Introduction

This Brexit Readiness Action Plan supports and promotes the necessary preparations for the substantial and enduring changes that will arise at the end of the transition period in less than four months’ time, on 31 December 2020. In many respects it draws on the Government’s Brexit Contingency Plans of December 2018 and July 2019.

The United Kingdom left the European Union on 1 February 2020 after both sides had concluded a Withdrawal Agreement which facilitates an orderly departure. The Withdrawal Agreement also includes the Protocol on Ireland and Northern Ireland which protects the peace process and avoids a hard border on the island of Ireland, while preserving the integrity of the EU Customs Union and Single Market and Ireland’s place therein. Regardless of the outcome of the future relationship negotiations, the provisions of the Withdrawal Agreement and the Protocol will be implemented. The Common Travel Area between Ireland and the UK will also continue to operate as it does today. Citizens of either country will continue to be able to live, work, study and to access associated entitlements and services in the other.

The Withdrawal Agreement also provides for a transition period. The transition period is intended to give time for national administrations, businesses and citizens to prepare for the changes that will definitively arise on 1 January 2021. From this point, the UK will be outside the EU’s Single Market and Customs Union, and will no longer be bound by EU law. This will significantly change the way the EU and the UK engage into the future.

The EU and the UK are currently negotiating a future partnership agreement. The EU’s approach to the negotiations is underpinned by the Political Declaration signed by the EU and UK in October, 2019. The Declaration set out the parameters for an ‘ambitious, broad, deep and flexible partnership across trade and economic cooperation with a comprehensive and balanced Free Trade Agreement (FTA) at its core’. One of the key issues addressed in the Political Declaration is the need for a strong level playing field, to ensure fair and open competition and to prevent businesses gaining an uncompetitive advantage by diminishing important protections of workers and the environment – an important element of any deal given the geographic closeness and interconnected nature of the EU and UK economies.

To date, the EU and UK have completed seven formal rounds of negotiations and progress has been disappointing. Given the limited progress we have seen to date, the Government decided on 29 May 2020 to intensify its readiness work on the basis of two scenarios: (i) a limited FTA (including fisheries), or, (ii) a hard Brexit with the EU and UK trading on WTO terms. While Ireland still supports the closest possible relationship between the EU and UK, prudence dictates that we approach our readiness planning on this basis. With less than four months until the end of transition, it is vital that government, business and citizens understand the changes that will arise and take steps now to mitigate the risks. Both scenarios will raise many, although not all, of the risks which arose in the No Deal planning undertaken last year, ahead of the Withdrawal Agreement being concluded.

In the first scenario, the EU and UK would agree a limited FTA with acceptable level playing field elements, providing for zero tariffs and zero quotas. This outcome will bring substantial challenges for supply chains and trade flows and will require checks and controls in both directions on EU-UK trade. In practice, this will mean that every time an Irish company or individual imports from, or exports to, Great Britain they will need to (at least) complete a customs declaration. A limited FTA would not address the full range of the EU’s relations with the UK.

If the EU and UK fail to reach an agreement, we will be faced with a hard Brexit and an immediate and disorderly change in the way the EU and UK trade and engage. In this scenario on 1 January 2021, the EU and UK will trade on WTO rules. In addition to the implications outlined above, this outcome will also see the introduction of tariffs and quotas on trade in both directions, with significant impacts on Irish trade, notably in the agri-food sector.

Either scenario will be highly disruptive and will have profound political, economic and legal implications, first and foremost for the UK, as well as having significant impacts on Ireland and the rest of the EU.

The EU and UK negotiations are continuing and our planning, together with EU partners, in respect of a number of key areas such as tariffs, fisheries, connectivity and transport and data sharing will evolve as the outcome of the negotiations becomes clearer. However, it is already very clear that a range of changes will definitively take place regardless of the outcome of the negotiations and it is vital that we step up our preparations to address these changes now. These changes will be significant and lasting. Of these, the most significant is that, from 1 January 2021, the UK will no longer apply the rules of the Single Market and Customs Union. This means that any business, regardless of size, who moves goods from, to or through Great Britain will be subject to a range of new customs formalities and other regulatory requirements.

The Government acknowledges that the end of the transition period approaches at a time when businesses and citizens are already under considerable strain because of the COVID- 19 crisis. This is not the context in which we would have chosen to implement such a major change to the relationship between the EU and the UK. However, as the UK Government has made clear that the transition period will not be extended, we all must turn our efforts to strengthening our readiness preparations based on the two scenarios outlined above.

The Government will take this work forward in three distinct but overlapping streams:

  • Work which the Government can lead directly such as infrastructure at the ports and airports; introducing new legislation; and engaging with the European Commission;
  • Communicating with and supporting sectors and businesses most directly impacted; and
  • Helping to prepare for wider societal and citizen-focused

Preparations of Government, business and citizens were well advanced for the possibility of a no deal Brexit on 29 March 2019 (may also apply to new exit date on 31 December 2020), 31 October 2019 (may also apply to new exit date on 31 December 2020) and 31 January 2020. The additional time afforded by the transition period provides space to refine this work and recalibrate as necessary for the end of the transition period. However, our readiness work for the end of the transition is also different from earlier no deal preparations as it will require planning for both immediate challenges, but also long term, permanent changes, to current arrangements. It can also be expected that EU contingencies will be limited.

It needs to be acknowledged that, notwithstanding the extensive readiness preparations that have been made by Government, businesses and citizens, significant risks can still be expected to arise when the transition period ends. These risks include:

The scale and interconnectedness of the EU-UK relationship mean we cannot entirely eliminate the possibility of disruption. Even with all the work that has been done, there will be severe disruption. However, Government, businesses and citizens working together to address the changes we know are coming will allow us to reduce the burden and impact that arises as a result of the UK’s decision to leave the EU.

Time is short and it is not feasible to await the outcome of the negotiations before acting. It is clear that, no matter what, the status quo will not be maintained. With less than four months to the end of the transition period, this Readiness Action Plan outlines concrete actions that the Government, business and citizens can take to address the changes and mitigate the risks that will arise regardless of the outcome of the ongoing negotiations. It is important that we take these actions now.

