when you were talking about your engagements in Brussels you mentioned meeting the Northern Ireland Executive Office. I would like to follow up on that. How did you find it? What was its engagement like, and how useful do you think that office is? But that is a supplementary to this main question.
Neil Johnston: To come back to the main point, hopefully the reset will improve things because, if we get an SPS agreement, that will be beneficial for Northern Ireland as a whole. It will be particularly beneficial for my members in terms of “not for EU” labelling, since many products would fall by the wayside. I cannot emphasise enough that there continue to be significant issues with that issue, particularly with branded suppliers that are refusing to play ball, so if we want to get those products into Northern Ireland then members will just have to bring those through the red lane, and all this just adds cost.
I know it is a commonly accepted belief that national retailers have very broad shoulders, but at the end of the day both those retailers and their logistics suppliers may have large turnovers but they actually operate on very small margins of 2% or 3%. In both the retail and logistics sectors, they carry all the weight of the Windsor Framework and the government measures that Claire mentioned earlier, such as employment law and wages. That is a big burden on us. So we are hopeful that as soon as possible we may see some of that stuff disappear, and we always believed that it was disproportionate to the risk, but then the devil is in the detail about things like wine and fish. It might be that we resolve some issues but create others and are still left with a considerable burden in bureaucracy and cost in getting products into Northern Ireland.
The Chair: We have had good co-operation from Nick Thomas-Symonds, the Minister largely responsible for the UK-EU reset. You represent different groups of traders in Northern Ireland. Do you feel that the Northern Ireland business community has had sufficient input into the UK-EU reset issues, given the speciality of Northern Ireland’s position in relation to the European Union?
Neil Johnston: It is difficult to say. We have engaged with them in Northern Ireland, and hopefully that will continue. The truth is that we are always at one step removed. Other colleagues of mine in the BRC are engaged as well on a UK level, but in Northern Ireland we always feel a wee bit one step removed. I reiterate that I think there is an improvement. Obviously there is an improvement in political relations, and that is reflected at the official level as well. If we can move forward on an SPS agreement, that cannot come quickly enough.
The Chair: Ms Sullivan, what is your view—
Neil Johnston: Sorry, can I just address the point about branded products? The Government seem to feel that if a product is available on the market then the internal market is fine, but what it might mean is that a branded vegetarian product is not available in some stores, so it is not available in X store in Strabane, but you can go down the road and get it in Omagh. That is not a properly operating internal market. We need a better solution for these branded products. One solution is to bring them in through the red lane, but again that just adds costs. The SPS agreement could resolve some of that, but there are issues about fishing and wine and then the broader stuff about the EUDR, which does not come under this at all.
The Chair: Ms Sullivan, what is CBI Northern Ireland’s view of the UK-EU reset?
Claire Sullivan: We are feeling positive about it, and we are hoping that we will see action and movement in the next year. Obviously our Northern Ireland members are really keen to see the SPS agreement being implemented and to see how it can help to resolve some of the issues that have been well laid out today and on other occasions.
The CBI is a UK-wide organisation and cross-sectoral, so we recognise that there are going to be different views, but we can say that businesses as a whole are saying that they need to see tangible benefits in outcome that reduce friction, prioritise delivery mechanism and deliver measurable milestones that will help business confidence. That is our line; right across all sectors, and right across the UK, that is what we need to see.
Like Neil, we were in Brussels last week. We were there in the same week last year, and I definitely feel that there is a warming. It was more positive in terms of some of the discussions, and you can see that there have been some positive moves. You can definitely feel some trust developing, and we need to look at how we build on that and bring it forward. The ongoing negotiations are specifically around some areas, and SPS is one of them.
We need to look at the wider issues as well; I know that at your previous session the issue of customs was raised, and that is something that certain sectors are pushing for. We need to look at how we maximise all those opportunities right across the sectors. The way that I put it is that we want to minimise the barriers and maximise the opportunities, and we need to be pragmatic and look at how we do that. Things are definitely moving in a positive direction, and we need to build on that and see how we can maximise it.
The Chair: Mr Walsh, you sit in a rather different position as an independent consultant and expert. Are you feeling positive vibrations from the UK-EU reset for your cohort of clients?
Jonathan Walsh: I think it is fair to say that the approach has changed. I have stayed away from the area of SPS—sanitary and phytosanitary—goods, to be honest. I have concentrated a lot in the engineering and manufacturing area rather than on SPS goods, but I am aware that the previous Government were coming up with solutions to help the flow of SPS goods, including agri-food goods, within the internal UK market. The current UK Government have publicly stated their intention to pursue a comprehensive sanitary and phytosanitary agreement.
When the “not for EU” labelling came in, Prime Minister Sunak said that it would be brought in across the whole of the United Kingdom, because there was a recognition that having those labelling requirements only in Northern Ireland would lead to the issues that Neil and others have highlighted and flagged to you. When the current Government came in, they removed that mandatory requirement, and we knew what the knock-on was going to be: we knew that it would mean products becoming delisted.
