Britain has a “huge misunderstanding” about how it will be able to trade with the EU after it leaves the bloc, a leading Brexit expert in the European Parliament said.
Danuta Hübner, a member of Parliament’s Brexit Steering Group, said British leaders thought they could leave the EU’s customs union but enjoy an arrangement with Brussels that would produce similar benefits. But, Hübner said in an interview with POLITICO, British politicians did not seem to grasp what a customs union is or how it operates.
“There is a huge misunderstanding,” said Hübner, who is an important voice in the Brexit debate as the European Parliament must approve the final withdrawal deal between the U.K. and the EU. “All the comments that we hear from politicians in the U.K. clearly show that there is no understanding between what it means to be in the customs union … or have a ‘sort of’ customs union, or customs partnership like Turkey.”
The U.K. has said that it wants to leave the EU’s customs union so that it can strike its own trade deals with other countries. But it has also stated that it wants to establish a new “highly streamlined customs arrangement,” which would continue some customs arrangements, or a “customs partnership” that “removes the need for a UK-EU customs border.”
Hübner, a Polish member of the conservative European People’s Party group, said Britain would run into considerable difficulties if it was anything less than a full member of the customs union, applying all its common external tariffs.
“The problem with the U.K. is that they’re so clear on what they don’t want and then not clear on what they really want,” she said on the sidelines of Parliament’s plenary session in Strasbourg last week.
While Turkey is in a customs union with the EU that covers all industrial goods, the arrangement does not cover coal, steel, agricultural goods or services. This means Ankara does not apply the same common external tariffs as the EU. Hübner said such an arrangement demands checks to ensure items comply with the EU customs union’s rules of origin.
“If you don’t have these common external tariffs, then the question of the rules of origin applies because you can’t have just any product entering from outside,” she said.
Any customs arrangement between the EU and the U.K. would have to be “very broad” to be recognized by the World Trade Organization, Hübner added.
Hübner said that the U.K also has to understand that trade relations “are not just about customs” as many obstacles to trade, such as food safety rules, are covered by the EU’s single market.
Hübner said the Brexit talks also have a long way to go on Ireland and that there are differences even in the areas in which there has been significant progress, such as the rights of U.K. and EU citizens after Brexit.
Last week, the EU’s chief Brexit negotiator, Michel Barnier, said the EU would ensure that the protections of citizens’ rights would be extended until December 31, 2020 — the proposed end of post-Brexit transition period.
The U.K. has pushed back on that demand, insisting that the guarantees should apply only until the official withdrawal date, at the end of March, 2019.
Hübner said EU citizens who moved to the U.K. during the transition period should have the right to be part of the deal covering citizens’ rights.
“We still have difference on the cutoff date for citizens,” Hübner said. “For us, this cutoff date is the end of transition.”