Richard Price, Fruit Marketing
Border processing – the transporters’ perspective
This article looks at post-Brexit cross-border trade from the transporter’s perspective. As such our thanks go to Steve James of Brittany Ferries for his input. Steve has been involved – along with representatives of other shipping lines, ports, hauliers, local and national government – in preparing for the post-transition changes for cross-border logistics. To follow is information on who does what, where and when.
As previously stated, from January 1st 2021 all goods sent to and from the EU need to be processed at the borders as well as being risk-assessed.
These processes will be required even though a free trade agreement has been reached.
And remember – every export is an import, and vice versa.
Most traders will rely on a customs agent or haulier to get their goods to destination. But a knowledge of the process will help understand how shipments work, and also the value being delivered by these intermediaries.
NB. The term GB is used (rather than UK) for trade between England, Wales, Scotland and the EU. Border processes for trade into and out of Northern Ireland differ from those between GB and EU.
An export declaration must be completed and approved by HMRC. The haulier is then given Permission to Proceed (P2P) to the port of export or requested to go to a destination where the goods/documents will be checked.
Most traders will employ a customs agent to complete the declaration into CHIEF, the HMRC customs processing system. It also includes the Export Summary Declaration (EXS) for Safety & Security. From 1 January – 30 June 2021 these will not be checked by the ferry operator/Eurotunnel; rather they must have reasonable belief (through contract terms) that the haulier will not arrive at port without the correct documentation.
From July 1st 2021 the export documents will be checked against HMRC records at the port by the ferry operator/Eurotunnel prior to shipping. Any discrepancy may result in non-shipment.
Imports into the EU.
There are varying customs processes, depending on the systems used or developed by the EU nation states.
The driver must carry this documentation as it will be checked on the way to the GB port of export. He/she will be prevented from proceeding if the pre import declaration is not available for inspection.
For those shipping via Dover or Eurotunnel, hauliers must have a Kent Access Permit and for Portsmouth triage points have been created on the approaches to the city. There is no service at Plymouth until the 22nd March 2021. Find out more here
At port the ferry operator will scan the barcode and pair it to the vehicle registration number, sending the information to the SI Brexit system. The goods will be processed during the crossing and a message sent to the haulier/driver confirming the status of the goods on arrival :- green, good to go; orange, inspection needed on arrival.
Your haulier will also need to complete an IMPORT Summary Declaration (ENS) which is completely separate from the customs processes, although some of the information is duplicated. This is submitted into the EU Import Control System (ICS) which has been developed to help assess the risk that goods entering any EU state may pose. The declaration has to be submitted at least 2 hours before arrival into the EU.
Import processing for goods entering Spain uses the traditional system used for Rest of World (RoW) trade, which involves the ports having “temporary storage” facilities (allowing the goods to stay within a customs approved area until cleared) and being “inventory linked” which means the port, customs agents and customs authorities are linked via one digital system.
Other EU countries
Other EU countries of first destination use a system similar to Spain. Although the processes may differ slightly, the requirements are the same. i.e. full customs clearance before the goods can be released into circulation as well as clearing the risk assessment via the ENS declaration.
Exports to GB
Goods being imported into GB also have to complete export processes from the EU. This will be completed by the exporter or customs agent, generating the required documentation which will be passed to the haulier/driver. This will be checked at the port before the vehicle is embarked.
Goods coming into GB ports will be processed in one of two ways:-
Many ports – e.g. Portsmouth, Poole and Plymouth will have both; other ports may have one or the other.
The pre lodgement model is very similar to the French SI Brexit system.
The haulier will also need to complete an IMPORT Summary Declaration (ENS) which is completely separate from the customs processes although some of the information is duplicated. This is submitted into Safety and Security GB (S&S GB), the system developed by HMRC to help assess the risk that goods entering GB may pose. The declaration has to be submitted at least 2 hours before arrival into GB.
NB. Unlike exports, and to allow time for preparations to be made, the UK government will not enforce the above process for imports – using pre lodgement or GVMS/temporary storage and ENS declarations – until the 1st July for non-controlled goods (which are the majority.) For a list of controlled goods see the UK Border Operating Model https://www.gov.uk/government/publications/the-border-operating-model
Goods being imported using traditional methods don’t require a pre import declaration, however, this will delay clearance (goods can remain 90 days before clearance is required). As this does not suit the dynamic of most goods travelling by RoRo ferry/Eurotunnel (or hauliers), a pre import declaration is usually lodged by a customs agent before shipment, allowing full clearance to be completed either during the crossing or, more commonly, on arrival.
Goods moving in transit do not require customs clearance on arrival in the EU or GB. They are covered by the Common Transit Convention (CTC) and are cleared at destination.
For example, if you have sold goods to a Portuguese customer and they are being transported by lorry via Spain, they are entered into the New Computerised Transit System (NCTS) and a Transit Accompanying Document (TAD) is raised, with a Movement Reference Number (MRN), which must accompany the goods.
Before embarking at the UK port, the TAD details are entered into NCTS by Border Force at the office of transit (these offices will be at the RoRo ferry ports Portsmouth, Poole and Plymouth).
On arrival at the Spanish port, the TAD details are again put into NCTS and the goods can then proceed to Portugal, where full import customs clearance will take place.
NB. All goods travelling in transit need to be covered by a guarantee that ensures any duty/tariffs due will be paid. They will also need ENS declarations.
(some are acronyms, some aren’t)
RO-RO Roll on Roll off, the method of transporting goods by ferry/Eurotunnel between the UK and EU
EXS Exit Summary Declaration
ENS Import Summary Declaration
SI Brexit The system developed by French customs to help aid the flow of freight traffic
MRN Movement Reference Number
URN Unique Reference Number
ICS Import Control System
RoW Rest of World
GVMS Goods Vehicle Movement System
GNR Goods Movement Reference
S&S GB. Safety & Security GB
CTC Common Transit Convention
NCTS New Common Transit System
TAD Transport Accompanying Document