Our Customs Journey Since BREXIT

Maxi has been well prepared and tried to always get in front of any customs changes both from a knowledge and systems point of view.

What started as an added value service for customers has now become a successful part of our haulage business and an area which is growing and add further knowledge to.

We operate 24/7 and help all our customers with research and implementation

 

2021 – Leaving the EU

Article 50 was triggered in March 2017 which started the process of our withdrawal from the European union after multiple delays due to negotiation Brexit as we know it started on January 1st, 2021.

This was an incredible change to the way we as a transport company operated between UK-EU-NI, there were challenges that we overcome and there was needing to be a change of mindset within our business with additional documentation and references in order to ship goods.

Overnight the huge stock piling to Ireland suddenly stopped and the market declined into Dublin by up to 70% in the first weeks.

 

ROI – 2021

ROI requires stages to be completed for the goods to ship, these stages are below and once all completed, they will each give you a unique reference number:

UK Export – this tells the UK government what goods we are shipping out of the UK, the information that you need to tell the system is basic. There are no requirements for in depth details regarding the goods such as exemption codes, gross weights, Ferry IMO number and arrival time etc. These were not compulsory to do until 1st of Jan 2022 however we have done since day 1.

AIS Import – this tells ROI what goods they are receiving in detail, in this process you will need to include commodity codes, exemption codes, gross/net weights (Customs are move focused on the net weight) good description, item invoice amount, who is paying the duty, VAT terms and additions/deductions which includes things such as if the VAT is to be postponed or not.

We also found at that stage multiple additional document codes were needed which with the help of customers were quickly turned around and shipped goods successfully

ENS – this is a simplified entry & safety and security documentation this is needed when a non- European goods enter a member of the EU state, it is very similar to the export document it needs very limited information however the reference number that this generates is highly important as this will be needed when creating the PBN

 

PBN (pre boarding notification) – the PBN is the last link between completing the Customs information you have put together and the goods sailing. To get this PBN reference number the system requests the AIS import and the ENS references numbers. Once you have these it will generate a unique code that will be needed alongside the sailing reference once the driver arrives at port. The creation of this code is the responsibility of the haulier even if a 3rd party broker is used to create the UK export/AIS import and the ENS.

 

Outage of Customs system

On occasions the system had outages, this would involve where one or maybe all the processes needed to complete a declaration would become inoperable mainly due to HMRC / Irish Revenue updates and some of those updates not working.

When this would happen, we would receive messages stating we are to ship loads in what was called ‘fall back’. This would mean we state on the PBN that this trailer is empty, this would then allow the goods to be moved. This would seem a solution, however the import documentation then needs to be retrospectively submitted before the trailer is released.

Where we have errors and delays, we would not send a driver to port without all the correct customs paperwork completed. Meaning we would need to route a driver to a Maxi Haulage depot to keep the goods in safe locations.

Where fallback position has not need implemented, this would lead to several trailers stored at Maxi locations adding additional cost and operational constraints

 

Moving Goods to Northern Ireland Jan 2021

Goods moving via Northern Ireland to reach ROI.

During 2021 there was an increased amount of goods for ROI that were routed via Northern Ireland. However, added huge demand to the northern Irish shipping market with no extra capacity meaning those companies without block bookings or relationships with shipping companies were unable to ship into northern Ireland. As customers become more aware of the rules this then switched to sailing through ROI as the year went on due to customs issues becoming easier to resolve.

Jan 1st 2022 has caused some customers to temporary switch back to more goods moving through NI.

The main issue surrounding this is commodity codes of products. HMRC’s commodity codes are not matching up with those for Irish revenue meaning when the information is being inputted into an Irish import the system can not tell what product it is.

 

Dublin Customs

When our trailers are required for inspection, we firstly look to see which agency has required the goods. After finishing our first year of offering a customs service we have found the best approach is to react fast and efficiently in order for the goods to be cleared as quickly as possible.

Agencies can request anything from proof of the country of origin to providing a veterinary certificate. As soon as these are sent on and inspected, they can be released and changed to cleared status. However, this does not stop any other agencies from also wanting to inspect the goods.

Documents also need to be sent VIA the AIS system by uploading copies of commercial invoices and packing lists. We have found this reduces the number of calls to customs as the authorities can see the information match declarations.

 

POAO – CHEDS / TRACES ENTRIES

 

Half way through 2021 the next big change Products of animal origin and composite products this meant that before shipment a traces entry needed to be submitted and provide 24 hours pre notification of the products arriving.

For more complex products the supplier requires a Vet to sign the goods off and watch them being loaded onto a trailer at a time that we both agree upon, this has caused issues for both parties, especially when ourselves have previous deliveries with full/part refusals. We have managed to get around this obstacle by offering a dedicated service reducing the risk of previous Refusals and wasting a vets time.

 

When completing a traces entry a CHED documents (Common health entry document) would be created are needed for certain products so we can give prior notification of the arrival into Dublin. Furthermore, there are private attestations which suppliers complete with the product information which are sent as part of the pre alert process.

 

NI – 2021

Transporting goods to Northern Ireland is a much shorter process, it has two steps. creating a ENS via the Trader support service which when completed will allow you to create a GMR through the GVMS website.

Creating An ENS via TSS (trader support service) – We create a simplified document which only needs the basic information such as trailer number, net weights, and delivery point. This will then create reference number which will be used in the GVMS website to create a GMR.

