Robert Keen’s Column
BIFAlink
www.bifa.org
Helping government develop policy
BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266
September provided further evidence of the important role that BIFA Members can sometimes play in helping government departments to develop public policy. HM Revenue & Customs (HMRC) approached BIFA’s policy team in early September asking how the trade association could help obtain feedback from its Members on their current experiences of using the Arrived Exports process within GVMS. Since the UK left the EU, full Customs controls were re-introduced on 1 January 2022, and two export processes are now in operation: Standard Export and Arrived Export. The Standard Export process involves most of the Customs formalities, such as checks on the Customs declaration and physical checks of the goods to take place after the goods arrive at the border location and are within the control of His Majesty’s
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(A company limited by guarantee. Registered in England: 391973. VAT Registration: 216476363) Director General Robert Keen r.keen@bifa.org Executive Director Robert Windsor, Policy & Compliance – Surface & Legal
Government. However, for the Arrived Export process these formalities are carried out inland away from (and before the goods have travelled to) the port. When the Arrived Exports Model was first introduced, HMRC informed the industry of its plans to review the process at a later date, which is now being carried out, so that HMRC can focus on how the arrived exports process has operated over the last seven months, how it can be improved and how it will operate in the future. The response from Members to the online survey that the secretariat set up has been very good and I would like to thank all who submitted their comments. This is not the first time this year that the opinions of BIFA Members have been canvassed via the trade association. Earlier this year BIFA surveyed its Members on the thorny issues relating to the problems they have faced over the last several years in the maritime container shipping market. All respondents to BIFA’s survey were united in their opinion that there is a need to improve the regulatory monitoring of shipping line activities, in particular where they acted not only as carrier but also as logistics provider. Many of the responses to that survey helped BIFA to formulate its approaches to the Competition and Markets Authority (CMA) to raise Members’ concerns, as it reviews the retained Liner Shipping Consortia Block Exemption Regulation in order to inform its recommendation to Government on whether to keep it, replace it or drop it. The intricacies of the Liner Shipping Consortia Block Exemption Regulation are examined in the feature article on pages 12 to 13 of this issue and is well worth a read. BIFA will be very interested in seeing the outcome of the CMA review, and what it recommends the Government should do when the regulation expires in 2024. Once again, the Secretariat is ready to work with BIFA Members to make sure that their views are represented on issues such as rate fluctuations, service reliability, and whether there were (and still are) cases where independent freight forwarders believed themselves disadvantaged compared with a carrier’s ‘in-house’ forwarder. During the incredibly drawn out process of switching from CHIEF to CDS, I have sometimes been asked “what is BIFA doing about it?” I have often thought that it is an unfair implied criticism of the BIFA Customs Policy Group which, by raising constant questions, has put the necessary pressure on HMRC, leading to changes in the implementation timetable, as well as what is being implemented, that has helped BIFA Members. Having made further representations via the programme board seeking clarifications on behalf of our Members, we were pleased to hear HMRC announce its intention to allow CHIEF badge holders to apply for a discretionary extension to use CHIEF, which will give all concerned a further short grace period to finalise their transition and for software developers to complete their system development. However, we cautioned that the important thing to remember is that that this discretionary period is short and designed to facilitate those traders who are close to, but have not fully migrated to CDS. So anyone with their head in the sand over transition from CHIEF to CDS really needs to act fast. As you read this column, hopefully the work done by BIFA and its Members, to ensure that all parties connected with providing information and submitting Customs declarations via the Customs Declaration Service from 1 October, is achieving its goals. You can read the HMRC announcement as well as BIFA’s response on our website. Lastly, I was pleased to secure the services of Kevin Keegan to be our host at the BIFA Awards Lunch in January next year. Many of you may have seen Kevin at the 2021 MultiModal awards when he gave an entertaining talk until the fire alarm interrupted him. The talk will be different in 2023 for BIFA and I hope that many of you will be there as awards finalists to see him.
r.windsor@bifa.org Executive Director Spencer Stevenson s.stevenson@bifa.org Executive Director Carl Hobbis c.hobbis@bifa.org Policy & Compliance Advisor – Customs Igor Popovics i.popovics@bifa.org Policy & Compliance Advisor – Air David Stroud d.stroud@bifa.org Editorial Co-ordinator Sharon Hammond s.hammond@bifa.org Communications Manager Natalie Pitts n.pitts@bifa.org Membership Supervisor Sarah Milton s.milton@bifa.org
Published by Park Lane Publishing peter@parklanepublishingltd.com Contributors
Robert Keen, Robert Windsor, David Stroud, Spencer Stevenson, Carl Hobbis, Sharon Hammond, Natalie Pitts, Igor Popovics Note to media: If you wish to use items in this magazine that are older than one month, please contact the editor to ensure that the item in question still reflects the current circumstances. 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.
Robert Keen Director General
October 2022
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