The Government will continue to develop and refine our readiness efforts. As before, this work will be underpinned by a strong communications and outreach programme aimed at addressing specific sectors and challenges. We recognise that preparing for these changes is extremely challenging for many businesses already severely affected by the COVID-19 pandemic, and will try to support them as much as possible over the coming months. We remain grateful for our ongoing engagement with stakeholders and representative bodies and will continue to work closely with our partners in addressing our shared objectives. We will face the challenge of the end of the transition period as an EU Member State, with the support, solidarity and strength this brings.

September 2020

Readiness Measures at Governmental Level

Working with a broad range of stakeholders to address the needs of sectors and business impacted by the UK’s departure, as well an array of societal and citizen-focused issues, is central to the Government’s approach to Brexit readiness. In addition, as set out in this Chapter, the Government also drives a number of overarching projects and engagements which support our overall Brexit priorities.

1.1.   Economic and Budgetary Measures

While Ireland has one of the most open economies internationally, the UK remains a key partner and is the destination for almost 14% of our goods and services exports (2018) and the source of 13.5% of our imports (2018). Overall trade with the UK was valued at about €82.1 billion in 2018. It is a vital market for our SMEs. Changes in the East-West trade relationship due to Brexit will increase costs and affect productivity and competitiveness. A range of studies in recent years all point to substantial impacts for the Irish economy.

Brexit comes at a time when the economy is already hugely challenged as a result of COVID-

Elements of Brexit readiness work, such as business and employment supports, are already being applied in response to the COVID-19 pandemic. The policy response to the spread of the COVID-19 virus both domestically and internationally, while necessary from a public health perspective, has resulted in a sharp contraction in global and domestic economic activity. The size and speed of the impact is unprecedented in modern times.

A range of studies point to the negative impact Brexit, in any form, will have on economic growth in Ireland. The Department of Finance has projected over the medium-term the level of GDP would be around 2 – 3¼ percentage points lower relative to a hypothetical status quo scenario, with most of the impact in the first year or so. Underneath these figures are significant regional and sectoral variations with agri-food, fisheries, manufacturing and retail, the most exposed sectors. These projections pre-date the COVID-19 impact, but it is clear that we are facing into the end of the transition period from a fundamentally different economic starting point than for a no deal Brexit in 2019.

Government has been planning for Brexit since before the UK referendum to ensure that Irish citizens and businesses are as ready as possible for all scenarios. Significant dedicated measures and supports were announced in Budgets 2017, 2018, 2019, and 2020. Supports up to and including Budget 2019 amounted to over €800 million, and Budget 2020 provided for more than €1 billion to be spent in the event of Brexit occurring without a Withdrawal Agreement.

Further targeted measures to support businesses and affected sectors prepare and adapt will be considered in the context of Budget 2021. In order to inform these considerations, the Department of Finance and the ESRI have examined the interrelationship between COVID- 19 and Brexit on short-term economic prospects. Overall, this work suggests that if you add the Brexit shock to that of COVID-19 the number of sectors exposed to risk increases but the impacts are not magnified by the interaction of the two economic shocks. Nevertheless, we expect the capacity of businesses and households to manage a second economic shock will be more limited. This research will inform the Government’s macroeconomic forecasts as part of Budget 2021 and will be published shortly.

Many of the Government’s existing Brexit supports have been applied to respond to COVID

These, along with the wider COVID-19 economic response measures, can assist businesses to improve their resilience ahead of the end of the transition period.

However, there will also be additional challenges, including new customs and SPS requirements and trading arrangements, which are unique to Brexit. In light of this, the Government’s July Jobs Stimulus included a €20 million Brexit package to help businesses and affected sectors to prepare for the changes that are ahead. Further detail on business supports can be found in Section 1.3.

A number of EU supports will also be available. The European Council recently approved a

€5 billion Brexit Adjustment Reserve, to support countries and sectors worst-hit by the impacts of Brexit. The Government is engaging with the Commission as it develops and rolls out this fund, to ensure that Irish businesses and sectors benefit to the maximum extent possible, in the context of the disproportionate impact Brexit will have on Ireland.

1.2.   Communications and Stakeholder Engagement

A key element of our readiness work will include a major public information campaign to businesses and citizens and will be underpinned by outreach to key stakeholders. In the coming months, all Ministers and Departments will further step-up their levels of engagement with stakeholders across the island of Ireland. The Minister for Foreign Affairs will continue to chair the Brexit Stakeholders Forum.

Our communications strategy for the next phase of Getting Ireland Brexit Ready will directly address the needs of citizens and businesses. It will continue to be audience led and strongly focussed on “Calls to Action”. It will encourage engagement and action on the part of business and citizens to prepare for the enduring changes arising in 2021 by highlighting that the status quo is not an option and now is the time to prepare for the end of the transition period.

Central to this will be our trader engagement programmes to support business readiness for the new trading environment at the end of the transition period. Our Getting Your Business Brexit Ready campaign will target small businesses, including shops, hauliers, farmers, fishers and others who trade with the UK, who are most exposed. The campaign will comprise of events, stakeholder briefings, and national and local radio and press campaigns to build further awareness among businesses and sectoral audiences of the challenges and changes that will arise when the transition period ends, highlight the steps the Government is taking to address these challenges and encourage them to take necessary actions and to take up all relevant offers of support. We will also refresh and re-run public information campaigns, targeting communications based on the circumstances of the citizen – shopper, traveller, patient, driver, employee and student.

Unlike earlier campaigns, this campaign cannot, due to COVID-19 restrictions, plan for aligning with large gatherings or trade shows such as the Ploughing Championships. We will increase our use of virtual communications platforms such as webinars and online instructional videos. Subject to public health guidelines we will also look at the possibility of hybrid events consisting, for example, of a panel and small socially distant audience that is also webcast. We will also take opportunities at ministerial and official level to engage with appropriate partners such as business, farming, and fisheries organisations to amplify our message across their platforms.

Official websites and social media accounts will remain important. www.gov.ie/Brexit remains a trusted signposting website for businesses and citizens. The content of the site and its links continue to be reviewed and refreshed to help the interested citizen and business gain easy access to practical information and advice on a wide range of issues, and on the many Government supports that are available to them.

3.   Business Supports

Government Departments, enterprise agencies and regulatory bodies have made available a range of business supports, including financial, upskilling, and advisory supports to prepare for Brexit.

The Department of Business, Enterprise and Innovation Getting Business Brexit Ready site is a useful guide for business and provides detailed information on supports available in the many areas in which business may be impacted by Brexit. The Government’s current set of Brexit supports includes planning vouchers, consultancy and mentoring supports, tariff advisory services, research on new markets, and innovation supports, provided through Enterprise Ireland, the Local Enterprise Offices and InterTradeIreland.