 

Creating a GMR – once we have completed creating a GMR we will continue through the steps required on the GVMS website, this includes questions such as how the trailer will be put onto the sailing to others such as will the trailer be accompanied/unaccompanied. Once we complete these stages, we will be asked to add in the MRN number which in turn will then generate a unique reference number. This reference number along with the shipping reference will be needed when entering the port. If the GMR is rejected by the port the goods will not be allowed to sail, until resolved.

 

2022 – changes NI

From January 1st, the format of completing a North clearance changed slightly, instead of using the ENS number to create the GMR. Although for the first week of the new year this system was not working, this has since been rectified. We now use a MRN (movement reference number). This is generated when we complete the ENS. We then use this reference number in the GVMS website to create the GMR.

From July 1st, 2022 further changes were meant to happen however such as:

 

  • Requirements for full safety and security declarations for all imports
  • New requirements for Export Health Certificates
  • Requirements for Phytosanitary Certificates
  • Physical checks on sanitary and phytosanitary goods at Border Control Posts

 

However these were postponed

 

2022 – Changes- ROI

 

With the further changes made to move goods the inclusion of a GMR was needed for all goods moving to the EU.

GMR/GVMS system – this is a good movement reference that is created on the GVMS (goods vehicle movement service), up until 1st January this was only used for goods moving to Northern Ireland. We now require a GMR as well as export/import/ENS/PBN for all loads to ROI, the GMR requires a unique reference number (this is known as the DUCR reference) which is generated when completing the UK Export. The issue we have been having from some suppliers who use external have not included a code RRS01, adding RRS01 into the UK export acts as a validation code for the GVMS system and without it the system will throw back an error message stating the reference cannot be found. When this happens, we need to get in contact with the 3rd party who will then rectify the issue.

 

Temporary warehouse status (Maxi Haulage Warwick)

During 2021 Maxi Haulage was granted temporary warehouse status, this meaning that goods can arrive in the UK from the EU (to Maxi Haulage) without paying any duty before proceeding onto ROI.

We have also authorised consignee status meaning vehicles can come into our facility we can close the transit documents then create another transit when ready to move onwards again without attracting any duty

This has been a long project and have had many hurdles to cross in order to get approved but have our first customer ready to use this service in the near future

 

Further changes to come both from the 1st October 2023

 

UK Import Controls 2023 – The Border Target Operating Model ( TOM) – affecting imports from ROI into the UK

 

These new controls will have implications for all Irish exports to the United Kingdom, excluding Northern Ireland. In particular exports from the agri-food sector will subject to pre-notification and accompanied, in some cases, by export health and phyto-sanitary certificates.

As per the Northern Ireland Protocol and Windsor Framework, there will be no changes to moving goods between Ireland and Northern Ireland.

As always this will be a phased process with certain dates below affecting certain product groups

1- 31 October 2023

  • Export health certificates and phytosanitary certificates will be introduced for medium risk animal products and plant and plant products imported and High Risk Foods of Non-Animal Origin (HRFNAO) to GB from the EU.
  • Full customs controls will be introduced for goods moving directly from Ireland into GB ports.
  • UK import declarations will need to be pre-lodged and goods moved from the island of Ireland will become subject to checks and controls.

 

End of 2023

Permanent waivers will be introduced removing the requirement to submit Safety and Security declarations for the following low risk movements:

  • Fish /outbound transit /outbound freeport goods.

31 January 2024

Documentary and risk-based identity and physical checks will be introduced for the following medium-risk products from the EU:

  • animal products / plants / Plant products

31 October 2024

 

  • Safety and Security declarations for EU imports will come into force from 31 October 2024. A reduced dataset for imports will remove duplication where possible across different pre-arrival datasets – such as Safety and Security, SPS, and pre-lodged customs declarations.

 

Windsor Framework for UK – NI Movements

 

On 27th Feb 2023 the UK & EU agreed the Windsor Framework – providing a new set of arrangements to try and protect key areas

 

  • Maintain Flow of trade with the UK internal Market ( trying to remove burdens of east and westbound trade also help with some of the more complex product movements such as fresh meat)
  • Safeguard Northern Ireland place in the union

 

The Framework is a being rolled out in a phased approach with the final phases happening into 2025

 

The key changes affecting Maxi and our customers which we are in constant dialogue with are:

 

Introduction of the Northen Ireland Retail Movement Scheme from 1st October 2023 ( ReMos)

This scheme replaces the STAMNI scheme with was a temporary measure to help keep the flow of Agrifood and more complex lines of product moving.

ReMos will operate a Red and Green lane policy meaning traders who comply with the Green lane will be subject to a lot less checks upon importing into NI.

Where as the traveling via the red lane would mean further checks and border delays

 

To be in the Green lane traders have to comply with labelling requirements with products having a NOT FOR EU label as well as having a end to end seal process for the load travelling to NI from the UK to prove the load has not been comprised while travelling

We are working closely with customers to guide through this process based on their individual products which fall into this scheme.

 

In September 2024 the HMRC red and green lanes will also become introduced which will be based around any products attracting DUTY / VAT payments

 

As the Windsor framework interpretation is changing all the time we will update on further changes over the next few months

 

If anybody would like specific information on the Windsor Framework or general customs enquiries, please get in touch by email or Phone

 

timrutter@maxihaulage.co.uk

01925 605 790