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Robert Keen’s Column


BIFAlink


BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266 Web site: www.bifa.org E-mail: bifa@bifa.org (A company limited by guarantee. Registered in England: 391973. VAT Registration: 216476363)


Director General Robert Keen r.keen@bifa.org Executive Director Robert Windsor r.windsor@bifa.org Executive Director Spencer Stevenson s.stevenson@bifa.org Executive Director Carl Hobbis c.hobbis@bifa.org Policy & Compliance Advisor Pawel Jarza p.jarza@bifa.org Policy & Compliance Advisor David Stroud d.stroud@bifa.org Editorial Co-ordinator Sharon Hammond s.hammond@bifa.org


Published by Park Lane Publishing peter@parklanepublishingltd.com Contributors Robert Keen, Robert Windsor, Pawel Jarza, David Stroud, Spencer Stevenson, Carl Hobbis, Sharon Hammond


A brief lull in enquiries on regulation changes – before the next onslaught


Things have quietened down at the Secretariat compared with the first couple of months of 2021 when we experienced a huge volume of enquiries about EU-Exit and the associated changes to procedures. Of course, it is never quiet for long and we expect similar activity in October when checks on agri-food and feed become applicable; although the activity is likely to become more intense in January 2022 when the delayed declaration easements are withdrawn. Later in 2022 we will say goodbye to CHIEF (Customs Handling of Import and Export Freight) and no doubt grapple with the introduction of the new Customs Declaration Service (CDS) for entry processing. I have vivid memories of the introduction of CHIEF for import entries on 1 April 1994, when managing the import department of a large Heathrow forwarder. Despite


preparing for the go-live date many months in advance (with an IT system enhancement that met the published specification) we were overwhelmed by the changes and had staff working late into the night. As well as doing entry work, one of my key roles was trips to the pizza shop and off licence! Another ‘working through the night’ part of my career was 40 years ago in May 1981 when HMRC (then HM


C&E) took industrial action. Entry processing was handled by the predecessor of CHIEF called DEPS (Departmental Entry Processing System), and with Customs officers ‘working to rule’, the system had insufficient capacity for entries to be transmitted and was withdrawn during the day. As entries were cleared by officers in the day and space freed up on DEPS, the system was opened for use at 3am the next day, leading to Heathrow import staff setting alarms for the early hours and rushing into the office waiting for the system to open. A mad scramble then took place competing to get entries input before space was filled at about 5am when we all tried to get a bit more sleep. Fortunately, long-term fallback with manual entries was introduced after a short while. A fun memory is of a community meeting when a senior Customs manager said: “Why do you get up at 3am? Just go to work as normal in the morning.” He was swiftly educated on the way work is conducted in the commercial world. So, returning to CDS, we sincerely hope that the introduction will be smooth but as one wag said to me,


“when did a government computer system get introduced on time, within budget and work first time”. HMRC has said that CHIEF will be withdrawn after a period of dual running with CDS to allow for any teething problems to be fixed. I sincerely hope that Members do not experience some of the issues that came with the introduction of CHIEF, which will be helped by the advances in technology since then and the proliferation of freight software companies that manage transmission of entries. Meanwhile, development of our online CDS training course continues apace and we hope to announce the


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Please be advised that BIFA DOES NOT OFFER LEGAL ADVICE. BIFA is not a law firm and the authors of this publication are not legally qualified and do not have any legal training. The guidance and assistance set out herein are based on BIFA’s own experience with the issues concerned and should not be in any circumstances regarded or relied upon as legal advice. It is strongly recommended that anyone considering further action based on the information contained in this publication should seek the advice of a qualified professional.


start date and cost soon. It has been developed in collaboration with Agency Sector Management (ASM) and is modelled on the same format as the Customs Declaration training we have been running for the past two years. When you sign up you are given access to a learning management system and you simply follow the course at your own pace. More details will be in BIFAlink and on bifa.org To end, I must return to the thorny matter of pricing in the container shipping sector. I recently read a


comment from a forwarder in the trade media that there had been no support from industry bodies on this matter. I do not know how many times we have to say this, but BIFA would be in breach of competition law if we were to try to embroil ourselves in any discussions regarding rates. We can be informative where appropriate and suggest that the appropriate authorities investigate and intervene if they can, but shipping lines are private enterprises, commercial entities. The days of regulation and the conference system are long gone and there is no sort of regulatory or legislative body that can prevent the lines from pricing their services at the level they think that the market will pay.


Robert Keen Director General


June 2021


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