BIFAlink is BIFA's monthly magazine covering issues of importance for the logistics and supply chain industry.
The magazine of the British International Freight Association INSIDE: • Business Leaders Forum • Understanding the GLEC Framework • How the Northern Ireland frontier changes will work • Pro fi le: deugro’s award winning project work • Strengthening our regional team BIFA link October 2023 The Border Target Operating Model: A missed opportunity?
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Issue: 398
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Steve Parker’s Column
Signs of the changing times D o you like cricket? I am a fan and enjoy all the forms of the game from the 100 to Tests. I have been fascinated by the change in approach; the desire to ‘go for it’ in every game (win or lose), to both enjoy and thrive, whatever happens. Our industry has seen, and continues to see, much change, and as
BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266 (A company limited by guarantee. Registered in England: 00391973. VAT Registration: 216476363) Director General Steve Parker s.parker@bifa.org Member Policy & Compliance Director Robert Windsor r.windsor@bifa.org Member Support Director Spencer Stevenson s.stevenson@bifa.org Member Services Director Carl Hobbis c.hobbis@bifa.org Member Engagement Director Denise Hill d.hill@bifa.org International Relations Manager Robert Keen r.keen@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 bifacomms@bifa.org Membership Supervisor Sarah Milton s.milton@bifa.org Published by Park Lane Publishing peter@parklanepublishingltd.com Contributors Steve Parker, Robert Windsor, David Stroud, Spencer Stevenson, Carl Hobbis, Web site: www.bifa.org E-mail: bifa@bifa.org Sharon Hammond, Natalie Pitts, Igor Popovics, Brooke Neilson, Nezda Leigh, Robert Keen, Denise Hill 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.
always there is a lot happening. This is reflected in the workload at BIFA, so for this month’s DG column I want to highlight a number of interesting articles in this edition that show a direction of travel for the association and our business. So, whether or not you are a 100 fan, enjoying the excitement of limited overs, or an advocate of Test cricket, a test of stamina, take a read.
Did you notice? It is said ‘a picture paints a thousand words’. Did you notice the subtle change in my portrait picture? Gone is the suit and tie to something more casual, which is not only in line with today’s business attire, but also reflects what we wear to the office at BIFA. “Does this matter?” I hear you cry. May be not much, but like the move away from the all- white kit in cricket, it does reflect the efforts we make to be up to date. BIFA: CCS-UK & AIS For those who love test cricket the new Advanced Information System (AIS) innovation in air cargo collections and deliveries is going to take some time to get used to, so take a read of the article on page 24 explaining the process and benefits for users. CCS-UK has been working with stakeholders to enhance AIS to support electronic delivery and collection notes in the near future with the objective of removing paper and improving security. BIFA has been alongside this development and updating the best practice guide issued years ago by the trade association and the AOCC (Airline Operators Committee, Cargo). If you move your freight via air, and particularly at Heathrow (although national roll-out is planned), then this is of great interest to you. Board You should also read the article on page 7, which reports on a recent ‘away game’ for the BIFA Board. We held one of our meetings in Liverpool and took the opportunity to meet with local stakeholders, and some BIFA members. Awards submission For us, the annual awards ceremony is like painting the Forth bridge, we barely finish one year and we start on the next. Here is gentle reminder that submissions to all 11 categories of the 2023 awards are due now. Business Leaders Forum If you are a business leader, by the time you read this you should have received your invite (if not, please contact Sharon on s.hammond@bifa.org). I have mentioned this before, but this, the second forum in the series, will take place on 19 October in central London. Howzat? As ever, if you have any queries on any item covered in BIFAlink or wish to bring an issue to our attention, please do not hesitate to contact me or one of my colleagues. Our details are listed in the panel to the left or at https://bifa.org/contact/company-staff/
Director General
October 2023 | 3
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BIFA News
CNS introduces its fi rst port community system Ian Matheson, from Impress Communications, reviews some recent news that might impact on Members’ business
Signatories to this continent- linking transport infrastructure included the USA, the EU, India, Saudi Arabia and the UAE. The Sevington Inland Customs processing facility, at Ashford in Kent, is now fully operational and able to carry out Customs checks on items crossing the border, including the movement of more highly regulated goods such as live animals, as well as strategic exports and sanctioned goods. Along with a site in Holyhead, it will reduce HMRC’s dependence on commercial operators Dover Western Docks and Stop 24, which have handled Customs checks since the UK left the EU in 2020. IN THE WAREHOUSE The 2023 European Real Estate Logistics Census, published by Savills and Tritax EuroBox, revealed that respondents identified rising rents as the greatest concern amongst logistics occupiers this year, followed by access to labour and a lack of supply of new buildings. IN THE AIR In early September, IATA released its global air cargo data for July 2023, which highlighted a consistent pattern of recovery in growth rates, a trend that has been ongoing since February. IN BUSINESS In line with the push from various organisations and entities to move towards a digitised trade future, the FIT Alliance – made up of BIMCO, Digital Container Shipping Association (DCSA), FIATA, International Chamber of Commerce, and Swift – has announced the Declaration of the electronic Bill of Lading (eBL). This aims to secure a commitment from all stakeholders in international trade to collaborate in driving digitalisation to help streamline international trade, making it more efficient and dependable.
