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Policy & Compliance


• An increase in shortsea movements, • Additional government interventions at the frontier.


The other area that is likely to be impacted by Brexit is


customs and related activities. For the purpose of this article, we are only going to examine frontier activities. • The number of import customs entries could increase from approximately 70 million to 350 million. In all probability CHIEF and CDS will be able to process this increase, but there are significant capacity issues relating to staff availability, premises and potentially IT infrastructure.


• There are financial implications relating to the provision of deferment and transit guarantees.


• The introduction of re-engineered customs procedures for goods moving between the EU and UK, which will include the need to provide safety and security declarations.


At this very difficult time the industry is also having to cope


with the introduction of CDS, which is increasing workloads in both the short and longer term. Even areas such as airfreight, which many have felt will be


impacted to a lesser extent than road, will have to adjust. The question of the so-called ‘flying truck’ moving between the EU and UK still has to be resolved. To date, from a security viewpoint, the EU Commission has indicated that it will not recognise the UK’s system as being the equivalent of the European one. This will mean that the UK will have to apply under the ACC3 regulations for its airports and carriers to be approved by EU inspectors. Currently the UK is responsible for granting ACC3 designations to 37 carriers from around the world on behalf of the EU, including many third country national airlines. It is possible that these will lapse when the UK exits the EU and that they will have to re-apply to a different EU member state for their system to be recognised as meeting EU standards.


Contingency planning – points to consider Change is inevitable due to Brexit and companies are planning for and, where possible, implementing the necessary adjustments where the cost impact is relatively low. For costlier and more-difficult-to-implement changes involving recruiting additional staff and leasing premises, Members are making plans but not implementing them. The crucial point is for Members to fully understand their


current business and assess both what may change, and the impacts on their business. Given the current lack of clarity surrounding the outcome of the Brexit negotiations, there is a certain element of guesswork involved, but there does seem to be consensus forming that a decline in cross-Channel traffic is likely, although the extent is unclear. Even here there is the possibility that increased revenue from customs clearance will compensate in part for a decline in forwarding activity. Having spoken to Members already familiar with customs


entry work, dependent on customs policy, they are considering basing the EU customs entry function away from the port of entry into the UK, and/or moving the goods inland for clearance. There are existing procedures for presenting consignments at Dover, but these would need expanding to meet the demands posed in a post-Brexit environment. This


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Many forwarders have already indicated that they will give priority to existing customers who understand customs activities arising from importing or exporting goods to or from countries outside the EU


will allow forwarders to maximise existing resources and minimise delays at the port. Inevitably consideration has to be given to traditional


business requirements such as staffing, training, finding suitable premises and IT requirements. However, there are a couple of areas which we believe have


not been adequately covered. The first is that Members must consider carefully where they obtain information on Brexit. It is important that Members keep themselves up to date by subscribing to the latest updates from the GOV.UK website; whilst some of the material has been naïve, it is both readily available and comprehensive. This information could be made available by Members to their customers. The second point will be more controversial, much has been


made of the many tens of thousands of businesses who will have to consider dealing with customs activities for the first time. Many forwarders have already indicated that they will give priority to existing customers who understand customs activities arising from importing or exporting goods to or from countries outside the EU. These traders will have at least some understanding of customs activities. There is concern regarding the risks incurred by dealing with companies with no customs experience. The only way to overcome this issue is to maintain strict due


diligence procedures, which may include an assessment of new clients’ customs knowledge, and only taking on business where the customs agent acts as a direct representative. We hope that this article will allow the reader to start


considering what areas to focus on when planning for Brexit. The main issue is clearly the lack of clarity surrounding the nature of the post-Brexit arrangements, and it has to be remembered that these are just as significant the other side of the Channel. For instance, BIFA has 24 trading Members in and around the Dover area; recent communication from one highlighted that there is only one customs agent in Calais. The crucial thing is that both UK and EU negotiators agree upon a long transition period to allow all parties sufficient time to adjust to the necessary changes.


December 2018


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