BIFAlink April 2022

Robert Keen’s Column

BIFAlink

www.bifa.org

Concern over self-declaration proposal

BIFAlink is the official magazine of the British International Freight Association Redfern House, Browells Lane, Feltham TW13 7EP Tel: 020 8844 2266

It is often said that “history repeats itself” or “there is nothing new under the sun”. On page 8 you will find an article written by my colleague Robert Windsor about a proposed ‘Single Trade Window’ to government, the concept of which I first came across in 1998 when I was the HM Customs and Excise (nowadays HMRC) resource for a freight software house. I attended a number of consultative meetings between 1998 and 2003 about the Single Trade Window concept, and here it is coming around again. This time, however, there are considerable resources being made available by government in a drive to reduce so-called red tape. There has been a fear expressed by some BIFA Members that this is the beginning of the end of Customs entry work, but it is my view this will not happen.

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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

Before the Single Trade Window, some of the older ones among you may recall something colloquially known as ‘The Rickwood Report’ in the mid-1980s. Mike Rickwood was a senior officer at HMC&E who advanced the theory that well over 90% of businesses are legitimate so why not allow them to report imports in the same way that they complete a VAT return. It was too radical at the time, although I for one was worried that it was going to be the end of Customs brokerage. Of course, there was Period Entry which became EIDR and CFSP (now SDP), but until now most importers have not wanted to do their own entries. As technology improves, it is a logical step to offer traders this option but, in my experience, traders will always look to their forwarder to be an intermediary between them and HMRC. An old boss of mine often used to say that if you banned forwarding you would have to re-invent it the next day. There is often talk of disintermediation and although there have been many changes with online transactions in business, there is no obvious trend for importers to switch from forwarders and complete Customs declarations themselves. The potential of self-declaration of border data into the Single Trade Window is seen as detrimental to our sector and I encourage you to read the article and respond to the government consultation. The latest proposal for a Single Trade Window will be seen by many as another potential source of supply chain disruption if it is not created and managed properly. Whether it is the infamous pandemic, a ship stuck in a canal, cyberattacks, unprecedented swings in customer demand or territorial conflicts, it has become increasingly obvious over the last few years that it is a question of ‘when’ and not ‘if’ your business will feel the impact of supply chain disruptions. The old adages ‘Prevention is better than cure" and ‘A stitch in time saves nine’ are more relevant in the supply chain today than at any other time. Real-time visibility and transparency in supply chains could be the potential answer to mitigate supply chain disruptions, capable of saving you time, money and eventually your business. As I was writing the conclusion to my column for this issue, I got a sense of deja vu with the news that China’s zero-COVID-19 strategy has seen major cities lockdown in response to a surge in cases during March. Shanghai and Xi'an have implemented lockdown measures, while the port city of Shenzhen started a seven-day full lockdown on 14 March. Last year, a COVID-19 outbreak at Shenzhen’s Yantian port sent shockwaves through the supply chain. This time round, ports and terminals are said to be operating normally, but with landside logistics impacted there are bound to be implications for global trade. According to media reports, due to lack of labour, things were slower and less efficient. Individuals, especially truck drivers, had to show negative tests at checkpoints and when crossing city borders. The situation only served to exacerbate delays and create bottlenecks, adding further pressure to an already tense supply chain. Hopes that this year would see a stabilisation of rates, an opportunity for forward planning, or even a return to something close to normal are quickly dissipating, and as it stands now, 2022 has shaped up to be another year of firefighting for those managing international supply chains.

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, Nezda Leigh 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

April 2022

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