ON THE QUAYSIDE CNS, a DP World company, is introducing its CNS port community system (PCS) in UK ports, starting with Belfast. The PCS will replace Compass and offer HMRC compliance, enhanced ease of use, cross- platform integration, and adaptability to regulatory changes, whilst promoting data sharing, efficiency and resilience of the ports in a digital era, the company said. ON THE OCEAN Maritime UK, the collective voice for the UK’s maritime industries, used the London International Shipping Week, last month, to highlight the need for £2 billion of private
and public sector investment per year to deliver its target of decarbonising the maritime industry by 2050, and further support an ambition to become a global leader in decarbonisation.
duress and could become the targets of takeovers by global liners, according to a new report from Danish maritime consultancy Sea-Intelligence. After record-high volumes transported by sea in 2022, the first half of 2023 saw the container shipping market return to volumes slightly above 2020 levels, the shipping analyst Container Trade Statistics noted in its latest report. It presented figures showing volumes down by 3.6% compared with 2022. After a slow start, the use of telematics is gaining ground in container shipping and the sector now appears ready for tracking boxes, as falling unit costs make smart container devices viable for dry equipment, and carriers also see the benefits of managing their fleet inventory. OVERLAND The Loadstar website reported in September that European road freight spot prices had dropped below contract rates for the first time in six years. Feedback from operators active in the sector suggested the floor has yet to be hit. One of the key outcomes from last month’s G20 summit in New Delhi was the signing of a memorandum of understanding to create the India-Middle East-Europe Economic Corridor (IMEC).
Operators in the heavily fragmented intra-Asia
container shipping trades are coming under severe financial
4 | October 2023
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BIFA News
BIFA to hold second Business Leaders Forum
BIFA Director General Steve Parker held the inaugural Business Leaders Forum in April attended by a limited number of senior personnel of BIFA Members. The second event in this series is to be held this month and all BIFA trading Members should have received an invitation for their MD, CEO, Country Manager, etc, to attend. During this event, BIFA will update Members on the latest topics that will impact the industry in the months to come and explain what you can do now to prepare... an opportunity not to be missed! Topics covered during the session will include the latest on: Air • The FIATA/IATA agreement - an update on
our advice on the topic of representation and establishment. Training • New training courses – BIFA plans to develop more training opportunities to support and upskill your workforce Environment & Sustainability • A strategy for our industry - we share the findings of a consultant-led report commissioned by BIFA Scan the QR code to sign up to attend the event.
this agreement that could set the relationship between freight forwarders and airlines for the next generation. • AIS - Advanced Information System aiming to automate the process of collections and deliveries from UK airports. Surface - Maritime/Road /Rail • CBER - an update on the
current state of the Container Block Exemption Regulation review being undertaken by the competition commission Customs • BTOM, CDS Exports, Windsor Framework, Single Trade Window - potential disruptions that need attention now. • Indirect and Direct - have you been caught out? Hear
Survey launched on supply chain visibility platforms
We at BIFA value our Members’ insights and strive to understand the evolving needs of the industry so that together we can continue to grow and thrive. Following an increasing number of articles in the trade press recently regarding supply chain visibility platforms, you should have received an invitation from BIFA to contribute to our survey on the subject. The focus of this survey is to delve into your attitudes, needs and practices concerning supply chain visibility platforms – a topic that is increasingly gaining momentum in the industry. Your participation is voluntary but very important, regardless of whether your company is already leveraging supply chain visibility platforms or if you are unfamiliar with them. Your unique perspectives, spanning businesses of all sizes
and types, will undoubtedly shape the direction of our industry's future. By participating in this survey, you can help us gain critical insights into: 1. The specific challenges your organisation faces in terms of visibility and tracking freight. 2. The methods you currently employ to access real-time information about shipments, logistics and potential disruptions. To get started, scan the QR code or visit www.smartsurvey.co.uk/s/BIFA
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6 | October 2023
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BIFA News
FIATA Best Practice Guide on Electronic Contracting FIATA released its latest publication in September, the Best Practice Guide on Electronic Contracting , developed under the auspices of the FIATA Advisory Body on Legal Matters (ABLM) to provide best practices when contracting by electronic means throughout the process. It takes into account various practices around the world from a global perspective and provides practical tips to consider when using electronic contracts. FIATA would like to express its gratitude to the delegates of FIATA Advisory Body on Legal Matters, who provided valuable input and insights. Their contributions were critical to the success of this guidance, and FIATA is deeply grateful for their support. For more FIATA best practice guides, scan the QR code to visit the FIATA website.