Supports and advice are also available from the National Standards Authority of Ireland, the Health and Safety Authority, Revenue, Skillnet Ireland, the Strategic Banking Corporation of Ireland, Údarás na Gaeltachta, Bord Iascaigh Mhara, Bord Bia and Fáilte Ireland.

The Government’s July Jobs Stimulus provided more than €7 billion worth of stimulus and support measures to help businesses and people impacted by the COVID-19 crisis through the period ahead. It also included a €20m Brexit package to help businesses involved in exporting and importing with the UK to put in place the necessary internal arrangements, staffing, software, and IT systems to be ready for the new customs arrangements and regulatory requirements that will apply from 1 January 2021. As part of this package, Enterprise Ireland will shortly launch a new “Ready for Customs” grant through which businesses can claim grants of up to €9,000 per eligible employee hired, or redeployed within the business, to a dedicated customs role. A second phase of Skillnet Ireland’s free customs training, Clear Customs Online 2020, is open for applications from September, to support the customs intermediary sector and businesses that trade frequently with, or through, the UK.

The Local Enterprise Offices will be carrying out the second phase of their one-to-one Brexit mentoring and training ‘Prepare Your Business for Customs’ workshops. These will commence in September and will be supported by a full awareness campaign to target all relevant small Irish businesses. This follows on from the successful phase one rollout which took place in 2019 and saw 1500 businesses partake and understand the steps required to trade with the UK post-Brexit

Further measures to support businesses and affected sectors to prepare for, and adapt to, Brexit will be considered in the coming months.

The COVID-19 pandemic has significantly changed the economic context in which the end of the transition period is taking place, along with the capacity of Irish business to prepare.

Government supports provided in response to the COVID-19 pandemic, such as the Temporary Wage Subsidy Scheme, the new Employee Wage Subsidy Scheme, along with supports to access finance and working capital, can already assist businesses improve their resilience and prepare ahead of the end of the transition period. Many of these supports will remain in place in 2021 and can continue to be availed of in the period following the end of the transition period.

The July Jobs Stimulus announcement also included a €200 million investment in training and further education, skills development, work placement schemes, recruitment subsidies and job search and assistance measures, which will help those who have lost their jobs find a new one or become self-employed, retrain, or develop new skills.

Additionally, the Government has put in place measures to ensure a speedy response to assist those who may lose their jobs, this includes the development of a Job Loss Response Protocol, by the Department of Employment Affairs and Social Protection, working with the Department of Business Enterprise and Innovation and the Department of Education and Skills. This Protocol ensures that Government will respond quickly and effectively to ensure workers who lose their jobs are supported to access the appropriate welfare entitlements, job search assistance, and upskilling and training opportunities.

 

Current Brexit Support schemes, in place and available to businesses, include:

The Brexit Loan Scheme: providing affordable working capital to eligible businesses with up to 499 employees that are exposed to current or future impacts arising as a result of the UK’s withdrawal from the EU. This scheme is underpinned by a guarantee from the European Investment Fund (EIF).

The Future Growth Loan Scheme (FGLS): providing long-term lending to SMEs, and the agricultural sector, with terms of 7-10 years, to support strategic investment for future sustainability and growth. This scheme is underpinned by a guarantee from the European Investment Fund and has recently been expanded to make up to €800 million available.

Enterprise Ireland provides a range of financial supports aimed at Brexit Readiness including the Act On Initiative, Be Prepared Grant, Strategic Consultancy, Market Discover Fund, and the Agile and Operational Excellence offer.

Local Enterprise Offices (LEOs) can offer support in accessing a number of financial supports for businesses to prepare for Brexit, including TAME Grants, Trading On-line Vouchers and Micro Finance Ireland Loans. LEOs can also provide advice on other supports available through InterTrade Ireland and the Strategic Banking Corporation of Ireland (SBCI).

InterTradeIreland provides a range of Brexit supports and advice through its Brexit Advisory Service. As well as support through voucher funding, the Brexit Advisory Service also offer a tailor-made online learning tool, a tariff checker, glossary of key Brexit terminology, research, networking and information events.

In addition to the range of specific Brexit initiatives that have been introduced, the full range of Enterprise Ireland, Local Enterprise Office (LEO), InterTradeIreland and Údarás na Gaeltachta grant and advisory supports continue to be available to eligible firms to help with building resilience in the face of external challenges. This substantial set of supports includes assistance with strategies to make capital investments, invest in R&D, access finance, commence or ramp-up online trading activity, reconfigure business models, cut costs, innovate, diversify markets and supply chains and to improve competitiveness.

Targeted sectoral supports have also been made available including:

Agriculture and Food Sector

Bord Bia provides a range of capability development services for the food and drinks sector. This includes the Brexit Readiness Radar, a Food & Drink Action Plan, Customs Readiness Programme, Supply Chain Workshops and bespoke Mentoring Programmes. It also provides fresh UK consumer and customer insights and data via the Bord Bia Thinking House. In light of the disruption caused by COVID-19, it has also launched a series of programmes to assist clients to defend and grow UK business via virtual pitches and online customer engagement.

Infrastructure at Ports and Airports

From the end of the transition period, the basis for trade between Ireland and Great Britain will change fundamentally. Regardless of the results of the future partnership negotiations, the UK will leave the EU Customs Union and Single Market and goods imported from, exported to, or transiting through Britain will be subject to new and more intensive customs and regulatory (including SPS) procedures1.  Given the volume of trade between Ireland and Great Britain, implementing these new procedures requires substantial investment in infrastructure, staff and resources, procedures and IT systems.

Since 2018, detailed work has been underway across Government to invest in the infrastructure and systems required for additional checks and controls for trade with the UK, in both directions, at Dublin Port and Rosslare Europort, as well as at Dublin Airport. This is one of the most visible aspects of the Government’s preparations for Brexit. Our approach to this work is driven by the twin objectives of ensuring trade can flow through our ports and airports to the greatest extent possible while maintaining food safety and public health and Ireland’s obligations to the Single Market.

The work on the Border Control Post (BCP) at Dublin Airport is now complete and consists of approximately 2,000 sq. metres with separated inspection areas for animal products, SPS and food safety checks and live animals, together with associated staff accommodation, freezer storage and inspection facilities.

