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Policy & Compliance


BIFAlink


information can be found in the European Commission’s notices to stakeholders on Brexit and Air Transport and on Brexit and Air Transport Safety Rules.


Road Road will be the mode most affected by a no-deal Brexit, with multiple impacts. For the first time since 1993, the trucker will be regarded as a ‘carrier’ with significant responsibilities relative to customs procedures. Also, in order to operate in EU member states, they will have to be aware of permit requirements. It has been agreed that UK truckers will be granted


temporary haulage rights to ensure basic connectivity and facilitate the flow of goods through the Channel Ports. The intention is to minimise any possible disruption to trade. Rather like with air, UK truckers will find that they will be able to make limited deliveries and that they will be prohibited from undertaking cabotage. Also, the rights are conditional on the UK confirming equivalent rights to EU-based operators. The EU has stated that UK drivers working for EU operators


will have to obtain a Driver CPC issued by an EU country. In many member states this will require 35 hours’ training to be undertaken by the driver. The European Commission has issued a notice to stakeholders on Brexit and Road Transport


Maritime Once again, the loss of the Single Transport Contract facilitation for goods transhipping on a through waybill at an EU port will lead to additional customs procedures. However, because the containerised goods will remain under customs supervision at the transhipment port, these additional procedures, we understand, will be aimed mainly at clearing the relevant inventory systems. One area that is likely to cause concern to EU traders relates


change will be the disappearance of the Single Transport Contract for shipments transhipped at an EU port consigned on a through waybill to a destination outside the EU. All goods will have to be exported from the UK and placed into transit for the journey to the airport of departure, where the transit movement is discharged. Local procedures will need to be undertaken to complete the export. For goods moving from the EU to UK for export, the procedure will need to be reversed. Airlines will still be able to conduct their business but in very


different circumstances. The Commission has passed the necessary legal acts allowing airlines to fly point-to-point between the UK and European airports. These very basic flying rights, matched by the UK, will be effective until March 2020. However, the most significant change will be that operators will be unable to continue on to other EU destinations or take new passengers to non-UK destinations. These are very short-term and limited measures and it is to be hoped negotiators will be able to agree a fuller aviation agreement. One area that is largely overlooked relates to aviation


security; it is ironic that the UK originated most EU initiatives in this area. On pages 18-19 of this issue of BIFAlink there is an article giving more detail on this subject. Additionally,


October 2019


to the potential loss of the Union Status of their goods if a vessel carrying them berths at a UK port. To prevent this problem a T2 will be required, as it will be for goods being shipped from the Republic of Ireland via mainland UK to the EU. The final direct impact of a no-deal Brexit on maritime


transport will be the loss of cabotage rights for UK vessels operating within the EU.


Customs In many ways this is the area where a no-deal Brexit has the most significant impacts; the Single Market, supported by the Customs Union, has facilitated the free movement of goods throughout the 28 members states for over 25 years. After 31 October in a no-deal scenario this will cease; customs controls of some form will have to be re-imposed. One of the most overlooked but significant customs-related


changes will be the disappearance of Indirect exports, including the Single Transport Contract for shipments transhipped at an EU airport, consigned on a through waybill to a destination outside the EU as mentioned earlier. All goods will have to be exported from the UK and placed


into transit for the journey to the airport of departure in the EU, where the transit movement will be discharged. Local


From the enquiries received at BIFA, certain sectors are taking the threat of a no-deal extremely seriously and are preparing accordingly.


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