2 >> 1 has also


Issue 7 2018 - Freight Business Journal


down of CHIEF. A l t houg h Release 1 of CDS


went live on schedule in mid- August, HMRC has confirmed that only two low-volume traders were currently using it to make “a tiny number” of customs declarations, says Stewart. HMRC has recently indicated


that, as with TTM5, Release 2 of CDS will also be split in two, meaning that delivery of full imports functionality will be delayed until “aſter Christmas”. The publication of the new electronic tariff, which soſtware firms need to populate their databases,


been


significantly delayed. Realistically, said Stewart: “I think HMRC could have a working system for imports early in 2019, but there is no way that there will now be enough time to have the whole UK trade move over in February/March.” He added that at the


Association of Freight Soſtware Suppliers (AFSS) autumn meeting, an HMRC spokesperson had stated that CHIEF would have to continue in operation aſter March. Indeed, the contract to maintain the CHIEF infrastructure had recently been extended to the end of 2020. According to the National Audit Office, HMRC had spent almost £9 million on scaling up CHIEF for contingency. However, Gordon Tutt of the Association of Freight Soſtware


Suppliers told FBJ that dual running of the new and old systems was possible: “The plan was to have non inventory import declarations migrated to CDS and everything else on CHIEF until full migration was possible. It is for this reason that the CHIEF service has been upgraded to handle additional declarations and become part of an overall contingency plan.” He added that AFSS and its


members have been actively engaged in discussions with HMRC and the CDS project since the project to replace CHIEF was first proposed. Tutt added: “The provision


to operate both CDS and CHIEF concurrently is a major element of the cutover plan and having this dual running element in the delivery is a key factor to minimise disruption to the trade.” Stewart said that the soſtware


supplied by Forward Computers will support dual-running, but warned: “Once you submit a declaration to CDS, if it fails to work you cannot then revert and submit it to CHIEF instead, and this could make traders nervous to migrate.” He suggested that there had


been serious shortcomings in the way the CDS project had been run and HMRC’s preparation for the trade tests was not rigorous or robust enough, a fact tacitly acknowledged by HMRC at the AFSS meeting, he claimed. There is also an issue around


visibility of common problems that developers are experiencing, resulting


in duplication of


effort and a huge waste of time. Queries and fault reports lodged with the CDS team oſten went unanswered for weeks, which was particularly frustrating for soſtware developers, who were oſten leſt in the dark as to whether they needed to fix problems with their own systems or whether the fault lay in CDS. The CDS Programme Board was recently informed by AFSS that, as a consequence, the developer community is now “at a point of crisis in terms of testing”. He


did though sympathise


with HMRC, saying that “CDS is an extremely complex project. While HMRC has some very dedicated and capable staff working on the coalface with CDS, they seem stuck between a rock and a hard place.” He went on to say that


HMRC is gradually becoming more transparent and the CDS Programme Board


has


committed to an overhaul of its internal processes to improve the quality of the trade tests, although “similar promises made before have come to little”. That said, HMRC is planning to throw in extra resources for each soſtware house’s pilot implementation, “which does give us a little more confidence for the final rollout”. Stewart downplayed suggestions that the problems


would lead


UK customs plans will take a decade to realise, says Clecat


UK plans for a Facilitated Customs Arrangement (FCA) could take up to a decade to put into practice and are not a realistic solution to the problems posed by Brexit, says forwarder’s group Clecat in a new position paper published on 16 October. The


group urged Brexit


negotiators to prevent a no-deal situation “at all costs” in a position paper on the future economic partnership between the EU and UK published on 16 October. It says that an agreement the withdrawal “including


over


a reasonable transitional period, a trade agreement, certain conventions (like the Common Transit Convention


der Jagt explained that while UK plans for a Facilitated Customs Arrangement (FCA) might be worth further exploring, “it needs more detail and therefore more time. The proposed FCA leaves so many questions unanswered, that we fear that it will not be possible to apply it in practice by the end of the transitional period and, most importantly, it increases the chance of …a no-deal situation.” According to the paper, the FCA


plan: “leaves out several critical aspects and at the same time introduces aspects with which no trader, customs service provider or (customs) authority is familiar.” The concept of the FCA and


and/or a


security agreement) and other arrangements or facilitations as they currently exist, would be the most realistic way forward.” Director general Nicolette van


ideas like a free trade area or a common rule book “might be good solutions which may be worth exploring, but many aspects of those proposals need far more detail.”