At Dublin Port:

  • two large warehouses have been acquired and refurbished to provide a total of 25 inspection bays for SPS and food safety checks, as well as a Revenue turnout shed, which is in addition to two existing inspection bays elsewhere in the Port;
  • parking for up to 128 heavy goods vehicles (HGVs) has been provided, as well as documentary and identity check facilities, a public office, driver facilities and staff accommodation to cater for approximately 90 staff; and
  • a live-animal Border Control Post (BCP) and pet facility were put in

Work is continuing to further enhance these facilities including the development of:

  • further HGV parking, a documentary office for imports, driver facilities, a facility management office, as well as staff accommodation and parking;

 

1 The Protocol on Ireland and Northern Ireland means that no new checks or controls will apply on trade in goods between Ireland and Northern Ireland from the end of the transition period, and ensures that there will be no hard border on the island of Ireland.

  • an export facility including HGV parking, a documentary office for exports, driver facilities, and staff accommodation and parking;
  • the refurbishment and extension of an existing warehouse to provide additional inspection bays for SPS and food safety checks, as well as Revenue turnout sheds. Staff accommodation and car parking will also be provided;
  • alterations to one of the existing inspection facilities to provide additional temperature- controlled storage facilities for detained goods as well as enhanced inspection rooms; and
  • the extension of the existing live-animal Border Control Post to include additional

At Rosslare a ten-acre site near the port was acquired and developed to provide inspection facilities including:

  • a purpose-built inspection facility including 4 inspection bays for SPS and food safety checks, a Revenue turnout shed, driver facilities, a facility management office, and staff accommodation; and
  • parking for 38 HGVs, a public office, documentary and seal check facilities as well as a live-animal Border Control

A pet facility and an export office were provided in Rosslare Europort itself, as well as offices for an additional 30 customs staff. An additional office was refurbished to provide accommodation for a further 63 staff. An additional structure is being constructed at the live animal inspection facilities to provide additional capacity.

In addition to substantial investment in infrastructure, the Government has also provided additional resources to the agencies to carry out the checks and controls. Provision has been made to date to facilitate the deployment of around 1,000 staff to ensure compliance with import and export customs, sanitary and phytosanitary and food safety regulations and work is ongoing to ensure border inspection posts are staffed sufficiently to meet Brexit challenges.

Ensuring Optimal Goods Trade Traffic Flows

At Dublin and Rosslare Ports, the interagency approach agreed between Revenue, the Department of Agriculture, Food and the Marine, the Department of Health, HSE Environmental Health Service and the Food Safety Authority as part of the contingency planning for a no deal Brexit in January 2020 continues to be refined on the basis of new modelling and additional infrastructure. Revenue staff will continue to manage and resource the control centre that has oversight of available spaces and exam bays and numbers of upcoming checks and inspections. The agencies are also working to finalise resource and system planning, including to take account of the impact COVID-19 has had on operations. The robustness of the proposed inter-agency arrangements will be tested prior to the end of 2020.

Capacity of the Customs IT systems has been significantly increased in order to deal with the expected growth in the number of transactions post-Brexit. Revenue estimates that import and export declarations could increase to as many as 20 million per annum (an extra 18.3 million or a 12-fold increase). A new national import system, Automated Import System (AIS) will replace the current system for imports in November 2020. This change is necessary in order to ensure compliance with the Union Customs Code; to provide the most efficient process possible for trade; and to provide additional functionality that is not possible with the existing system.

The AIS is part of a planned suite of IT changes that have been in preparation by Revenue in relation to the full framework of customs IT systems and that is happening across the EU Member States. Preparations for the introduction of the system have been ongoing throughout much of 2019 and 2020 and Revenue has engaged extensively with software providers and customs agents to ensure these critical sectors are aware of the upcoming changes. The AEP system will continue to be used for exports until 2023.

Revenue will also launch a Customs Roll-On Roll-Off Service to assist in streamlining procedures for ferry traffic at Irish ports (see Chapter 2 for more information).

It is critical that businesses fully understand and familiarise themselves with all new customs and other regulatory (particularly SPS and food safety controls) requirements in order to avoid unnecessary delay. Further information is set out in Chapter 2.

1.4.2.  Traffic Management – Dublin

Brexit-related traffic congestion in Dublin Port has the potential to impact on adjacent roads, the Port Tunnel, and the motorway system. A Traffic Management Group was established to put in place a contingency plan in advance of a possible no deal Brexit in 2019. This Plan is being updated to reflect developments since. The Plan will set out the roles of the various agencies, the associated communications strategy and operational plan outlining the options and actions required to mitigate impacts on the road network. When finalised, details of the Plan will be published and notified to stakeholders.

1.4.3.  Passenger Flows through Irish Ports and Airports

In line with the Common Travel Area, there will not be any change in the way Irish and UK citizens travel between the UK and Ireland respectively. When the UK becomes a third country, it is possible that a Duty Free and VAT Retail Export Scheme may also operate between Ireland and the UK (excluding Northern Ireland). The 2020 Brexit Omnibus Bill includes a number of measures relating to duty free sales and the application of any VAT Retail Export Scheme to UK Residents. Further information on the Bill can be found at Section 1.5.

Businesses should now:
  • Avail of opportunities to engage with the state agencies to understand the changes that will arise at our ports and
  • Follow the advice outlined in Chapter 2 Trade in
  • Businesses moving live animals, plants and products of animal and plant origin (including wood and wood products) between Ireland and the UK, or to other EU Member States via the UK landbridge should as soon as possible do the following:

e.g. wood pallets; information is available on the DAFM website;

  • Ensure that you are aware of the UK certification requirements for products that you export. These are subject to change but details are available from the UK Government at gov.uk; and
  • Talk to your suppliers, logistics agents and customers and ensure that everyone in the supply chain knows their role and

1.5.   Legislation

The Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Act 2019 (Brexit Omnibus Act) was enacted on 17 March 2019 as part of our preparations for a possible no deal Brexit in 2019. Many of the provisions of the 2019 Act were not commenced because the Withdrawal Agreement was ultimately concluded and entered into force.

To underpin the required readiness measures at the end of the transition period further legislation is required. The Government, on 29 May 2020, approved the preparation of a scheme for a new Brexit Omnibus Bill. The General Scheme of the Bill has now been published and can be accessed on the Department of Foreign Affairs’ website. Work is underway across Departments on the detailed drafting of the Bill which will be brought before the Oireachtas later in the Autumn.

