It has been a while since we published an update. Probably overdue. We have not been idle though. April came and went and hardly anybody was ready. We got an extension until end of October and it’s been pretty chaotic since then! We sat back, re-assessed and realised that we could not repeat the March/April panic – we needed to do something different. So we created the CUSTOMS CLEARANCE CONSORTIUM and have been busy training new staff ready for 31st October and life after Brexit. We expect to be handling around 2000 declarations a day, from day one! This is precisely why we might have gone a bit quiet. We’ve been building and it’s looking pretty good.
For us there are only three major issues remaining:-
1. Export transit
2. Shortage of vets for health certification
For many, number 4 would be the lack of Customs agents, but that is precisely why we created the CONSORTIUM.
So, what can we tell you? Actually, quite a bit now that the Government have lifted the NDA’s that may have prevented us from being quite so open in the past.
UK exports might not affect you and you may be tempted to ignore this issue. Don’t! If the truck that brought your goods in struggles to get back out again, he may not be quite so keen to repeat the process. Transit is mostly related to export movements from UK to mainland EU. The vehicle will either clear at the EU port of arrival or transit inland for clearance at approved premises closer to the ultimate destination. The majority will be on transit. We often hear that transit is the solution to all…it can be the problem too! To raise a transit document you need a transit guarantee (not cheap!). To authenticate a transit you need authorised consignor status or you need to go to the port…along with all the others who are not as prepared as they could/should have been.
Arrive in Calais, for example, with no transit or a transit that has not been authenticated and you might be coming back on the next ferry! (unless you have a pre-lodged entry in place). Operation BROCK, which is the freight stacking system for Kent is mostly for transit – while trucks queue up to get their TAD (transit accompanying document) raised and stamped at STOP24 or MotisFSA. You need to avoid these queues…and you can. Government want to make sure that only those that are BORDER READY are allowed to reach the port/terminal of export. There is even the suggestion of fines if trucks arrive at Dover, for example, with incorrect or incomplete documents.
What is being done about it? More locations are needed to (a) check the paperwork and (b) authenticate the paperwork. Government plan is to install a number of pop-ups (about 100) dotted around the UK. The driver will be required to call in, get pre-checked and directed accordingly. This can work. We are also working with a number of truckstops to have them approved for the authentication of export documentation. The most notable being the recently extended Ashford International Truckstop which can now accommodate around 600 trucks, thereby doubling the capacity in Kent.
A large part of the effort is focused on export transit at the moment. I’m back in Whitehall this week precisely for this reason. Watch this space but be aware that diagnosis is 50% of the cure…we’re working hard on the other 50%!
SHORTAGE OF VETS
Products of animal origin (POAO) will require an export health certificate to be allowed entry in to EU. For the avoidance of doubt, in most cases you will NOT need a health cert for UK imports. There is a shortage of vets, probably more than there is a shortage of Customs agents. Exporting POAO goods will be a delay at despatch (waiting for vet sign off) and a delay at EU import as goods and paperwork will need to be checked. There simply aren’t enough vets. We are expecting DEFRA to delegate responsibility to authorised traders and 3rd parties (similar to the process today with the issue and authentication of EUR1/ATR1 preference certificates). We have suggested that some (not all) of the proposed export pop-up stations should include the ability to issue health certs.
If you know a vet, talk to him/her as soon as possible – you need to secure their services in the event of a no deal…and they’ll be getting many calls right now.
Not a Customs issue but could be a major issue. Wooden pallets entering the EU should be ISPM15 heat treated. Most are not. Mainland EU have shown signs of relaxing this requirement. A recent communication from Tesco Ireland would suggest that Ireland are intending to apply the letter of the law. We continue to monitor the situation. You should speak to your pallet provider. You need the ones with the IPPC stamp!
Of course that is not it. We also need to tell you about TSP, about the pitfalls of DDP, about registering with TRACES/IPAFFS/PEACH/DAFM. Too much info for this update. So we’ve written an interactive guide. The guide offers punchy advice whether you are a UK exporter, UK importer, EU exporter, EU importer or logistics provider. It also includes a walk-through of the no deal border process. To get your copy go to: https://www.mybrexit.uk/downloads and click on the link for BREXIT guide Aug19 (we’ve made it red so you can find it easily). Download the file to your desktop and play as a Powerpoint show otherwise the animations and links will not work. Enjoy!
Conspicuous by its absence. Not included here in great detail as not fully designed as yet. We know what the processes will be for GB-IRL-GB. We know what the process will be for IRL-NI. The missing piece is NI-IRL. We know what the process is but the question is more where than what. The CONSORTIUM is set-up to also prepare and present Customs declarations in IRL so we are fine with the processes. We continue to monitor developments and are confident that we are agile enough to handle the eventual process, no matter what it is. We have also not covered IRL-UK-IRL transit here but again, we know the process, aside from GB-IRL-NI as currently there is no stand-out solution for closing the transit in NI. Again, diagnosis is 50% of the cure.
We hope you will find this update useful. Make sure you download the BREXIT Guide Aug19.
Robert Hardy, Commercial Director, Oakland International