The responsibility for completing up to 37 lines of information, much of it duplicating the customs entry details, lays with the haulier, not the importer or customs clearance agent, instantly paving the way for post clearance arguments about who delayed deliveries and incurred demurrage due to failure to complete adequate documentation.
Hauliers will need to obtain all needed information from exporters and importers, add small amounts of data relating to the lorry and trailer, and then submit the full data set as a new declaration to HMRC, and the information must be logged with them one hour prior to arrival in the UK. The image conjured up is of drivers cutting short their official rest breaks whilst travelling on UK bound ferries to ensure they will be allowed out of the port of arrival.
Credit for the HMRC announcement was claimed by both the Road Haulage Association (RHA) and the Freight Transport Association (FTA) but it is true to say without the expert guidance of both of these, plus input from other similar bodies such as BIFA and the UKWA, the picture would be even more gloomy. In any event it appears the six month moratorium has nobody exactly jumping for joy.
For its part the RHA continues to call for massive simplification of the declarations after the six-month suspension. It points out that government authorities will obtain the data on all shipments from other sources anyway and says demanding a repeat of the same information, as currently planned, to meet unnecessary bureaucratic specifications is both wrongheaded and inappropriate. Elaborating, RHA chief executive, Richard Burnett said:
“It is clear that Government has listened to us. We have been insistent that the proposal to introduce consignment level Safety and Security Declarations for imported road haulage would be impossible to introduce by 29 March. The extension will help but it still isn’t enough, there is no guarantee that businesses will have the necessary processes in place in six months’ time.
”It’s just a stay of execution. We need practical simplification of the system to ensure that it works for everyone and we will continue to push for this. However, the issue of goods leaving the UK and entering the EU by road remains. As things stand the demand will also be for consignment level declarations for these road-based movements.”
Meanwhile FTA's Head of Global & European Policy, Pauline Bastidon, was quick to illustrate her organisation’s role in prompting the government’s action, saying:
"Today's HMRC announcement on the temporary waiver of security and safety declarations for post-Brexit logistics movements is a great response to FTA's campaigning over the past two years, and a positive step towards minimising disruptions on trade between the UK and EU and integrated supply chains after Brexit. However, it is imperative that the UK government maintains pressure on the EU to ensure that a similar waiver is adopted by the EU.
”To ensure that Britain can keep trading efficiently, it is vital that the European Commission and UK agree a longer term, more sustainable arrangement to remain in the same security zone, which would make safety and security declarations for UK-EU trade irrelevant. Above all, it is vital that the UK's supply chain remains as frictionless as possible, British business needs to be confident that goods and materials will continue to transit the nation's borders as swiftly and efficiently as possible."
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