Board dinner held in Liverpool
Pre-pandemic, the BIFA board always took one board meeting a year on the road. Like so many other things in life, this had to stop when restrictions were introduced. Not this year, though. BIFA board members gathered in Liverpool in early September and we were able to host a dinner with the local
stakeholders and some Members from the city. We saw first-hand the
continues to struggle). More important than that, we were able to discuss the potential for the area and the part BIFA and its Members might play to ensure Liverpool remains an ongoing success story. Steve Parker, BIFA Director General, offered his thanks to everyone who attended and made the evening enjoyable and a success.
regeneration, which in part was focused around the European city of culture status in 2008 but has clearly continued since. For football fans, we heard all about the building of a new stadium for Everton (but sadly for some supporters, not the rebuilding of the team, which
New phased approach to CDS
Phase 1: High-volume declarants During the initial phase, HMRC, in collaboration with software developers, will provide dedicated support to selected high-volume declarants. These businesses are scheduled to migrate to CDS for exports by Thursday 30 November 2023. Phase 2: All Other Businesses The second stage of this approach encompasses all
HM Revenue and Customs (HMRC) unveiled a new phased approach in August for businesses transitioning their export declarations to the Customs Declaration Service (CDS). Based on feedback from industry stakeholders, HMRC is taking a strategic step to facilitate a smoother transition for businesses adopting CDS for their export declarations. The transition will be completed in two phases.
remaining businesses, who are expected to make the transition to CDS for exports by Saturday 30 March 2024. This approach allows HMRC and its delivery partners to leverage existing IT testing and conduct additional performance analysis while businesses with the existing IT functionality begin their migration. This ensures the provision of enhanced support making the transition to CDS as smooth as possible.
The Limits of Liability for Carriers
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By road – CMR (8.33 SDR): £8.94 per kg
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October 2023 | 7
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Policy & Compliance
Levelling the playing fi eld: A universal methodology that enables freight forwarders of all sizes to measure and report emissions consistently. Enhanced Credibility: With widespread recognition as the industry standard, stakeholders can trust that reported data adheres to a standardised methodology. Benchmarking and collaboration: practices enables decisions backed by data and the setting of realistic reduction targets. Future-proo fi ng compliance: Freight forwarders with GLEC accredited scope 3 emissions reporting will be better positioned to stay ahead of evolving compliance measures. What’s next for the GLEC Framework? Whatever the future holds for the GLEC Framework, it will play a pivotal role in helping T&L tackle new challenges as the industry transitions to a more sustainable future. As technology and data collection methods evolve, the GLEC Framework will need to be adapted to further enhance the accuracy of scope 3 emissions calculations. The promotion of wider adoption among freight forwarders globally also remains essential. For more information, see the QR code (left). Keep up to date with BIFA Comparing emissions and benchmarking against best As announced in BIFAlink last month, BIFA has launched a new Sustainable Logistics & the Environment Policy impacting their day-to-day business, to contribute to external consultation and to spread best practice and understanding throughout the international freight community. The first meeting of the new Sustainable Logistics & the Environment Policy Group will take place on 16 November. Contact Mike Jones, Policy Advisor – Sustainability & Environment (m.jones@bifa.org) to express your interest in joining this group. Group to provide a forum for members to discuss issues
The GLEC Framework’s industry-leading guidelines will play a pivotal role in helping the transport and logistics sector tackle new challenges as the industry transitions to a more sustainable future. Understanding the GLEC Framework
W ith rising concerns about the impact of climate change, the transport and logistics sector (T&L) faces increased pressure to tackle its carbon footprint. The fi rst step is knowing the quantity of emissions produced by the sector to determine where in the supply chain reductions can be made. In August 2016, a BIFAlink article reported on the Global Logistics Emissions Council framework (GLEC framework) that had been launched in Washington as “the first global carbon accounting method for the logistics chain”. Later that year, the European launch of the GLEC framework took place in Brussels. Since then, the GLEC Framework has developed into a set of industry-leading guidelines that standardise the methodology for calculating and reporting logistics greenhouse gases across all modes of transport. As the only globally recognised standard for emissions calculation in the logistics industry, it also serves as the primary guideline to support the implementation of the ISO:14083 standard for the quantification and reporting of greenhouse gas emissions arising from transport chain operations.