The overarching aim of the provisions is to address the wide range of complex issues that could arise post transition and seek to protect citizens and consumers, facilitate the sound functioning of key sectors, and ensure our businesses are not disadvantaged. The Bill will also support aspects of the Common Travel Area and North-South cooperation.

 

Table 1. Parts of the Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Bill 2020
Part Outline
1 Preliminary and General (Minister for Foreign Affairs and Trade)
2 Healthcare Arrangements (Minister for Health)
3 Reimbursement of medical expenses (Minister for Health)
4 Amendments to Companies Act 2014 (Tánaiste and Minister for Business, Enterprise and Innovation)
5 Amendment to Section 10(2) of the Employment Permits Act 2006 (Tánaiste and Minister for Business, Enterprise and Innovation)
6 Arrangements in relation to Fluorinated Greenhouse Gases (Minister for Communications, Climate Action and Environment)
7 Amendment of Student Support Act 2011 (Minister for Further and Higher Education, Research, Innovation and Science)
8 Taxation (Minister for Finance)
9 Financial Services: Settlement Finality (Minister for Finance)
10 Financial Services: Amendment to the European Union (Insurance and Reinsurance) Regulations 2015 and the European Union (Insurance Distribution) Regulations 2018 (Minister for Finance)
11 Amendment of Customs Act 2015 (Minister for Finance)
12 Amendment of Harbours Act 1996 (Minister for Transport, Tourism and Sport)
13 Third Country Bus Services (Minister for Transport, Tourism and Sport)
14 Amendment of Social Welfare Consolidation Act 2005 (Minister for Employment Affairs and Social Protection)
15 Amendment of Protection of Employees (Employers’ Insolvency) Act 1984 (Minister for Employment Affairs and Social Protection)
16 Amendment of Extradition Act 1965 (Minister for Justice and Equality)
17 Amendment of the Immigration Act 2004 (Minister for Justice and Equality)
18 Amendment of the International Protection Act 2015 (Minister for Justice and Equality)
19 Amendment of Childcare Support Act 2018 (Minister for Children and Youth Affairs)

1.6.   EU Brexit Readiness and Contingency Planning

Work at EU level to prepare for Brexit and provide advice to businesses and citizens has been a key factor in complementing readiness work across Government in areas where competence rests at EU level or where there is benefit in coordinating the national responses of individual Member States.

The European Commission has published 7 Communications on Brexit readiness and contingency planning. The most recent such Communication on ‘Getting Ready for Changes’ was published on 9 July. This provides an overview of the main areas of change that will take place at the end of the transition period regardless of the outcome of the ongoing EU-UK negotiations. It provides a useful complement to this Action Plan.

In July, at the Summit on the EU Multi-Annual Financial Framework and the COVID-19 Recovery Instrument, EU leaders agreed to make €5 billion available to a special Brexit Adjustment Reserve to counter the adverse consequences of Brexit on the most affected Member States and sectors. As one of the Member States most impacted by Brexit, Ireland is working with the Commission to ensure Irish businesses and sectors benefit from the Reserve, to the maximum extent possible. The Commission will make a legislative proposal for the new reserve in November 2020.

1.6.1.  EU Readiness Notices

The European Commission is updating its 102 sector-specific Readiness Notices to help stakeholders to prepare for the end of the transition period. The Commission intends these readiness notices as an important source of information for stakeholders and pubic administrations about changes that need to be made before the end of the transition period. They cover a wide range of areas including, for example, air transport, the movement of animals, customs, data protection, waste, fluorinated greenhouse gases, road transport, and VAT on goods and services. In particular, the revised notices provide advice on the impact of the Protocol on Ireland and Northern Ireland. Links to specific Commission notices are provided where relevant throughout this Action Plan.

1.6.2.  EU Contingency Measures

As part of its no deal Brexit planning work, the Commission published a number of Communications on its approach to preparing for the UK’s withdrawal. These Communications detailed the state of play of EU preparations, and a number of EU legislative contingency measures were also adopted. These contingency measures were temporary in nature, and were intended to mitigate the worst impacts of a no deal Brexit. The entry into force of the Withdrawal Agreement ensures that a number of the earlier contingency measures will no longer be necessary while the Commission has made clear that stakeholders should take advantage of the extra time provided by the transition period to ensure they have taken all the necessary steps to prepare. Substantive discussions on possible contingency measures with the European Commission and other Member States will likely not take place until later in 2020. Contingencies for the end of the transition period can be expected to be limited in scope and will not maintain the status quo.

  1. e their resilience ahead of the end of the transition period.

 

However, there will also be additional challenges, including new customs and SPS requirements and trading arrangements, which are unique to Brexit. In light of this, the Government’s July Jobs Stimulus included a €20 million Brexit package to help businesses and affected sectors to prepare for the changes that are ahead. Further detail on business supports can be found in Section 1.3.

 

A number of EU supports will also be available. The European Council recently approved a

€5 billion Brexit Adjustment Reserve, to support countries and sectors worst-hit by the impacts of Brexit. The Government is engaging with the Commission as it develops and rolls out this fund, to ensure that Irish businesses and sectors benefit to the maximum extent possible, in the context of the disproportionate impact Brexit will have on Ireland.

 

 

 

 

1.2.   Communications and Stakeholder Engagement

A key element of our readiness work will include a major public information campaign to businesses and citizens and will be underpinned by outreach to key stakeholders. In the coming months, all Ministers and Departments will further step-up their levels of engagement with stakeholders across the island of Ireland. The Minister for Foreign Affairs will continue to chair the Brexit Stakeholders Forum.

 

Our communications strategy for the next phase of Getting Ireland Brexit Ready will directly address the needs of citizens and businesses. It will continue to be audience led and strongly focussed on “Calls to Action”. It will encourage engagement and action on the part of business and citizens to prepare for the enduring changes arising in 2021 by highlighting that the status quo is not an option and now is the time to prepare for the end of the transition period.

 

Central to this will be our trader engagement programmes to support business readiness for the new trading environment at the end of the transition period. Our Getting Your Business Brexit Ready campaign will target small businesses, including shops, hauliers, farmers, fishers and others who trade with the UK, who are most exposed. The campaign will comprise of events, stakeholder briefings, and national and local radio and press campaigns to build further awareness among businesses and sectoral audiences of the challenges and changes that will arise when the transition period ends, highlight the steps the Government is taking to address these challenges and encourage them to take necessary actions and to take up all relevant offers of support. We will also refresh and re-run public information campaigns, targeting communications based on the circumstances of the citizen – shopper, traveller, patient, driver, employee and student.

