BIFAlink
Policy & Compliance
www.bifa.org
sector well, that is less so in the overland arena. Relative to EU Exit, BIFA wonders whether too many of the policies have been designed to appeal to too many parties and have caused confusion. One example was the last-minute decision to allow GVMS to operate at inventory-linked ro-ro ports; another is clearer messaging to drivers provided by the French Logistics Envelope system. BIFA is concerned that trucks are regularly delayed for up to three days whilst relatively simple queries are resolved. Members frequently complain about a lack of trained staff and confusion regarding who to report to at an IBF. Concerns also remain over the handling of cargo where an importer’s Deferment Account limit has been exceeded. For goods in a warehouse awaiting clearance this is relatively simple, but this becomes more complex when a truck driver wants to deliver cargo to complete their journey. Reports suggest that freight is often offloaded, with no receipt given for the cargo at the IBF. Non-compliance There is also a strong belief that non-compliance is being under- reported. Queues at Dover over the weekend of 21-22 January indicate that all is not well with the new systems. Members have swiftly realised that manually arriving an entry with RRS01 creates a false impression that the consignment has been correctly auto- arrived when, in fact for whatever reason, it has not. The other problems we are being advised of relate to the functioning of the system. For whatever reason, it does not function as expected and on occasion does not seem to process data or generate outputs in the manner expected. One such problem reported to us was that the system failed to facilitate the automatic generation of S8s for goods being exported from ‘pre- lodgement locations’. Many exporters rely on it as the primary evidence of export to support the zero-rating for VAT purposes of export consignments. It is possible to print screen shots of the export declaration (EXD) and send commercial documents to support the zero-rating, but this increases the freight forwarder’s workload. BIFA Members who have addressed the new operating environment early, for instance by raising the GMR themselves and controlling the whole movement, appear to be encountering fewer issues than those who are allowing the haulier to raise the movement reference. From the 1 July 2022, the extra requirement to raise an ENS prior to moving goods from the EU to UK has to be considered. Members are asking BIFA the following questions about GVMS: Who will do it? How will it be done? What information will be transmitted? And to whom? At the moment freight forwarders are endeavouring to make GVMS function properly but are encountering considerable difficulties. Some of these are the result of initial incorrect policy decisions, allocating functions to the wrong party within the supply chain and implementing GVMS without adequate testing and familiarisation. In the short to medium term, GVMS will need to be upgraded to provide better functionality. We have already seen a small step in the right direction with an upgrade which now indicates which IBF a driver should attend when an inspection is required. BIFA is now urging government to take heed of the lessons learned during EU Exit when developing new systems, such as the Single Trade Window.
have become aware of them ignoring a ‘Inspection Required’ message, or the manual arrival of goods has led to a Customs intervention. BIFA continues to receive reports of drivers reaching their depots with uncleared goods on board, including firearms and pharmaceutical products. This is leading to an unusual situation where the customs agent/freight forwarder is having to undertake roles that either HMRC or Border Force should be fulfilling. This is further evidence that the design of Customs and other regulatory systems should be based on the knowledge of people who have practical experience of frontier freight flows. Another important point to stress is that from 1 July 2022, an import safety and security declaration (ENS) will be required; the truck operator is the party legally obliged to submit this, which is much more complex than a GMR. Whilst the haulier can allow a third party to submit the ENS, the legal obligation to ensure that the declaration has been submitted remains with the former, which many see as an unrealistic proposition, and an additional workload that the sector is inadequately prepared to handle. Forwarding processes are complex, especially where they interact with government systems, and whilst Customs procedures and the supporting IT systems, which were largely set by the European Commission, serve the air and maritime
A frequently reported issue is that hauliers are failing to report to Inland Border Facilities as required
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March 2022
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