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A summary of Technical Notices issued by the UK government


The Technical Notices give a snapshot of what will happen, from the UK’s perspective, in a no-deal scenario and what the country will be able control domestically


At the time of writing, the UK government has issued three tranches of Technical Notices covering aspects of Customs, international travel and transport, and general business activities. One of the problems with so many documents


released in one tranche – 24 in the third batch – is that it makes evaluation difficult. In this release there were two of particular interest to BIFA Members, one covering aviation security, the other international road freight movements. All the documents follow a familiar pattern covering: • The current pre-March 2019 position, • Preparations being made for Brexit in the UK, • The post-March 2019 position.


The documents emphasise that they only cover the “unlikely” event of a “no-deal” arrangement which would mean that there would be no Withdrawal Treaty (which is already 90% agreed) or Transitional Agreement in place. Therefore, these documents must not be regarded as fact, merely one view of what might occur – a Doomsday scenario if you like. What


November 2018


they do show is that a no-deal scenario will hurt the UK much more than the EU 27.


What the documents show


In all cases the documents show that there is: • A significant level of integration of EU systems, whether it be covering aviation security, international driving permits or the inspection of animals or products of animal origin.


• In some cases, as emphasised in the road haulage document, plans are being made to implement trailer and permit schemes, etc, and use alternative available systems, but these will not be adequate.


• The UK’s fallback situation, in many cases, will be to recognise EU standards/directives in the UK hoping that the EU will reciprocate, which aligns with the Common Rulebook concept in the Chequers Agreement – It has to be emphasised that there is no certainty that the EU will reciprocate; for instance, one of the first tranche of Technical Notices referred to EORI


numbers, etc, and using the EU database. HM Revenue & Customs (HMRC) is making contingencies as the EU has advised that in a no-deal scenario, the UK will not have access to the EORI database, and in all probability the TARIC, TRACES, and the AVSEC databases detailing Regulated Agents and Known Consignors.


Some will probably argue that some of the text is naïve and verges on giving commercial guidance that may harm a sector; in particular, those comments about hauliers looking at different routes and participating in the modal shift to shortsea. However, the reality is that many traders and


forwarders believe and are planning for such changes.


No-deal snapshot The Technical Notices give a snapshot of what will happen from the UK’s perspective in a no- deal scenario, and what the country will be able to control domestically.


In a generic sense they show that government


is preparing for the worst-case scenario, which is to be welcomed. These notices are an encouragement to business, much of which is unfamiliar with international trade outside the EU, to start considering what it needs to have in place for a no-deal scenario.


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