if you read jonbwfc post which i agree with you will find that the greater the EU try and control be it trade or data the larger the amount that will slip through their fingers. but we will wait and see as i believe a quick and hard exit is on the cards after such it will be down to the EU to agree our deal not the other way around ...

Because it is a legal requirement of doing business with Europe. This is why the US is having such problems, especially the likes of Facebook and Google, they are constantly being pulled in front of the courts, because they are breaking the rules for storing personal data on Europeans. If you do business in Europe, you have to comply with EU laws, and that includes EU data protection. That was the whole point of the Max Schrems vs. Facebook case, which he won and thereby proved that the Safe Harbor agreement wasn't worth the toilet paper it was written on.


Ahain, see the Max Schrems case, the current Google investigations into data protection infringements etc.

The laws state that you must hold the data within the EU or you must guarantee, that it is held to the same standards when held offshore. That is where the US companies have fallen afoul of the law, because they agreed to Safe Harbor, which meant that they agreed to hold the data to European standards, including not passing the data to third parties without getting the written permission of identifiable parties. The companies were then complying with FISA Court letters and handing the data over to the US Government, which is illegal, thus the Safe Harbor collapsed and left the cloud providers without a leg to stand on and companies in Europe using cloud services with a presence (a presence mind you, not necessarily headquarters) in the USA with a serious problem, where their cloud provider was opening them up to prosecution and private legal action for breeching EU data protection laws, by allowing the US Government access to the data - even though the businesses were "unaware" of it, when they took out the contracts with the cloud companies.

Holding financial data in the cloud is even more risky, you need to get a special dispensation from the local treasury in order to store the data within the EU (outside the country of origin), let alone outside the USA.

I was handling the details of a partnership deal with a US based cloud service, as data protection officer for my employer, and that was one of the sticking points, they kept saying that everything was OK and that they had Safe Harbor (2012/2013) and I kept telling them that Safe Harbor wasn't going to work, because of the FISA courts. They just didn't seem to understand how doing business in Europe meant dealing with EU laws and making sure they were compliant. They did work with the German Finanzamt (Treasury) to get their accounting suite validated, but each customer had to then apply separately for dispensation to use the service, because it stored the data in 2 data centers in the USA.


And that is what Facebook tried to do with Ireland, but the German and Austrian data protection legaslatives are very strong and the case ended up at the ECJ, because the Irish DP Commissioner said that it had nothing to do with them. The ECJ said otherwise, claiming that Safe Harbor was null and void in light of FISA and the Snowden revalations and that the Irish DPC should jolly well do his job!

Compared to countries like Germany and France, the UK data protection commissioner seems to be impotent and nearly useless.


With all due respect, most of them were bitching, before the Brexit vote, that if Brexit went through, they would probably have to leave the UK, if they wanted to continue doing business with the EU. If the UK doesn't comply with EU data protection regulations, then the companies will at least need to open data centers within the EU borders, and if RIPA gets approved, probably run the way the Microsoft centers are run - by an EU third party, where the company doesn't have any physical or administrative access to the data.


If the EU can force the USA to comply, especially in light of the Safe Harbor fiasco and the current court case between Microsoft and the US Justice Department, about whether the USDJ has jurisdiction in Ireland, then I don't think they will have many problems making the UK comply.

Given that the USA is in a much stronger position to bargain than the UK, I don't think the UK will be in a position to dictate terms, if the USA has to agree to store data following EU guidelines, even if it is held in the USA.

It hasn't though has it? It's not like the USA has enacted laws equal to the EU's on data protection and everybody sticks to them. Some individual firms have, some have not, which is why we have the ongoing run of legal cases. And as I said, the noise about data on/from EU citizens being held in Russia and/or China is conspicuous by it's absence.

The EU data regulations are a good thing. But in the real world the fact they have to keep taking people to court about them rather suggests their observance is significantly less common than you seem to be assuming it is. Brexit is not going to make that better in fact it's probably going to make that worse.

the UK will not dictate a deal that will be the preserve of the EU. and to be honest i believe its only going to be WTO rules only as that will bypass any EU dictates.
and just to add we the UK are in the driving seat on this not the EU as we can now trade without fear lett or hindrance outside the EU with anyone ...

I would think that, in any trade negotiation (for physical goods at least) you will eventually have to agree a minimum set of standards the goods will have to meet. If your internal standards exceed the minimum set by the other side then no problem, except perhaps your stuff will cost more. On the other hand, if your standards are lower than those of the market you are trying enter there will be a problem.

This was one of the issues with TTIP for example. If it was signed then it would have lowered EU standards to match those of the US rather than requiring the US to come up to EU standards. At the moment the EU appears unwilling to drop its standards so the deal is dead (fingers crossed anyway).