How does the GLEC Framework work? The GLEC Framework enables
forwarders to use shipment weight, distance travelled and an emissions intensity factor to calculate an accurate estimate of the emissions produced for a given shipment. • The methodology is specifically designed to use standard assumptions taken from average industry operating practices to fill any data gaps. • Forwarders with very little shipment data can still access accredited emissions calculations. (Note: standard assumptions are typically conservative and could compared with actual conditions.) • The methodology also enables users to gain further insight and accuracy, depending on the quality and granularity of their data. The bene fi ts of measuring carbon emissions with the GLEC Framework The core purpose of the GLEC Framework is to be a driving force towards sustainability in T&L. The benefits include: lead to results that over- or underestimate emissions
“ The GLEC Framework enables forwarders to use shipment weight, distance travelled and an emissions intensity factor to calculate an accurate estimate of the emissions produced for a given shipment
8 | October 2023
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Policy & Compliance
It is planned that, from October 2024, the Windsor Framework will ensure ‘not at risk’ movements are freed of unnecessary paperwork, checks and duties How the Northern Ireland frontier changes will work
S ince, and stemming from, the Brexit referendum result there has been almost constant change in Customs and related frontier activity. Nowhere is this more true than in Northern Ireland, the people of which have had to endure the false start of The Northern Ireland Protocol and now the Windsor Framework, which currently does not seem to be delivering all the hoped-for benefits. It is important to bear in mind that the implementation of the Windsor Framework is having impacts on the UK mainland as well. Government is having to divert resources, including financial, away from important projects such as improving CDS to implementing the Windsor Framework. The different initiatives required to implement the Windsor Framework have been released at different times. The purpose of this overview is to bring them together so the new individual processes can be viewed as a whole. However, not all the details are clear and further guidance is needed from government. UK Internal Market Scheme The Windsor Framework establishes a new voluntary scheme, the UK Internal Market Scheme (UKIMS), for the movement of ‘not at risk’ goods into Northern Ireland from the UK mainland. At the time of writing this article, the scheme, which has been open for registration for much of this summer, was due to replace the UK Trader Scheme (UKTS) from 30 September 2023, although some details remain unclear. UKIMS will continue to enable registered traders to move goods in line with existing ‘not at risk’ arrangements. It is planned that, from October 2024, it will ensure that ‘not at risk’ movements are also
freed of unnecessary paperwork, checks and duties. We feel it relevant to highlight the word ‘unnecessary’ in the previous sentence – the Windsor Framework is about reducing unnecessary checks, but some checks will remain. Government believes that the scheme significantly increases the number of businesses eligible to move goods ‘not at risk’ of entering the EU through three important changes: 1. All businesses established in the UK are eligible and will move away from the previous restrictions that required a physical premises in Northern Ireland. 2. Government will increase the turnover threshold below which companies involved in processing can move goods from the current £500,000 limit up to £2 million. 3. Even if businesses are above that threshold, they will be eligible to move goods under the scheme if those goods are for use in the animal feed, healthcare, construction and not-for-profit sectors. They will be able to do this even if they sell-on the eventual product to one subsequent entity in the supply chain, in a significant improvement to existing arrangements. Inputs into food production will continue to benefit from inclusion in the ‘not at risk’ definition. At the time of writing, it was envisaged that from 30 September the UKTS would no longer be used as the authorisation for moving ‘not at risk’ goods into Northern Ireland. Traders will need to use their new UKIMS authorisation. At this point it is relevant to emphasise that the UKIMS scheme is voluntary and that traders can complete normal frontier clearance