By the way, the “not for EU” labelling gives a view that is not correct. It simply means that the products have not gone through the requirements to go into the EU, or that they are prohibited restricted goods such as chilled meat. But, as we know, today in Enniskillen, Newry, Strabane or any one of those border towns and cities, the car parks in the shopping centres will be full of cross-border shoppers going in, doing their shopping and bringing the goods back over the border.
Am I encouraged by it? You asked previously whether we are optimistic. Yes, I am optimistic that there is engagement. You cannot solve problems in a vacuum. You have to talk to people; you have to listen to views and opinions and find solutions that work pragmatically. An SPS agreement will benefit not only GB-NI but the UK and the EU as a whole.
The Chair: Baroness O’Loan, you have quite a broad question, which is relevant.
Q26 Baroness O'Loan: From a business engagement perspective, do you consider there to be any lessons the UK can learn from the experience of Northern Ireland and the Windsor Framework for dynamic alignment with Great Britain?
Neil Johnston: Speaking from the retailers’ perspective, we are seeking to put a broad range and choice of products of value on shelves across the United Kingdom. The Government need to be alive to the fact that anything that misaligns that adds costs, pure and simple. It is a highly competitive business, which means that costs are kept down, but it is hugely detrimental. As I said before, it is a low-margin industry and anything that adds to increased costs is detrimental.
The UK Government need to think long and hard about that UK internal market and how to protect it, and to get the EU to balance its approach more—that is their day job. Part of the problem is that, if you employ officials in the European Union to protect the single market, they will protect the single market. If you ask them to have consideration for the UK internal market, they will nod sympathetically; perhaps it is just not in the KPIs for their jobs.
The UK Government need to impress upon the EU that this is a two-way street—a compromise—as I said earlier. The EU is not spending a fortune manning border posts between the Republic and Northern Ireland; my members are spending a fortune instead, so a wee bit of understanding from the EU would not go amiss. The UK perhaps needs to be more forthright in saying, “We have a UK internal market here. We understand the risks of the single market, and we are dealing with them and complying as best we can”. The risk to the EU single market is low, and we must recognise that. We need to make sure that consumers can get easy access to all the products available in GB.
Jonathan Walsh: I think it is fair to say that Northern Ireland has been used as a test bed by the UK Government for a number of systems, such as the CDS—when CHIEF was being replaced and the new customs declaration service was coming in.
On engagement, alongside my work with businesses, I am currently working on a piece commissioned by the Department for the Economy and Invest Northern Ireland that examines practical trade facilitation measures under the Windsor Framework. The department wanted to do something a bit different from what has gone before. We wanted to look at finding areas where improvements could be made to reduce friction for traders and to provide options and resolutions. We engaged with a number of key stakeholders—I wish we had had the ability to engage with more—across both GB and NI. The CBI was one of the organisations that we engaged with in that process. We have the draft report at this point. What I find encouraging is that there is no long list of separated asks but there is a long list of different key requirements. There is a very consolidated list of things, such as the SPS agreement and what it would do, a database around divergence and rules that apply in Northern Ireland, the requirements around the one-stop shop, the knowledge up stream in GB and so forth.
We need to ensure that the narrative coming out is accurate. It is unfortunate when we see oversight. The figure that comes to mind is that 96% of all goods going from GB to NI are not “at risk”. That is not correct. I know that because I was involved in the consultation process, and what was said was that 96% of all goods moving from GB to NI do not have tariffs applied to them. That is because about 20% of all goods going into the EU per commodity code do not have any tariffs anyway—they are 0%—or they are moving on to the UK so they are moving on to waivers or on to UK preferential origin, or whatever.
There is an island economy, as well as the internal UK economy. We have been encouraged for many years to get involved in both, so we need to look at the realities of trade. Yes, I think that the UK Government can do more, but I also agree that the EU can do a lot more to talk about Northern Ireland and our dual market access. If we are having the pain, we need to have the advantage as well.
The Chair: We have run out of time, but would you like to add a brief word, Claire?
Claire Sullivan: I will finish by saying again that it is about learning the lessons that have happened in Northern Ireland over the last few years. Our members would say that the principle of dynamic alignment is that it needs to remove barriers and strengthen competitiveness, and there needs to be clear economic benefit. It is about the UK also working with the EU to find where there is mutual benefit. We are all facing the same issues in this current geopolitical world, so how can we get mutual benefit for us all that includes increased competitiveness and economic growth?
The Chair: That is a very positive question on which to end; it is very suitable as a coda to our meeting. Thank you all very much for your very valuable contributions to our meeting. I shall now draw the public session to a close. I remind you, our three witnesses, that you will be supplied with a transcript, which will reach you soon for correction. Thank you very much for your evidence; I know I speak on behalf of the whole committee.