 

Unlike earlier campaigns, this campaign cannot, due to COVID-19 restrictions, plan for aligning with large gatherings or trade shows such as the Ploughing Championships. We will increase our use of virtual communications platforms such as webinars and online instructional videos. Subject to public health guidelines we will also look at the possibility of hybrid events consisting, for example, of a panel and small socially distant audience that is also webcast. We will also take opportunities at ministerial and official level to engage with appropriate partners such as business, farming, and fisheries organisations to amplify our message across their platforms.

 

Official websites and social media accounts will remain important. www.gov.ie/Brexit remains a trusted signposting website for businesses and citizens. The content of the site and its links continue to be reviewed and refreshed to help the interested citizen and business gain easy access to practical information and advice on a wide range of issues, and on the many Government supports that are available to them.

 

 

 

 

 

1.3.   Business Supports

Government Departments, enterprise agencies and regulatory bodies have made available a range of business supports, including financial, upskilling, and advisory supports to prepare for Brexit.

 

The Department of Business, Enterprise and Innovation Getting Business Brexit Ready site is a useful guide for business and provides detailed information on supports available in the many areas in which business may be impacted by Brexit. The Government’s current set of Brexit supports includes planning vouchers, consultancy and mentoring supports, tariff advisory services, research on new markets, and innovation supports, provided through Enterprise Ireland, the Local Enterprise Offices and InterTradeIreland.

 

Supports and advice are also available from the National Standards Authority of Ireland, the Health and Safety Authority, Revenue, Skillnet Ireland, the Strategic Banking Corporation of Ireland, Údarás na Gaeltachta, Bord Iascaigh Mhara, Bord Bia and Fáilte Ireland.

 

The Government’s July Jobs Stimulus provided more than €7 billion worth of stimulus and support measures to help businesses and people impacted by the COVID-19 crisis through the period ahead. It also included a €20m Brexit package to help businesses involved in exporting and importing with the UK to put in place the necessary internal arrangements, staffing, software, and IT systems to be ready for the new customs arrangements and regulatory requirements that will apply from 1 January 2021. As part of this package, Enterprise Ireland will shortly launch a new “Ready for Customs” grant through which businesses can claim grants of up to €9,000 per eligible employee hired, or redeployed within the business, to a dedicated customs role. A second phase of Skillnet Ireland’s free customs training, Clear Customs Online 2020, is open for applications from September, to support the customs intermediary sector and businesses that trade frequently with, or through, the UK.

 

The Local Enterprise Offices will be carrying out the second phase of their one-to-one Brexit mentoring and training ‘Prepare Your Business for Customs’ workshops. These will commence in September and will be supported by a full awareness campaign to target all relevant small Irish businesses. This follows on from the successful phase one rollout which took place in 2019 and saw 1500 businesses partake and understand the steps required to trade with the UK post-Brexit

 

Further measures to support businesses and affected sectors to prepare for, and adapt to, Brexit will be considered in the coming months.

 

The COVID-19 pandemic has significantly changed the economic context in which the end of the transition period is taking place, along with the capacity of Irish business to prepare.

 

 

 

Government supports provided in response to the COVID-19 pandemic, such as the Temporary Wage Subsidy Scheme, the new Employee Wage Subsidy Scheme, along with supports to access finance and working capital, can already assist businesses improve their resilience and prepare ahead of the end of the transition period. Many of these supports will remain in place in 2021 and can continue to be availed of in the period following the end of the transition period.

 

The July Jobs Stimulus announcement also included a €200 million investment in training and further education, skills development, work placement schemes, recruitment subsidies and job search and assistance measures, which will help those who have lost their jobs find a new one or become self-employed, retrain, or develop new skills.

 

Additionally, the Government has put in place measures to ensure a speedy response to assist those who may lose their jobs, this includes the development of a Job Loss Response Protocol, by the Department of Employment Affairs and Social Protection, working with the Department of Business Enterprise and Innovation and the Department of Education and Skills. This Protocol ensures that Government will respond quickly and effectively to ensure workers who lose their jobs are supported to access the appropriate welfare entitlements, job search assistance, and upskilling and training opportunities.

 

 

Current Brexit Support schemes, in place and available to businesses, include:

 

 

 

The Brexit Loan Scheme: providing affordable working capital to eligible businesses with up to 499 employees that are exposed to current or future impacts arising as a result of the UK’s withdrawal from the EU. This scheme is underpinned by a guarantee from the European Investment Fund (EIF).

 

The Future Growth Loan Scheme (FGLS): providing long-term lending to SMEs, and the agricultural sector, with terms of 7-10 years, to support strategic investment for future sustainability and growth. This scheme is underpinned by a guarantee from the European Investment Fund and has recently been expanded to make up to €800 million available.

 

Enterprise Ireland provides a range of financial supports aimed at Brexit Readiness including the Act On Initiative, Be Prepared Grant, Strategic Consultancy, Market Discover Fund, and the Agile and Operational Excellence offer.

 

Local Enterprise Offices (LEOs) can offer support in accessing a number of financial supports for businesses to prepare for Brexit, including TAME Grants, Trading On-line Vouchers and Micro Finance Ireland Loans. LEOs can also provide advice on other supports available through InterTrade Ireland and the Strategic Banking Corporation of Ireland (SBCI).

 

InterTradeIreland provides a range of Brexit supports and advice through its Brexit Advisory Service. As well as support through voucher funding, the Brexit Advisory Service also offer a tailor-made online learning tool, a tariff checker, glossary of key Brexit terminology, research, networking and information events.

 

In addition to the range of specific Brexit initiatives that have been introduced, the full range of Enterprise Ireland, Local Enterprise Office (LEO), InterTradeIreland and Údarás na Gaeltachta grant and advisory supports continue to be available to eligible firms to help with building resilience in the face of external challenges. This substantial set of supports includes assistance with strategies to make capital investments, invest in R&D, access finance, commence or ramp-up online trading activity, reconfigure business models, cut costs, innovate, diversify markets and supply chains and to improve competitiveness.