activities to clear goods into Northern Ireland if they so wish. Duty reimbursement scheme As a result of the Windsor Framework, the government is able to meet a longstanding commitment to bring forward a duty reimbursement scheme to allow traders to reclaim EU duty paid on goods that can be shown not to have entered the EU. This scheme was launched on 30 June and can apply to goods moved since 2021. Customs Duty Waiver Scheme From January 2024, the government will also be expanding the support provided to businesses through the existing Customs Duty Waiver Scheme. This will mean that in the New Year, the maximum value of duties able to be waived over the course of three tax years for ‘at risk’ goods moved into Northern Ireland will rise to €275,000 (~£235,000) from the current level of €200,000 (~£170,000). Moving goods from Great Britain to Northern Ireland - sanitary and phytosanitary products The Windsor Framework also sets out dedicated arrangements to support the critical flow of agrifood retail products into Northern Ireland. These movements are currently supported under the Scheme for the Temporary Agrifood Movements to Northern Ireland (STAMNI). STAMNI is being replaced in October 2023 by a new scheme, the Retail Movement Scheme. This will
“ The Windsor Framework is about reducing unnecessary checks, but some checks will remain
10 | October 2023
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Policy & Compliance
able to register their interest through a pre-registration process. The STAMNI scheme will remain in operation until these new arrangements enter into force. All existing members of the STAMNI scheme will be contacted directly regarding moving seamlessly to the new scheme. Trader Support Service As a core part of the Windsor Framework arrangements, the government committed to continue, via the Trader Support Service (TSS), to provide a free-to-use support service for those moving goods between Great Britain and Northern Ireland. BIFA is aware, and has advised government, that this decision is unpopular with many of our Members because the TSS funded by government can unfairly compete with commercial Customs agents. This is stifling the growth of an independent Customs intermediary sector. At the time of writing, we believe that all the information and timelines are correct. However
should there be any changes to the timelines we will publish information via our website Having spoken to Members, especially in Northern Ireland, clearly many just want to be allowed to run their business and have a stable trading situation in which to do so. At this point it is essential to highlight that whilst the Windsor Framework is an improvement on the Northern Ireland Protocol, it does not bring the benefits of the Single Market and Customs Union. There is still friction because there are still regulatory processes to follow, although the full impacts of these are not fully clear. Some Members may wish to read additional information, and this can be found at: QR code 1 The Windsor Framework - GOV.UK (www.gov.uk) QR code 2 The Windsor Framework - further detail and publications - GOV.UK (www.gov.uk) As an Association we anticipate a ‘soft’ launch to UKIMS as the next stage in launching the Windsor Framework.
be available to more traders and will provide a sustainable basis for these movements into Northern Ireland, removing unnecessary checks and complex certification requirements. It will allow goods made to UK public health standards to be moved, subject to certain requirements such as additional labelling. Formal registration for the new scheme was launched in September 2023. Traders have been
QR code 1
QR code 2
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October 2023 | 11
BIFA Awards
to the port required removal of obstacles, arrangement of permits and police escorts, levelling and compacting of pinchpoints, power and telephone cable lifting, and trailer technical checks and regular equipment maintenance,” Riley outlined. “To meet the ground-bearing capacity of the route, hydraulic axles were used to ensure adequate load distribution. Additional trailers were shipped from the USA, and deugro imported transport beams from the UAE and Asia to ensure sufficient support of the cargo saddles during transportation and offload at the jobsite.” Loading and unloading All units except the C3 tower were loaded at Kuantan Port by tandem lift using the vessel’s cranes. In order to position the 338-tonne C2 tower and the 600-tonne quench water tower on board, a crane boom support had to be temporarily removed. After safe arrival at the Phu My construction jetty, most of the components were stored at the Customs area before on-carriage. “While saving time and costs, this also increased flexibility in the delivery schedule of components in accordance with the construction site’s required sequences,” Riley pointed out. The cargo was moved to the construction site’s dressing area with self-propelled modular transporters (SPMT) and hydraulic trailers. The trailer configuration for the huge C3 tower required a reduction in the gradient of several areas of the jobsite. Lampposts and fences had to be removed, and several areas were reinforced to ensure the components could cross various underground services safely. In particular, said Riley: “The pipe rack area on the construction site was extremely tight for manoeuvrability, needing detailed inspections and engineering to design a safe transport path.” “The road around the pipe rack was compacted and levelled to provide the needed turning radius. Movement during the rainy season meant some site areas were waterlogged, needing civil works to be completed along with pumps and drainage to be installed so that the area adequately dried.”
