Goods, Customs and Rules of Origin

Brexit Institute Working Paper Series No 5/2023

19 Pages Posted: 8 Nov 2023

Date Written: October 11, 2023


This chapter examines the legal content of the TCA’s centre-piece, its chapter on trade in goods. Trade in goods is critical between such closely linked trading partners with 48% of total UK imports coming from the EU as well as nearly 60% of its food imports. This chapter argues that the UK is continuously facing a choice between divergence and increased cooperation with the EU. It charts positive progress in areas such as the Windsor Framework and technical barriers to trade but argues that this must be built upon in other areas affecting trade in goods such as SPS requirements and rules of origin. This chapter discusses how the implementation of the TCA’s SPS rules disproportionately affects UK farmers and how the limitations of the rules of origin provided for in the TCA threaten the place of UK manufacturers in EU supply chains in the long term. While the TCA’s trade in goods chapter remains a step back on UK’s previous position, it nonetheless provides a baseline for EU-UK trade that can be improved upon if the will is there to do so.

Keywords: goods, PEM convention, rules of origin, SPS requirements, TCA

Suggested Citation

Moran, Niall, Goods, Customs and Rules of Origin (October 11, 2023). Brexit Institute Working Paper Series No 5/2023, Available at SSRN: or

Niall Moran (Contact Author)

Dublin City University ( email )

Ireland 9
Dublin 9, leinster 9

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