A couple of big weeks ahead, culminating in the European Council meetings 17-18th October. As it stands we are leaving on the 31st October 2019. Quite how that can happen is a mystery. The PM is still saying “we are leaving on the 31st” despite the Benn Act suggesting otherwise. Hopefully this is little more than a negotiating tool to keep the heat high.
We are still preparing for a no deal exit on the 31st October and will continue to do so until there is firm information to the contrary.
THE WORRY LIST
Government have four items giving them cause for concern. Shortage of Customs agents, heat treated pallets, export transit and vets! Most other items are ticked off (even if the tick is not particularly big in some cases). The shortage of agents is a concern. The work load will increase five-fold in the UK and more than ten-fold in Ireland. There are not enough agents. We have been working hard to get the Customs Clearance Consortium up and ready by 31st October and things are, so far, going according to plan. We are getting ready to handle more than 2,000 declarations a day…from day one! Impressive numbers but still less than 0.5% of the market!
Heat treated (ISPM15) pallets is still an issue. EU have not yet confirmed a concession but considering the three main pallet poolers are EU based (Chep, IPP and LPR) we are hopeful of some leniency. If you have a stock of ISPM15 pallets, keep them safe. You might not be able to export from UK to EU unless on an ISPM15 compliant pallet. For the avoidance of doubt a ‘euro pallet’ is not ISPM15 compliant unless it has the IPPC stamp. Do not think that because it says ‘euro’ it is okay. Do not export (from UK to EU) on a wood pallet unless it has the IPPC heat treated stamp. As it currently stands, you do not need ISPM15 pallets to import to UK.
Export transit. Transit is the solution to many woes but creates its own challenges. You should plan to authenticate any UK export transit documents at your premises or other premises away from the port. Wherever possible do not plan to endorse a transit document at the port of export – there are likely to be large queues. HMRC are attempting to solve this problem by creating 100+ pop-up Customs offices at truckparks across the UK. The mantra is “border ready”. Go to a pop-up, get the documents checked and if all in order you should be able to avoid any export queues which should only exist for those that have not yet obtained documents. In most cases you do not need a transit to import to UK.
Vets! Big problem. There are not enough vets for the volume of export health certificates required. Finding a vet is quite easy. Finding one that can be with you when you want (at a price you are willing to pay) is not so easy. If you export products of animal origin, get to know your local vet. Get to know her/him well! Agree the process and price. There is no point in us arranging export Customs documentation if the health certificate has not been done first. You cannot export without the certificate. Government are employing a whole bunch of assistant vets who can issue (but not stamp) the export health certificate. Idea being the ‘flying vet’ will appear to stamp those certificates that have been pre-arranged. UK have been on a recruitment drive for vets, so much so that we now understand that there is a shortage of vets in Spain!
PRODUCTS OF ANIMAL ORIGIN
Online advice has recently been updated and is conflicting. We have reported this to the Border Delivery Group. The web page has improved but it is still foggy. Our understanding is that imports from EU do NOT require IPAFFS or IV66 from day one. We have meetings in Whitehall on Tuesday and will seek further clarity on this point. For now, if you have not already done so, it would be worth registering on IPAFFS, it’s quick, easy and free!
OUR BREXIT GUIDE
We created an interactive guide and have received a lot of positive feedback on it. If you have not already done so please go to www.mybrexit.uk/downloads and select the red button. It covers all of the above and much much more. The guide is aimed at EU exporters through to UK imports and logistics companies.
WHAT DO I NEED TO KNOW?
We are often asked the same questions. What paperwork is required and where? What do I need to do if I trade on DDP incoterms? What duty rate will apply to my imports and my exports? There are many questions but many that are recurring. We have decided to do something about this. We have written an interactive guide that helps you understand what is required and what you need to be aware of. You can find it here: https://www.mybrexit.uk/what-do-i-need-to-know Take the test and see how much you understand. Share it within your organisation as a training aid. We hope you will find it useful.
WHAT DO I NEED TO DO?
For those that understand the basics the next question is always “what do you need from me?” We always planned to write this guide but rather than list the things you need to tick off when importing or exporting we thought we would take it to the next level. We’ve imagined you have a live transaction and you require Customs documentation. What better way to show you what is needed than actually doing a dry run? To access this element go to: https://www.mybrexit.uk/what-do-i-need-to-do Work through the questions and submit your data. You will receive a confirmation that we have the information, referenced by the trailer number and date. The data arrives with us in a way that allows us to efficiently prepare Customs documentation. Try it, share it and generally have a play. We will prepare a dummy entry based on what you send to us. There is no charge – we need good test data and your sampling of the process will help both of us.
If you are a logistics company and would like your own branded version of the ‘what do I need to do?’ process let us know. It will be set-up in your name with the entry data going directly to whatever email address you nominate. There is a charge of £500 for the personalised version. There is no charge for members of the Customs Clearance Consortium.
The clock is ticking and, to coin a phrase, “Denial is not a strategy”.
Robert Hardy, Commercial Director, Oakland International