A concept like the FCA “would


require five to ten years before it can be applied in practice,” the paper asserts. The only realistic scenario


is a regular EU external trade environment, a reasonable transitional period, a trade agreement with customs conventions like Common Transit and/or a security agreement) and other arrangements or facilitations as they currently exist. This “would be the most realistic and would limit damage for both economies” Clecat asserts. However, working towards


this situation would still require thousands of new customs experts to be recruited and trained, IT systems would need to be able to cope with millions of extra declarations and notifications, thousands of new authorisations acquired and companies that


CDS to


‘meltdown’ or complete paralysis of the UK’s international trade aſter Brexit, but said that there could be potential for “controlled chaos”. In the worst case scenario, problems with HMRC’s systems, coupled with delays at the country’s borders due to an upsurge in the number of clearances needed, “could lead to significant disruption to the trade” he said, adding: “HMRC’s original plan for CDS rollout is now significantly off course and


the soſtware developer


community is becoming increasingly frustrated as time slips by.” In response to FBJ’s queries,


HMRC said in a statement: “The first phase of the Customs Declaration Service was delivered on time in August 2018 and all remaining functionality will be in place by the end of March 2019.” It added that trade tests HMRC make


that available


to soſtware developers and community system providers have been delivered slightly later than planned, due to technical challenges in building what is a highly complex IT programme. HMRC says it has always planned a period of dual running with CDS and the existing CHIEF system, which will also be scaled to handle any increase in volumes post EU exit. HMRC continues to work closely with key delivery partners, including the freight sector, to deliver CDS.


have never dealt with extra-EU trade need to be made aware of procedures, along with the right infrastructure at ports, airports and other corridors. It says while it is not impossible


to achieve this, there needs to be an understanding that a Brexit with a regular trade environment, far from being a negative outcome, is actually the most realistic and pragmatic approach at this stage of the withdrawal. The technical notices published


by the UK notices on what would happen in a no deal situation have though created unnecessary confusion, says Clecat. It also says that the time frame


provided in the Withdrawal Agreement for a transitional period from March 2019 to December 2020 is very short. (Reports of Brexit negotiations in mid-October suggested that this could be extended.) Extending the transitional


period or a second transitional period, would provide several benefits, Clecat considers.


///NEWS


DfT could charter ferries to keep freight movig


Contingency plans by the


Department of Transport contingency to charter truck ferries to keep essential supplies moving into the UK in the event of a no-deal Brexit were unveiled to the Cabinet on 23 October. According


to a report


commissioned by transport secretary Chris Grayling, the move could be triggered if France were to reintroduce customs checks which in turn would necessitate a shiſt of freight away from Dover and the Channel Tunnel to longer crossings including Tilbury or Liverpool. The Government Owned or


Operated Logistics scheme was reportedly likened by one cabinet member to putting the country on a war footing. Other commentators suggested that it was an attempt by the prime minister to bring home the seriousness of the situation should the UK crash out of the EU without a deal.


Meanwhile, the Freight


Transport Association’s head of European policy, Pauline Bastidon said that a National Audit Office report published on 24 October “confirms that the fears of the logistics industry over border readiness for Brexit in the event of no deal are justified. “There are still so many elements


to prepare if trade is to continue to move freely into and out of the UK, from the Government IT systems required, to contingency measures to mitigate border delays and the availability of government resources to handle new controls and procedures. “Despite repeated warnings


from FTA since article 50 was triggered, it is concerning to note the NAO has confirmed that it is now too late to implement new border infrastructure and that border processes on day 1 aſter Brexit will be ‘less than optimal’.”


News Roundup


Cloud-based network specialist E2open is to acquire the INTTRA ocean shipping network, soſtware and information provider. E2open describes itself as the largest networked supply chain solution, with over 70,000 partner companies and 200,000 users. Founded in 2001 by ocean carriers, INTTRA operates a neutral multi-carrier network across 177 countries with more than 35,000 active shippers, 60 carriers and 150 integrations with transportation management and port system soſtware partners. One out of every four ocean containers shipped globally is booked through the INTTRA platform, it says.


Sea


Unifeeder added a larger vessel to its UK/Baltic Sea route to Riga on 24 September. The new vessel on the twice weekly services has a capacity of 800teu and is ideal for transporting 45’ high-cube containers says the operator.


Unifeeder has appointed Timm Niebergall as director of shortsea services. He was previously regional director west and central Europe.


CMA CGM has joined Maersk Line in imposing a sulphur surcharge. It says that the additional levy of about $160 per teu is necessary to pay for the increased costs of using higher grades of fuel oil and to invest in new technologies such as gas-powered ships or exhaust scrubbers.


The European Commission is inviting comments on the current block exemption for liner shipping consortia from EU antitrust rules, which expires on 25 April 2020. In particular, it is seeking the views of shipping companies, their clients (shippers and freight forwarders), port operators and their respective associations. All stakeholders are invited to submit their views on the Commission’s consultation website up to 20 December 2018. http://ec.europa.eu/competition/consultations/2018_consortia/ index_en.html


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