The British International Freight Association (BIFA) is encouraging businesses engaged in visible trade between the U.K. and E.U., and the freight and logistics companies that serve them, to make sure that they are fully prepared for rule changes that will take effect over the next six months following an initial postponement.
In March, BIFA welcomed the easements for new customs declaration requirements and other checks on imports from the E.U. as part of delays in the implementation of Stages 2 and 3 of the Border Operating Model. The delays were introduced by the U.K. government to soften the impact of the U.K.’s departure from the E.U. single market and customs union at the end of 2020.
Now, the trade association says the clock is now ticking on the extended deadlines.
While BIFA director general, Robert Keen, notes the media suggests the delayed customs declarations timetable has simply delayed a potential crisis, he is confident that most BIFA members have now had the opportunity to prepare for new customs processes for imports from the continent.
Failing to declare
However, he also noted that any importers that are new to the customs environment should beware of the implications of failing to make the declarations that will become necessary.
“That’s why we are encouraging them to consider appointing a freight forwarder, if they haven’t already done so, to deal with their customs documentation, whilst they concentrate on their core business, which has been hard hit by both Brexit and Covid-19.
“Feedback from our members suggests that one lesson learned from the changes implemented at the start of January this year is that the practical application of the changes has often been as challenging or, in certain cases, more challenging than anticipated.
“Now, both the trade association and its members need to encourage traders to fully consider the likely impact of the requirements of Stages 2 and 3 on their business well before the implementation dates.”
Gaps in information
Although the government has provided advice and guidance on some of the changes, BIFA says that significant gaps in information remain, which need to be filled to allow businesses to make certain key operational decisions.
Keen continues: “Despite constant pressure, we are still lacking full clarity as to which ports will be operating a Pre-Lodgement, as opposed to a Temporary Storage, model for processing cargo, for example.
“Furthermore, despite reassurances from government, concerns remain among BIFA members whether the necessary infrastructure will be built in time for them to meet the requirements of the revised deadlines announced in March.” Members have expressed particular concerns regarding the “White Cliffs” facility under development at Dover.
BIFA notes that from 1 October 2021, there will be additional documentary checks on products of animal origin and high risk foods not of animal origin, whereby traders will be required to declare all SPS consignments on IPAFFS The original documents will need to be submitted and these will be audited post clearance.
Third stage
The third stage of full border controls will be implemented on 1 January 2022 and BIFA says that from a Customs perspective the most important changes will be the ending of the Delayed Declaration Scheme at that time.
After this date, a full or simplified customs entry will be required at the frontier for goods being imported from the E.U. to the U.K. mainland. Depending on location the entry will have to be submitted as a pre-lodged declaration utilizing the Goods Vehicle Movement System (GVMS), or as a frontier declaration at the point of entry into the U.K. Associated with this is the requirement for a Safety and Security (ENS) Declaration to be submitted prior to the goods being loaded on the means of conveyance bringing them to the U.K.
In addition, certain products such as Products of Animal Origin will be subject to full SPS controls and have to be presented to Border Control Points, where inspections may be undertaken.
“The period after 1 January 2021 was very challenging, although trade did not grind to a halt. However, the new fear is that we face much greater challenges after 1 January 2022 than we did the previous year, if only because there are more new processes to master and, historically, levels of import traffic exceed exports by a considerable margin,” Keen said.
“Clearly, there is much to consider and prepare for, and there is not much time to do so. While we continue to help members with their own preparations, we are also encouraging them to help their clients that import from the EU to be equally prepared. Of particular concern is the level of preparedness and knowledge of EU suppliers with regard to the new import procedures to be adopted, and potentially the export procedures in Europe.”
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