 

Targeted sectoral supports have also been made available including:

 

Agriculture and Food Sector

Bord Bia provides a range of capability development services for the food and drinks sector. This includes the Brexit Readiness Radar, a Food & Drink Action Plan, Customs Readiness Programme, Supply Chain Workshops and bespoke Mentoring Programmes. It also provides fresh UK consumer and customer insights and data via the Bord Bia Thinking House. In light of the disruption caused by COVID-19, it has also launched a series of programmes to assist clients to defend and grow UK business via virtual pitches and online customer engagement.

 

 

 

 

 

1.4.   Infrastructure at Ports and Airports

From the end of the transition period, the basis for trade between Ireland and Great Britain will change fundamentally. Regardless of the results of the future partnership negotiations, the UK will leave the EU Customs Union and Single Market and goods imported from, exported to, or transiting through Britain will be subject to new and more intensive customs and regulatory (including SPS) procedures1.  Given the volume of trade between Ireland and Great Britain, implementing these new procedures requires substantial investment in infrastructure, staff and resources, procedures and IT systems.

 

Since 2018, detailed work has been underway across Government to invest in the infrastructure and systems required for additional checks and controls for trade with the UK, in both directions, at Dublin Port and Rosslare Europort, as well as at Dublin Airport. This is one of the most visible aspects of the Government’s preparations for Brexit. Our approach to this work is driven by the twin objectives of ensuring trade can flow through our ports and airports to the greatest extent possible while maintaining food safety and public health and Ireland’s obligations to the Single Market.

 

The work on the Border Control Post (BCP) at Dublin Airport is now complete and consists of approximately 2,000 sq. metres with separated inspection areas for animal products, SPS and food safety checks and live animals, together with associated staff accommodation, freezer storage and inspection facilities.

 

At Dublin Port:

  • two large warehouses have been acquired and refurbished to provide a total of 25 inspection bays for SPS and food safety checks, as well as a Revenue turnout shed, which is in addition to two existing inspection bays elsewhere in the Port;
  • parking for up to 128 heavy goods vehicles (HGVs) has been provided, as well as documentary and identity check facilities, a public office, driver facilities and staff accommodation to cater for approximately 90 staff; and
  • a live-animal Border Control Post (BCP) and pet facility were put in

 

Work is continuing to further enhance these facilities including the development of:

  • further HGV parking, a documentary office for imports, driver facilities, a facility management office, as well as staff accommodation and parking;

 

1 The Protocol on Ireland and Northern Ireland means that no new checks or controls will apply on trade in goods between Ireland and Northern Ireland from the end of the transition period, and ensures that there will be no hard border on the island of Ireland.

 

 

 

  • an export facility including HGV parking, a documentary office for exports, driver facilities, and staff accommodation and parking;
  • the refurbishment and extension of an existing warehouse to provide additional inspection bays for SPS and food safety checks, as well as Revenue turnout sheds. Staff accommodation and car parking will also be provided;
  • alterations to one of the existing inspection facilities to provide additional temperature- controlled storage facilities for detained goods as well as enhanced inspection rooms; and
  • the extension of the existing live-animal Border Control Post to include additional

 

At Rosslare a ten-acre site near the port was acquired and developed to provide inspection facilities including:

  • a purpose-built inspection facility including 4 inspection bays for SPS and food safety checks, a Revenue turnout shed, driver facilities, a facility management office, and staff accommodation; and
  • parking for 38 HGVs, a public office, documentary and seal check facilities as well as a live-animal Border Control

 

A pet facility and an export office were provided in Rosslare Europort itself, as well as offices for an additional 30 customs staff. An additional office was refurbished to provide accommodation for a further 63 staff. An additional structure is being constructed at the live animal inspection facilities to provide additional capacity.

 

In addition to substantial investment in infrastructure, the Government has also provided additional resources to the agencies to carry out the checks and controls. Provision has been made to date to facilitate the deployment of around 1,000 staff to ensure compliance with import and export customs, sanitary and phytosanitary and food safety regulations and work is ongoing to ensure border inspection posts are staffed sufficiently to meet Brexit challenges.

 

  • Ensuring Optimal Goods Trade Traffic Flows

At Dublin and Rosslare Ports, the interagency approach agreed between Revenue, the Department of Agriculture, Food and the Marine, the Department of Health, HSE Environmental Health Service and the Food Safety Authority as part of the contingency planning for a no deal Brexit in January 2020 continues to be refined on the basis of new modelling and additional infrastructure. Revenue staff will continue to manage and resource the control centre that has oversight of available spaces and exam bays and numbers of upcoming checks and inspections. The agencies are also working to finalise resource and system planning, including to take account of the impact COVID-19 has had on operations. The robustness of the proposed inter-agency arrangements will be tested prior to the end of 2020.

 

Capacity of the Customs IT systems has been significantly increased in order to deal with the expected growth in the number of transactions post-Brexit. Revenue estimates that import and export declarations could increase to as many as 20 million per annum (an extra 18.3 million or a 12-fold increase). A new national import system, Automated Import System (AIS) will replace the current system for imports in November 2020. This change is necessary in order

 

 

 

to ensure compliance with the Union Customs Code; to provide the most efficient process possible for trade; and to provide additional functionality that is not possible with the existing system.

 

The AIS is part of a planned suite of IT changes that have been in preparation by Revenue in relation to the full framework of customs IT systems and that is happening across the EU Member States. Preparations for the introduction of the system have been ongoing throughout much of 2019 and 2020 and Revenue has engaged extensively with software providers and customs agents to ensure these critical sectors are aware of the upcoming changes. The AEP system will continue to be used for exports until 2023.

 

Revenue will also launch a Customs Roll-On Roll-Off Service to assist in streamlining procedures for ferry traffic at Irish ports (see Chapter 2 for more information).

 

It is critical that businesses fully understand and familiarise themselves with all new customs and other regulatory (particularly SPS and food safety controls) requirements in order to avoid unnecessary delay. Further information is set out in Chapter 2.

 

1.4.2.  Traffic Management – Dublin

Brexit-related traffic congestion in Dublin Port has the potential to impact on adjacent roads, the Port Tunnel, and the motorway system. A Traffic Management Group was established to put in place a contingency plan in advance of a possible no deal Brexit in 2019. This Plan is being updated to reflect developments since. The Plan will set out the roles of the various agencies, the associated communications strategy and operational plan outlining the options and actions required to mitigate impacts on the road network. When finalised, details of the Plan will be published and notified to stakeholders.

