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Innovation Campus. Given the COVID-19 restrictions in place at the time, Keegan was granted a key worker certificate. This allowed him to travel to Portsmouth docks to oversee the loading of the chamber sections onto specialist vehicles. He was also able to travel with the police escort from Portsmouth to Harwell. Just after the BIFA Awards, Specialist Logistics Services was expecting a vibration plate to arrive from the US for this project. Looking further ahead, Keegan plans to keep developing his skills. “I have done some training with BIFA and I would like to do more to increase my knowledge generally – but also specifically in relation to Customs, to help EU shipments move smoothly and efficiently,” he said. contractual arrangement with the exporter and declare themselves in Box 2 or oblige the exporter to find an established entity who would otherwise assume the exporter’s role. The consequence of representing a non- established entity is that a declaration will have to be lodged by an established party (usually the freight forwarder/customs agent who is legally required to be established) but on behalf of a non-established entity. This automatically means that the forwarder/Customs agent will become an indirect Customs agent by the force of law (for more information please refer to A Guide on the Appointment and Responsibilities of a Customs Agent www.bifa.org/media/4642393/107484 _gpg_customs_representation.pdf) making it jointly and severally liable for the accuracy of a Customs declaration and any Customs debt arising. This requirement is, however, known to traders and, although burdened with regulatory risk, is much more acceptable from the operations and legal perspective. At this point it is important to highlight the fact that the above approach would only apply to declarations submitted in Britain, excluding Northern Ireland where the UCC and other EU regulations still apply. BIFA will be updating Members once further guidance has been issued by HMRC.
“Previously, I had worked for another logistics company for about five years,” Keegan Starkey said. “This involved a lot of exhibition logistics, so I had the chance to travel a lot. Then a job came up at Specialist Logistics Services and it was a case of right time, right place.” He continued: “Each project is like a little mission. You have to figure things out, and it is never the same twice. It can be 10 times the effort but it is also 10 times the reward compared with sending a parcel.” In 2020, for instance, Specialist Logistics Services brought the six sections of the UK’s largest space test chamber from a manufacturer in Ortona, Italy, to the Harwell Science and
The non-established exporter: a follow-up
In the previous edition of BIFAlink we raised the issue of the export declaration completion rules where the exporter was a non-established entity as, despite the fact that the UK left the EU’s Single Market and the Customs Union, these completion rules were still aligned with the UCC guidance. The Secretariat has since queried the completion rules on the grounds of the post-EU Exit legislation, which does not incorporate the EU’s definition of exporter into the UK legislation and says the following: The Customs (Export) (EU Exit) Regulations 2019: Eligibility of persons to make export declarations 12. – (1) A person may make an export declaration in respect of goods if the requirements in paragraph (2) are met by that person.
(2) The requirements are – (a) that the person is able to – (i) make the goods available for examination, or (ii) secure that the goods are made available for examination; and (b) that, except where regulation 13 applies, the person is established in the UK. We now understand that HMRC has concluded that the lack of the EU’s definition of exporter effectively re-aligns export and import declaration completion rules. What it means for freight forwarders and customs agents is that they will be able to use the details of a non-established entity in Box 2 of an export declaration just like it is currently allowed to use the details of a non-established importer in Box 8 of an import declaration. They will no longer be required to either enter into a
September 2021
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