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Policy & Compliance


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supplementary declaration up to six months after initial import. This problem will cease when the need for a frontier


declaration is required after 1 July, but it will leave an uncomfortable legacy of confusion and additional workloads required to rectify the situation. The second primary lesson is that increased frontier


regulation increases the time taken to process cargo and the associated documentation. This has two significant impacts: it reduces capacity in the industry and increases the potential for delays, which then lead to equipment shortages. The most successful forwarders are those that planned and


invested in understanding the impacts of new procedures on their processes, whether it be new physical or IT infrastructure, and the expansion of their customs intermediary function. This was allied with a willingness to discuss and communicate unpalatable information to customers. In fact, in all probability the greatest problems to date surrounding EU Exit have been the failure to realise that there will be significant change, what precisely will be different and by how much.


Key changes So, moving forward to 1 July, the following five key changes will occur: • Full customs and other regulatory controls will be re- introduced for all goods being imported into the UK. This will require a full customs entry and clearance of the goods before they can be released.


• Similarly, SPS checks will be increased with higher inspection rates on imports of foodstuffs, etc. Consideration should be given to routing cargo to ensure that the import Border Inspection Point can handle the imported product.


• The temporary Delayed Declaration easement finishes, and the first supplementary declarations will be required to be submitted to HM Revenue & Customs (HMRC).


• Use of the Goods Vehicle Management System (GVMS) is expanded to all include all movements, not just Transit.


• For imports, a full Safety and Security Declaration will be required prior to goods arriving in the UK.


March 2021


It is important that the specific requirements of these


changes are fully understood and factored into procedures and commercial decisions going forward.


Impact on Members BIFA is very concerned that these new procedures will impact on some Members just as they are submitting the first supplementary declarations for Delayed Declarations; not only will these take time to prepare and verify, but there is a financial impact because the party submitting the supplementary declaration will have to pay maybe up to six months duty against a Deferment Account. This may lead to the Deferment Account holder having to increase its guarantee limits to cover the sum. At the same time, due to the increased use of Transit, forwarders are having to increase the guarantee for this regime as well. Many are facing having to increase both guarantees, which has the potential to place a considerable strain on a company’s cash flow, resulting in a need to reconsider its financial policies. The writer would like to conclude by giving a practical


example of changes that forwarders have implemented to minimise problems. Some will have noted that there have been fewer outbound queues than anticipated in Kent. In part this is due to reduced traffic levels, but it is also because better checks are being conducted upstream in the supply chain. We have heard of many cases where forwarders have started documentary and compliance checks at an earlier stage in the process – in certain cases even before cargo is collected and before being taken to a central hub for final loading. The next few months are going to be extremely challenging


for all involved in moving goods. However, as a sector we have certain advantages compared with 1 January. There is greater clarity with regards to what the agreement between the EU and UK requires, systems are better understood and there is a greater understanding of how to utilise them. There are still significant concerns, such as the unreliability of the New Computerised Transit System (NCTS), but planning will help Members overcome the inevitable problems that they will encounter in the next few months.


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BIFA is very concerned that these new procedures will impact on some Members just as they are submitting the first supple - mentary declarations for Delayed Declarations


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