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Overview of the gove Brexit Technical Not


BIFA is concerned that the government Technical Notices are not as joined up as they might be and that some sectors, such as road haulage, will face unwelcome changes to their current procedures


The UK government published a series of technical notices on 23 August setting out further detail on what is officially regarded as the unlikely event that the UK leaves the EU on 29 March 2019 without a deal. The notices are intended to ensure businesses and citizens have time to prepare by setting out steps they may need to take in the event of ‘no deal’. It should be remembered that whilst


the Single Market is very much a work in progress, the Customs Union is more complete, with Customs being one of the most integrated of all EU activities. Reference is made in all the documents that the advice covers a “no deal” situation. The reader should remember that there are many scenarios that would require increased frontier activity, including Customs declarations and other governmental interventions.


Intended readers Also, it is important to remember that these Technical Notices are aimed at those parties who have previously only traded with the EU and are thus unfamiliar with international trade and the customs requirements that would be introduced unless there is a special deal reached or the UK remains in the Single Market and the Customs Union. In this brief article we are going to look at the four main notices impacting on our sector: VAT,


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Tariff Classification, Exporting Controlled Goods, and Trading with EU. The last of these covers Customs activities. Increased frontier regulatory activity would


stem from a Brexit that included a Free Trade Agreement. Effectively there are only two scenarios where no Customs declarations would be required. These are an agreement which maintains the current status quo, or a bespoke deal such as envisaged in the White Paper based on a Facilitated Customs Arrangement supported by a Common Rulebook. Some initial reaction to the Technical Notices


was of a generic nature and overlooked certain key points, some of which are beneficial to the


sector. Having read the four documents, we feel that they are not as joined up as they might be and certain sectors, most notably in road haulage, will be faced with some unwelcome changes to current operational procedures.


Trucking sector Of all the modes, BIFA has consistently highlighted that the trucking sector will be the one most affected by the re-imposition of frontier controls. Also, we have highlighted that currently most truckers operate as hauliers not carriers. The latter type of operator fulfils wider regulatory roles than a haulier. In a “no deal” or deal under which safety and security


October 2018


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