BIFAlink November 2021


Policy & Compliance

Revised timetable for new Customs and DEFRA procedures

On 14 September, one day before an event organised by BIFA and supported by DEFRA, HMRC and French trade representatives, the UK government announced some significant delays to the UK’s timetable for implementing new frontier procedures. The main delays are to the implementation of checks on sanitary and phyto- sanitary (SPS) goods and the requirement for an import safety and security declaration for goods shipped from the EU. The reasons given by government for the delays were that COVID-19 had had greater impact on industry than anticipated. Industry’s view is that government is not fully prepared, noting in particular that in Kent the Border Control Posts (BCPs) had not been finished nor adequate staff recruited. Also, there is anecdotal evidence that EU exporters, particularly of foodstuffs, are struggling to comply with the new regulations. One area that is attracting particular attention is the shortage of vets to inspect Product of Animal Origin (POAO) shipments and complete the Export Health Certificate. Members have expressed concern regarding the availability of vets, particularly in the out-of- hours environment. Members have expressed mixed views on the delays, some noting that they have prepared for the changes in line with the original timetable and that they are being unfairly disadvantaged due to the delay. The reader should note that the initial Stage 1, impacting mainly exports from the EU to the UK, was implemented on 1 January 2021. Stage 2, as detailed below, has now been implemented. Stage 2 – 1 October 2021 The UK government has blamed COVID-19 for delays to the implementation of new Customs and DEFRA procedures, although industry has noted that the government has not finished building and staffing its Border Control Posts

• On 1 October 2021, the requirement for an Export Summary Declaration for goods being exported from the UK to EU under a ‘Contract of Carriage’ is implemented.

It is no coincidence that the most difficult to implement changes have been delayed the longest. On SPS goods, at least, there is an understanding of procedures and responsibilities; the main concerns relate to complexity of shipping such goods within a tight timeframe and release procedures at non- inventory linked ports. The concerns about import Safety and Security declaration run much deeper with fundamental fears regarding the fragmented ro- ro sector’s ability to process such declarations. BIFA will keep Members updated as to developments. Particular attention is drawn to the withdrawal of certain easements such as Delayed Declarations from 1 January 2022. One outcome of this is that all import consignments will have to be declared to Customs at the frontier. In many ways, implementing the import timetable, as detailed in Stages 2 to 4, will be much more difficult than the export controls enacted under Stage 1. Given the wider problems in the UK economy for many, it was a welcome decision; however, implementation of the new procedures cannot be delayed indefinitely.

Details of the revised timetable are: Stage 3 – 1 January 2022

• The requirement for pre-notification of agri- food imports will be introduced on 1 January 2022 as opposed to 1 October 2021. • The Delayed Declaration System ends, and all shipments will require a frontier Customs declaration (full or simplified). • Goods Vehicle Movement Service (GVMS) becomes mandatory for all ro-ro movements via a non-inventory linked port. Stage 4 – 1 July 2022 • The new requirements for Export Health Certificates, which were due to be introduced on 1 October 2021, will now be introduced on 1 July 2022. • Phytosanitary certificates and physical checks on SPS goods at Border Control Posts, due to be introduced on 1 January 2022, will now be introduced on 1 July 2022. • The requirement for Safety and Security declarations on imports will be introduced as of 1 July 2022, as opposed to 1 January 2022.


November 2021

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