WTO rules aren't some magical panacea for trade. They set some ground rules but there still has to be negotiation and agreement of terms, all of which takes time. And at the moment the UK is pretty thin on the ground in terms of experienced trade negotiators as it's all been handled at the EU level.
Whatever deals we may end up with will take time, can't start until we've triggered article 50 and left (or we'll be subject to financial penalties for breach of EU law) and may not be that great because quite frankly we don't have the experience any more (or not enough of it anyway).

http://www.bbc.co.uk/news/business-37605642

Prices are going up already in some areas. Apple upped it prices recently, and it seems that some car manufacturers have upped their prices since the recent collapse in Sterling. http://europe.autonews.com/article/2016 ... ter-brexit

Sterling is currently enjoying an all time low - one of the worst performing currencies this year. Expect petrol to go up soon. http://www.bbc.co.uk/news/live/business-37576875

Anyone thinking “we’ll be fine” is clearly living in their own little fantasy bubble.

i wouldn't worry about the level of the £ i would start being concerned about the state of the EU banks
as of fuel prices they are stacking and racking tankers by the hundreds out at sea ...

ps. are the % of tariffs EU tariffs imposed ? ...

Brexiters be like

Given that my company pension is in Sterling, I do worry about the level of the pound. The same for buying products, I just bought a new monitor. It cost me 100 quid more than it would have done a month ago!

At the moment there are no tariffs for the movement of goods within the EU, including the UK. After the exit from the EU, tariffs will need to be agreed upon.

Currently, for a UK business, all they have to worry about it the cost of delivery and ensure that they are VAT registered and they can sell their products anywhere in the EU - looking at the German Amazon portal, there are hundreds of UK businesses offering products there. (Some are a pain to deal with as a business, because they are not registered for VAT, which usually means we have to return the goods and look for another supplier; we quickly learnt to look at the sellers profile to see if they have a registered VAT number). The new rules (because of Amazon, Google, MS, Apple & Co. means that it is more difficult for smaller suppliers to operate, because they need to register for VAT in each country they sell products in - because the big names were using Luxembourg or Ireland as headquarters for sales, there was next to no VAT, which made the products much cheaper, so the EU are changing the rules and the VAT must be paid in the country where the buyer is registered.

After Brexit, they will need to deal with export licenses, customs regulations, import restrictions, CE certification for electronic goods etc.

As a good example for the problems, look at the cheap Chinese products, most are not CE certified and will be stopped by customs at the border and either destroyed or sent back to the seller - c't magazine did a test this month cheap vs. brand names and they tried to test the Xaomi Mi Book Air against a MacBook - pretty similar specifications, but the Mi Book was around 500€ and the MacBook 1400€, the MacBook Air around 1000€. Unfortunately the Mi Book is not officially imported into the EU, so they bought it on an international, Chinese-run sales portal. The customs declaration etc. were correctly filled out, but the package was sent from a known industrial estate in China, so it was held by customs and the staff at c't had to go to the custom's offices and open the goods in front of the customs official. Here, they simply looked for a CE-mark (manufacturers guarantee that the goods comply with EU regulations for electrical safety and radion smog), the US-Style power supply, the EU plug-adapter and the device itself were all missing the CE-mark, so the goods were sent back to China (the buyer can decide whether to have the goods destroyed by customs or have them sent back to the seller, with the latter option, there is a small chance that the seller will get their money back).

So, leaving the EU won't make any difference to the certification of goods, if they are to be sold in the EU, they must conform to those standards. If you are selling services to EU citizens, those services (including data security and data protection) must comply with EU standards. On top of that, there would then be the complications of export duties, extra paperwork etc. Of course, EU products going into the UK would also have to meet the UK standards, so it is a two-way street.

The question is, whether the UK would keep the EU-standards, like CE certification, to keep price rises to a minimum - if the device is certified for the whole EU to EU standards (which are pretty high and currently the requirement for the UK as well), it makes the product in the UK cheaper than if the product needs to be re-certified for the UK market and the costs of that certification applied just to products sold in the UK - this makes their price artificially higher than the rest of Europe, because the product has to be certified a second time for a relatively small market - spreading a 5-figure testing cost over customers in 27 countries, as opposed to just a single country makes a significant difference.

er..your own example provides another possibility - don't care at all about the EU standard, ship laptops in from China and lots of things get cheaper/companies importing them make more profit. More risky of course, but I can't imagine a conservative administration bothers that much about consumer safety tbh. It's all horrible red tape y'know...

You beat me to it!

"Hard Brexit will be ‘brilliant for Britain’, insists complete f*cking moron"

http://newsthump.com/2016/10/11/hard-br ... ing-moron/

https://twitter.com/DavidAllenGreen/sta ... 1149555712

The salient bit:

"Imagine if remain had won by tiny margin & the govt went for "hard remain" - Schengen, Euro, multilingual signage. People would go [LIFTED]."