The UK wants to redraw the post-Brexit trading arrangements it agreed with the EU for Northern Ireland, citing “profound difficulties” affecting the movement of trade.
The government said border checks on goods from Great Britain had proved to be unsustainable.
In a 28-page document, it said it had already become apparent “that it is not possible to operate these arrangements in a way that can be sustained, particularly not in the inflexible way the EU seems to want.”
Brexit minister Lord Frost has called on the EU to look on the country’s proposals with “fresh eyes”.
In the report, he said: “In particular, although most of the trade covered by the protocol remains within the UK customs territory and internal market, under its terms each and every movement is subject to the same extensive processes that are designed to manage third country trade into the EU.
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“That is leading to disruption to supply chains, increased costs, and reduced choice for consumers, and unnecessary boundaries that risk causing wholesale diversion of trade or economic damage in Northern Ireland.”
The report suggests that customs checks should be removed on goods from GB whose final destination is Northern Ireland; remove certificates and checks on food products intended to be consumed in NI and remove medicines entirely from the scope of the protocol.
In a statement, European Commission vice president Maroš Šefčovič said: “We take note of the statement made by Lord Frost today.
“We are ready to continue to seek creative solutions, within the framework of the protocol, in the interest of all communities in Northern Ireland.
“However, we will not agree to a renegotiation of the protocol.”