 

1.4.3.  Passenger Flows through Irish Ports and Airports

In line with the Common Travel Area, there will not be any change in the way Irish and UK citizens travel between the UK and Ireland respectively. When the UK becomes a third country, it is possible that a Duty Free and VAT Retail Export Scheme may also operate between Ireland and the UK (excluding Northern Ireland). The 2020 Brexit Omnibus Bill includes a number of measures relating to duty free sales and the application of any VAT Retail Export Scheme to UK Residents. Further information on the Bill can be found at Section 1.5.

 

 

 

 

 

Businesses should now:
  • Avail of opportunities to engage with the state agencies to understand the changes that will arise at our ports and
  • Follow the advice outlined in Chapter 2 Trade in
  • Businesses moving live animals, plants and products of animal and plant origin (including wood and wood products) between Ireland and the UK, or to other EU Member States via the UK landbridge should as soon as possible do the following:

e.g. wood pallets; information is available on the DAFM website;

  • Ensure that you are aware of the UK certification requirements for products that you export. These are subject to change but details are available from the UK Government at gov.uk; and
  • Talk to your suppliers, logistics agents and customers and ensure that everyone in the supply chain knows their role and

 

 

1.5.   Legislation

The Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Act 2019 (Brexit Omnibus Act) was enacted on 17 March 2019 as part of our preparations for a possible no deal Brexit in 2019. Many of the provisions of the 2019 Act were not commenced because the Withdrawal Agreement was ultimately concluded and entered into force.

 

To underpin the required readiness measures at the end of the transition period further legislation is required. The Government, on 29 May 2020, approved the preparation of a scheme for a new Brexit Omnibus Bill. The General Scheme of the Bill has now been published and can be accessed on the Department of Foreign Affairs’ website. Work is underway across Departments on the detailed drafting of the Bill which will be brought before the Oireachtas later in the Autumn.

 

 

 

 

The overarching aim of the provisions is to address the wide range of complex issues that could arise post transition and seek to protect citizens and consumers, facilitate the sound functioning of key sectors, and ensure our businesses are not disadvantaged. The Bill will also support aspects of the Common Travel Area and North-South cooperation.

 

Table 1. Parts of the Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Bill 2020
Part Outline
1 Preliminary and General (Minister for Foreign Affairs and Trade)
2 Healthcare Arrangements (Minister for Health)
3 Reimbursement of medical expenses (Minister for Health)
4 Amendments to Companies Act 2014 (Tánaiste and Minister for Business, Enterprise and Innovation)
5 Amendment to Section 10(2) of the Employment Permits Act 2006 (Tánaiste and Minister for Business, Enterprise and Innovation)
6 Arrangements in relation to Fluorinated Greenhouse Gases (Minister for Communications, Climate Action and Environment)
7 Amendment of Student Support Act 2011 (Minister for Further and Higher Education, Research, Innovation and Science)
8 Taxation (Minister for Finance)
9 Financial Services: Settlement Finality (Minister for Finance)
10 Financial Services: Amendment to the European Union (Insurance and Reinsurance) Regulations 2015 and the European Union (Insurance Distribution) Regulations 2018 (Minister for Finance)
11 Amendment of Customs Act 2015 (Minister for Finance)
12 Amendment of Harbours Act 1996 (Minister for Transport, Tourism and Sport)
13 Third Country Bus Services (Minister for Transport, Tourism and Sport)
14 Amendment of Social Welfare Consolidation Act 2005 (Minister for Employment Affairs and Social Protection)
15 Amendment of Protection of Employees (Employers’ Insolvency) Act 1984 (Minister for Employment Affairs and Social Protection)
16 Amendment of Extradition Act 1965 (Minister for Justice and Equality)
17 Amendment of the Immigration Act 2004 (Minister for Justice and Equality)
18 Amendment of the International Protection Act 2015 (Minister for Justice and Equality)
19 Amendment of Childcare Support Act 2018 (Minister for Children and Youth Affairs)

 

1.6.   EU Brexit Readiness and Contingency Planning

Work at EU level to prepare for Brexit and provide advice to businesses and citizens has been a key factor in complementing readiness work across Government in areas where competence rests at EU level or where there is benefit in coordinating the national responses of individual Member States.

The European Commission has published 7 Communications on Brexit readiness and contingency planning. The most recent such Communication on ‘Getting Ready for Changes’ was published on 9 July. This provides an overview of the main areas of change that will take place at the end of the transition period regardless of the outcome of the ongoing EU-UK negotiations. It provides a useful complement to this Action Plan.

In July, at the Summit on the EU Multi-Annual Financial Framework and the COVID-19 Recovery Instrument, EU leaders agreed to make €5 billion available to a special Brexit Adjustment Reserve to counter the adverse consequences of Brexit on the most affected Member States and sectors. As one of the Member States most impacted by Brexit, Ireland is working with the Commission to ensure Irish businesses and sectors benefit from the Reserve, to the maximum extent possible. The Commission will make a legislative proposal for the new reserve in November 2020.

1.6.1.  EU Readiness Notices

The European Commission is updating its 102 sector-specific Readiness Notices to help stakeholders to prepare for the end of the transition period. The Commission intends these readiness notices as an important source of information for stakeholders and pubic administrations about changes that need to be made before the end of the transition period. They cover a wide range of areas including, for example, air transport, the movement of animals, customs, data protection, waste, fluorinated greenhouse gases, road transport, and VAT on goods and services. In particular, the revised notices provide advice on the impact of the Protocol on Ireland and Northern Ireland. Links to specific Commission notices are provided where relevant throughout this Action Plan.

1.6.2.  EU Contingency Measures

As part of its no deal Brexit planning work, the Commission published a number of Communications on its approach to preparing for the UK’s withdrawal. These Communications detailed the state of play of EU preparations, and a number of EU legislative contingency measures were also adopted. These contingency measures were temporary in nature, and were intended to mitigate the worst impacts of a no deal Brexit. The entry into force of the Withdrawal Agreement ensures that a number of the earlier contingency measures will nolonger be necessary while the Commission has made clear that stakeholders should take advantage of the extra time provided by the transition period to ensure they have taken all the necessary steps to prepare. Substantive discussions on possible contingency measures with the European Commission and other Member States will likely not take place until later in 2020. Contingencies for the end of the transition period can be expected to be limited in scope and will not maintain the status quo.

 

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