deugro’s fl exibility and coordination were paramount in moving over 280,000 freight tons of petrochemical equipment to a petrochemical plant construction site in Vietnam while COVID-19 restrictions were in force, as recognised by the BIFA Project Forwarding Award 2022 Manoeuvring a 100 m C3 tower on a project construction jetty in Vietnam Coordinating the complex “ The safe movement of the components
F reight forwarder and project logistics specialist deugro arranged no less than 155 breakbulk shipments of critical oversized and heavy lift (OSHL)components, totalling 178,287 freight tons, on 55 heavy lift vessels that travelled a combined distance to Vietnam of more than 213,000 nautical miles. In all, the contract covered over 1,400 breakbulk, container and air freight shipments arriving at the petrochemical plant construction site from 30 points of origin. deugro faced numerous challenges in completing this complex project – not least, the widespread, ever-changing Covid- 19 restrictions in place at the time, which created a “dynamic” project logistics landscape with sudden schedule changes, noted Mark Riley, deugro UK branch manager. Other difficulties included high freight rates and severely limited vessel capacity. The only way to surmount such obstacles was through close collaboration between deugro’s project lead office and branches in 16 countries. The most challenging OSHL components, weighing over 778tonnes each and nearly 100 m
from the Kuantan yard to the port required removal of obstacles, arrangement of permits and police escorts
long, had to be moved from Malaysia to Vietnam at a time when suitable vessels were in short supply. deugro managed to contract six semi-submersible heavy lift ro-ro multipurpose dry cargo vessels, strengthened for heavy cargo. The 800-tonne, 93 m long C3 tower was transported by road 6km from the fabrication yard to Kuantan Port. The overland journey took 11 hours to complete. “The safe movement of the components from the Kuantan yard
– Mark Riley, deugro
Macbeth Insurance Brokers is extremely proud to sponsor the BIFA Project Forwarding Award. Whether your business specialises in freight by sea, air, road or rail, or handles specific goods, it can provide advice on applicable trading conditions and contractual obligations. Project Forwarding Award
12 | October 2023
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Membership
Reminder to all BIFA Members – BIFA Annual Membership Renewal
Renewal of BIFA trading membership for 2024 will begin in early November with a request for completion of the BIFA Annual Member Company Declaration being emailed to Members. This will be followed by 2024 Membership Renewal VAT Invoices in early January 2024. It is essential that any changes to key contacts, email addresses and location addresses are notified to BIFA ahead of the renewal process in order to ensure that messages are delivered correctly. Please email Sarah Milton at s.milton@bifa.org with any amendments. This is also the perfect time to log-in to the new BIFA website Member portal. The individual listed as the main contact for each BIFA Member can now manage their organisation’s details and update branch information, thereby ensuring that this information is always up-to- date. This is the fourth year that electronically. This has been well received by Members as an improved method to renew their BIFA and FIATA Membership. Did you know that you can pay for your BIFA Membership via Direct Debit? This payment BIFA is processing the membership renewals
method eases cashflow as payments are deducted 50% in January and the remaining 50% in July. Should this be of interest to you, please contact Sarah Milton s.milton@bifa.org who will be able to set this up. Please note: • Company Declarations need to be returned no later than 8 December 2023. • Membership Renewal VAT Invoices – will be issued early January and payment is required within 30 days. • Members who subscribe to direct debit membership renewals – please note that your VAT invoices will be emailed 5- 10 days prior to the direct debit being applied for (payments are applied for mid-January and mid- July each year). Should you have any questions, or require any database updates, please contact Sarah Milton – BIFA Membership Supervisor s.milton@bifa.org BIFA would like to thank you for your subscription and looks forward to supporting you through 2024.
Transaid update April 2022-March 2023 As a proud supporter of Transaid, BIFA is delighted to share its latest activity report. In the period 1 April 2022 - 31 March 2023, Transaid has continued to focus on working with partners to improve road safety, professional driver training, and access to healthcare in sub-Saharan Africa. Transaid’s mission to transform lives through safe, available and sustainable transport remains at the forefront of all their programmes. Scan the QR code to view the video report.
