The past year has been a period of adaptation to a post-Brexit trading environment, where businesses on both sides of the Channel have worked hard to get to grips with the operational changes that came after the end of the transition period. Trade is now looking to embrace another portion of changes in GB’s relationship with the EU. As of 1 January, which is in two weeks only, full customs controls apply to all goods moving between the EU and GB, along with additional pre-notification requirements for certain SPS shipments.
Only on Wednesday, the UK Government announced a further postponed introduction of post-Brexit border controls on goods moving from the island of Ireland to GB. While emphasising the importance of finding suitable arrangements for the implementation of the Irish Protocol, CLECAT notes that the continuous delays in decision-making and postponement on the phasing in of the Border Operating Model bring instability and uncertainty to trade.
From early on in the process of the UK’s departure from the EU, European Freight Forwarders and Customs Brokers have been prepared to support their Customers, and an as smooth as possible flow of goods. However, whilst reflecting on readiness of Supply Chains, it seems that the lack of preparedness of Hauliers and smaller traders for the upcoming new formalities and procedures remains, along with the somewhat familiar crippling fear that the new year will be met with operational chaos.
To ease the introduction of customs controls, the UK government decided to phase in customs requirements for GB imports from the EU, which was subsequently delayed at two occasions. While these postponements of customs controls allowed economic operators more time to prepare, CLECAT stressed the need for businesses to make the best use of the additional time, rather than ‘kick the can down the road’, multiplying the risks of disruptions at the border. CLECAT members have observed, however, that the extra time has not always been used wisely. Not only are Hauliers and smaller traders not fully ready to deal with the new requirements on 1 January 2022, but many of them are also still trying to get to grips with the changes that came on 1 January 2021. CLECAT stresses that a lot of work remains to be done to boost awareness and readiness, urging Shippers and Hauliers to take all steps to ensure that they are ready for new EU-GB border requirements from January 2022.
CLECAT and its members have engaged constructively with the UK HMRC and commend them for effective communications with Supply Chain stakeholders to support readiness. However, we are noting existing uncertainty at operational level and that the UK government still needs to sort procedural and IT details in preparation for taking control of its borders. Some of the main issues that remain for the industry relate to, among others, IT implementation and associated requirements and processes, particularly concerning the Goods Vehicle Movement Service (GVMS), confusion over different port models (pre-lodgement and/or temporary storage), as well as lack of understanding of the different responsibilities and liabilities of Supply Chain stakeholders. Furthermore, sufficient clarity regarding the SPS goods that will be subject to the new pre-notification requirements is still missing.
CLECAT recognises the pressures businesses face in coping with the impacts of the COVID-19 pandemic and Brexit simultaneously, as well as the lack of complete clarity on some operational details of the upcoming requirements for EU-GB trade. Adjusting to post-Brexit trading environment is a learning curve, that needs to be approached in a flexible and pragmatic way, to help rather than penalise economic operators in the ongoing transition.
CLECAT stresses that notwithstanding the lack of complete readiness in the private and public sector, further delays in the implementation of the Border Operating Model should be avoided. Another delay would only mean postponing what is inevitable, leading to further confusion.
CLECAT are the European Association for Freight Forwarders & Customs Brokers.
IIFA is Ireland's National Association Member of CLECAT.