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The Protocol claims that Northern Ireland will remain part of the UK customs territory, but in substance most EU customs rules will continue to apply, placing significant restrictions on GB/NI trade. Under the expansive definition of goods ‘at risk’ of onward movement into the EU market, EU duties are likely to apply to the
majority of goods, and the UK’s power to reimburse or waive these duties will be subject to the full EU state aid regime, as overseen by the Commission. EU institutions, including the CJEU, will have a significant role in oversight and enforcement.