On January 1 2021, the UK ceased to be a member of the EU. That dramatic change had wide-ranging consequences.
Now the UK has forewarned that some formalities on imports to Great Britain will increase from January 1 2022.
For businesses in Northern Ireland the changes have more complex implications. The arrangements agreed as part of the new relationship between the EU and the UK meant that to facilitate acceptable trading arrangements without a customs frontier on the island of Ireland, Northern Ireland would be treated as remaining within the internal EU market.
This seemingly simple difference has, as should have been anticipated, created a series of not so simple consequential changes.
The most obvious complication was that Northern Ireland could be used as a point of entry for goods being sold into the wider EU and should, therefore, be administered as if it was within the EU and any EU import requirements should be applied.
The administrative tension is that goods imported to Northern Ireland might be either part of normal trade within the UK, with no customs formalities, or trade destined for locations in the EU (using routes through NI).
Without a customs frontier on the island of Ireland there is a need to have an administrative process that makes a distinction on the proposed final destination of goods arriving in NI either for local users or to pass in transit across NI into the Republic of Ireland or onward in the EU.
As originally officially drafted the EU-UK Protocol seemed to treat all trade into NI as potentially likely to avoid EU import requirements.
Making the correct distinction on goods coming into NI is the core problem being faced in seeking a practical operational regime.
By acknowledging the possible export of goods from NI to GB (as internal trade) and also to other EU countries (as a protocol concession), traders in NI have the advantage of less restrictions on free trade in both directions.
Even at this early stage in the new trading environment, there is no surprise that the improved access for NI trade to Britain and EU markets is an obvious benefit.
Equally, without a clearer rule book, there is an important possible obstacle for traders selling into NI.
There is close scrutiny of the effects of the protocol on businesses in NI, GB and Ireland.
But two things make the collection of evidence somewhat uncertain. First, trade in the early months of 2021 is not necessarily firm evidence on the full effects.
Businesses will gradually adjust to the new conditions and, as a preliminary feature, must understand how the new trade arrangements will operate.
Second, the early evidence of the impact on the cross-border flow of trade in goods is neither comprehensive nor statistically reliable.
The best evidence, which is helpfully independent, comes from the collection of external trade statistics by the Irish statistical services.
As an aspect of policy, the Irish have a track record of publishing trade statistics separating (as far as the customs system allows) trade with Northern Ireland from statistics on trade with Great Britain.
The trade statistics prepared for the UK do not separately identify the flows to NI. The estimates made by the UK authorities are, therefore, less helpful.
However, the Irish statistics have shown critical changes.
There are now, useful estimates (with some reservations) for Irish exports to NI and exports by NI firms to Ireland.
We also have the Irish statistics on imports from and exports to GB. There is a statistical gap in the evidence on what has been happening to trade flows between NI and GB.
However, statistically the early months of 2021 show clear changes in trade flows north to south, and vice versa, on this island.
Northern Ireland has significantly increased exports going south and vice versa. Even though the full implementation of the protocol is still under debate, businesses, both sides of the border, have found more customers taking advantage of the maintenance of NI’s trading advantages post-Brexit.
We do not yet know with enough certainty how NI to GB trade has been affected. However, whilst GB exports to NI will have been disadvantaged, NI exports to GB should be largely unaffected.
In short, the protocol is working as expected. There is positive evidence that, for NI businesses, the advantage of access to both GB and EU markets is working.
Now, the critical test for Lord Frost and his EU counterpart is how to retain the benefits and avoid unnecessary difficulties in a revised series of protocol arrangements. The protracted negotiations on how the protocol could work seem to be an unhelpful mixture of pragmatic operational decisions made more difficult by contrasting political approaches.