October 2023 | 13
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Policy & Compliance
The Border Target Operating Model: A missed opportunity? The recently published Border Target Operating Model sets out how controls will be simpli fi ed and digitised over the year ahead, which are explained here. However, there are a number of reasons for traders to be concerned, as explored here by Robert Windsor
O n 29 August 2023, the government published the fi nal Border Target Operating Model (BTOM) setting out a new approach to security controls (applying to all imports), and sanitary and phytosanitary controls (applying to imports of live animals, animal products, plants and plant products) at the border. It sets out how controls will be simpli fi ed and digitised, and the government’s ambition for the UK’s new Single Trade Window, which is still under development. Before its delayed release, there had been much comment on the reasons for the delay and what would be contained within the BTOM when published. The reader found it a disappointing document; there is very little new within it although it has expanded from 67 pages, containing 228 paragraphs, to 97 pages with a total of 392 paragraphs plus numerous appendices. In many ways the document is as expected – more of a policy document than an operational guide. The document faces two ways at once – trying to finalise the last and perhaps most complex issues remaining for the UK’s withdrawal from the EU, whilst there is a clear attempt to set a direction of travel by modernising certain frontier activities via the
implementation of the first stages of the Single Trade Window (STW). Importantly the document covers Britain’s trade and associated controls for the UK’s global trade, not just trade with the EU as previous documents such as the Border Operating Model (BOM) did. Global trade It is suggested that Members familiarise themselves with the BTOM’s contents and where to find the most important information, particularly those engaged with trade in SPS goods to/from the EU. Government intends to implement the model through three major milestones, which are as follows: 31 January 2024 – The introduction of health certification on imports of medium risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the EU. The removal of pre-notification requirements for low-risk plant and plant products from the EU. 30 April 2024 – The introduction of documentary and risk-based identity and physical checks on medium- risk animal products, plants, plant products and high-risk food and feed of non-animal origin from the
“ It is suggested that Members familiarise themselves with the BTOM’s contents and where to fi nd the most important
14 | October 2023
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Policy & Compliance
for animals are set out below. These include lower check rates for some types of high health equines (eg racehorses) from low-risk countries, some zoological animals and some live aquatic animals. • Import of consignments categorised as medium risk will require pre-notification, simplified health certificates, documentary checks and be subject to risk-based identity and physical checks at the border. Some will be set at 1% physical and identity checks, although other goods will be considerably higher based on specific risks. A Trusted Trader scheme for medium-risk consignments will be piloted. • Import of consignments categorised as low risk will have minimal routine border controls applied. There would be no requirement for health certification or routine physical border checks, although there will be provision for intelligence-led intervention on low-risk products. Provision of a pre-notification data set and commercial documentation will be required for all low-risk animal products. Goods classified as low risk would still need to enter via a port that has a Border Control Post designated for that type of commodity Aligned with the above approach, traders will have the opportunity to join the appropriate pilot scheme with a view to becoming a Trusted Trader. The proposed Accredited Trusted Trader Scheme (ATTS) is a single modular framework that will provide businesses with flexibility and choice in how they engage with the Trusted Trader approach. Businesses will be able to build a package of facilitations that aligns with their specific operational needs rather than needing to engage with a one-size-fits-all solution. It is envisaged that one significant advantage for traders accredited to a Trusted Trader Scheme will be fewer frontier checks and inspections. However, the trader will have to ensure standards equivalent to those at the frontier. This effectively shifts greater responsibility, albeit under government supervision, onto the private sector for border control and in particular biosecurity. For traders involved in moving plants under the Authorised Operator Status (AOS), it is proposed that a trader, with appropriately trained personnel and internal control systems, can achieve authorisation, meaning their level of expertise is sufficient to perform physical and identity import checks. However, this authorisation scheme needs to be piloted to evaluate feasibility, both for the trader’s operational competency and biosecurity risks. The aim is for this scheme to be adopted on a Great Britain-wide basis. Trade with the island of Ireland When reading the document, one point that stands out is the level of agreement between Whitehall and the devolved governments, which is particularly important when considering the controls to be introduced on imports from Southern Ireland and non- qualifying imports from Northern Ireland. Many of those goods enter the Great Britain mainland via Welsh ports. From 31 January 2024, movements from the island of Ireland will face full Customs controls and the requirement for pre-notification and certification when
EU. Existing inspections of high-risk plants/plant products from the EU will move from destination to Border Control Posts. Simplification of imports from non-EU countries will also begin. This will include the removal of health certification and routine checks on low-risk animal products, plants, plant products from non-EU countries as well as reduction in physical and identity check levels on medium-risk animal products from non-EU countries. 31 October 2024 – The requirement for Safety and Security declarations for imports into Great Britain from the EU, or from other territories where the waiver applies, will come into force from 31 October 2024 as set out in the original Target Operating Model (TOM). Alongside this, a reduced dataset for import Safety and Security declarations (ENS) and use of the UK Single Trade Window will be introduced to cut the duplication of data being input. Effectively, the three-month delay in publishing the BTOM is reflected in the first two dates referred to having been deferred by the same period. It should be noted that the last date of 31 October 2024 remains as published in the draft TOM. In other words, trade has lost three months of the originally planned implementation period. The document re-affirms the move to a risk-based approach for managing the importation of SPS goods including animals, fruit and vegetables, and processed foods. According to the BTOM, document controls will be applied to such goods proportionately based upon their risk categorisation: • Import of consignments categorised as high risk (predominantly live animals, germinal products and goods under safeguard measures) will require pre- notification, simplified health certificates, documentary checks, and identity and physical checks at the border. In most cases, live animals will be subject to 100% identity and physical checks. Some exceptions to the requirement for 100% checks
