BIFAlink


Policy & Compliance


www.bifa.org


EU Exit: prepare for the next stages


The next few months are going to be extremely challenging for all involved in moving goods as stages two and three of the EU Exit come into effect. However, with a clearer understanding of what will be required, the sector will be in a better position than it was on 1 January


At the time of writing, Members have had to cope with a perfect storm of problems stemming from the UK exiting the EU, the disruption stemming from COVID-19 and, domestically, planning the implementation of the Customs Declaration System (CDS). The trade press has highlighted supply chain related issues; these have been issues of supply at origin in the Far East, then at import where the goods are consumed in Europe. Concurrently with these issues, consumer demand for goods has increased significantly. Supply chains have finite capacities that are difficult to expand quickly. One area where there has been a decrease in cargo volumes


being moved is between the UK and EU; no one is sure by quite how much, but a figure that was commonly bandied about regarding the Short Straits traffic at the end of January was approximately 70%. The fact that freight is still moving is a testament to our Members’ endeavours and their efforts should be acknowledged and applauded.


Problems on the horizon However, there can be no hiding from the fact that there have been mistakes and it is only reasonable for BIFA to point out that there are more problems on the horizon. This stems back to the fact that the UK’s implementation of border controls is a three- stage approach. In many ways the first stage focused on exports from the UK with limited additional import controls, although it might not seem that way to those endeavouring to cope with them; the final stage in July will focus primarily on import traffic. The second stage, which becomes effective on 1 April 2021,


is probably only going to have a fairly limited impact as the main requirement is that all sanitary and phytosanitary (SPS) goods will need to be declared to the import of products, animals, food and feed system (IPAFFS). However, the third stage, which occurs on 1 July, will have a much greater impact requiring a Safety and Security Declaration to be lodged for all UK destined cargo. In addition, a frontier customs declaration will be required for import shipments and DEFRA will be enforcing inspection rules for SPS goods. Into this mix, Members will have to deal with a build-up of


10


problems stemming from the first stage, a point that we will return to later. Important lessons can be learnt from the first phase of


implementing EU exit. Hopefully trade will understand the EU–UK Trade Co-operation Agreement and its implications by 1 July, particularly matters relating to the impact of the rules of origin clauses on free trade. The primary lessons to date are preparation and


communication. We have said, and will continue to state, that the changes stemming from EU Exit will require in a short timeframe the re-engineering of the EU-UK supply chain to take into account the additional ‘friction’ stemming from the re-introduction of frontier controls. At the moment, a significant number of the problems stem from the fact that not all parties moving goods either know about or comply with the new regulations. Members have been in regular contact with us regarding


unnotified inbound trucks that have arrived at their premises, in all probability without undergoing customs formalities. EU based forwarders and hauliers are presuming that UK importers are using the Delayed Declaration system, which requires an entry in declarants’ records supported by a


March 2021


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20