“ It is envisaged that one significant advantage for traders accredited to a Trusted Trader Scheme will be fewer frontier checks and inspections
October 2023 | 15 Continued on Page 16
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Policy & Compliance
government’s definition of an operational system and trade’s. Once government has delivered an operational system, commercial software developers will need additional time to develop the relevant systems to operate in conjunction with the STW. It is the latter date on which the true operational start date should be based. More concerning, although statements in the BTOM indicate that this issue is being addressed, is that in the demonstration model all data was manually input. This has been addressed in the sense that frequent reference is made in the BTOM to providing an Application Programming Interface (API) to software developers, which is to be welcomed. But how the STW is going to interact with Community Service Provider (CSP) systems which control payments and inventory systems is less clear. This raises the possibility of government’s attempts to improve one element of border flows having a negative impact on other processes, particularly inventory control and release. Publicly, BIFA has raised questions regarding the present arrangements for inspecting freight at Port Health Authority (PHA) manned Border Control Posts. Members have expressed concerns, which have been re-stated in public about payment procedures to secure cargo release from potentially multiple different local authorities, all with different charging levels. BIFA believes that there needs to be a centralised portal linking the different PHAs to simplify payment arrangements. One area of particular concern is that there is still a lack of clarity regarding the provision of inland Border Control Posts in Kent for goods entering via the port of Dover or Eurotunnel. The BTOM states: “A decision will be published soon on the future of both Sevington and Bastion Point Border Control Posts.” BIFA has publicly criticised this indecision and also the Common User Charge, which it is proposed to charge for each consignment eligible for Phytosanitary checks entering via the Port of Dover or Eurotunnel. The suggested charge is between £20 and £43 per consignment; however, there needs to be yet another consultation on the level of charge. Also there needs to be resolution as to how and when the fee will be collected. The logical point is when the IPAFF (Import of products, animals, food and feed) system declaration is made, but then government will have to introduce a mechanism to remit monies to the relevant PHAs. BIFA’s last and biggest criticism of the BTOM and STW, because they appear to be closely linked, is that it is a missed opportunity. Government performance at the border is frequently criticised; one particular complaint is the slow response time compared with authorities in other jurisdictions when resolving issues. This problem has a variety of causes but the difficulty in contacting officials in person to resolve a problem, is cited as a significant issue. It is important at this stage to point out that whilst compliance with the controls set out in the BTOM will be mandatory, the use of the STW, at this moment in time, is voluntary. If nothing else, it is clear that government is still actively trying to improve how the frontier operates. The BTOM is a policy document, not an operational handbook – and one of our main aims will be to clarify how these policies will work in practice.
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moved directly from Ireland via Irish ports to Great Britain. All ports will be required to apply full Customs controls to non-qualifying goods and goods such as excise goods moving from Ireland to Great Britain, meaning that these goods must have a valid declaration and be Customs cleared to be able to proceed to their destination. Government intends to implement the model through two major milestones: 31 January 2024 i. The introduction of pre-notification requirements (except for low-risk plants and plant products) and full Customs controls. ii. The introduction of health certification on imports of medium-risk animal products, plants, plant products and high-risk food and feed of non- animal origin from the EU. From 31 October 2024 i. The introduction of documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products and high- risk food and feed of non-animal origin from the EU. ii. The requirement for Safety and Security declarations for imports into Great Britain from the EU or from other territories where the waiver applies will come into force from 31 October 2024. Alongside this, a reduced dataset for imports will be introduced. In conclusion, certain elements of the document are forward thinking and set a clear direction of travel, particularly relative to the STW. However, this is a potential weakness because many of our future frontier processes appear to be reliant on a system still in its design phase and thus unproven in the real world. Having seen the Great Britain Safety & Security system in operation via the STW, there are elements to commend it, certainly for the small user. However, the mistakes of CDS are being repeated because once again access is via the Government Gateway – which caused significant problems when the first mentioned service was introduced. This time the issues may be multiplied because data filing by more than one trader is envisaged – leading to the question how will this be facilitated? Also, given the history of IT projects, the timelines for implementing an operational STW are very ambitious. We have to be cautious to differentiate between
“ In conclusion, certain elements of the document are forward thinking setting a clear direction of travel, particularly relative to the STW
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www.bifa.org
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