The COVID-19 pandemic has posed challenges that none of us could have predicted at the start of 2020 and, while the freight distribution and logistics sector has reacted with resilience to keep Ireland trading, it is now time to focus on recovery and the next issue facing our sector; Brexit. While nobody has given up on the idea of a trade deal being reached, Aidan Flynn, General Manager at the Freight Transport Association Ireland (FTAI) explains about some of the practical operational changes Ireland faces in the event of a ‘No deal’.
The biggest challenge of all will be on the European Union (EU) and the UK achieving the comprehensive ‘free trade agreement’ that Ireland desires within the limited time left to do so. Time is the issue now with experts suggesting that it will be impossible to achieve ‘the deal’ necessary by the end of December 2020. The UK has rejected the opportunity to extend the transition period (deadline was 1 July 2020) instead, insisting that talks were progressing well and they were confident of a deal being done to the satisfaction of all sides. Negotiations between the EU and the UK are obviously progressing. However, in May Michel Barnier gave an extensive press conference where he set out the EU ambition as follows:
- Our ambition is still to achieve a Free Trade Agreement, with no tariffs or quotas on any goods. (first in the history of EU FTAs).
- Strong Level Playing Field guarantees. Looking to the future also means taking into account that trade policy has evolved. EU trade policy must aim to serve sustainable development. (the UK refuses this discussion!).
- We want a very broad partnership that goes well beyond trade in goods and services.
- Why would we seek to give favourable market access conditions to certain British professionals when our European fishermen would be excluded from British waters?
- Why would we help British enterprises to provide their services in the EU without any guarantees of economic fair play?
He went on to comment that the UK ‘is even looking to maintain the benefits of being a Member State, without the obligations’ and ‘There is still a real lack of understanding in the United Kingdom about the objective, and sometimes mechanical, consequences of the British choice to leave the Single Market and the Customs Union’.
Things seemed to progress a little in July, following a meeting between Michel Barnier (EU) and David Frost (UK) on Thursday, 23 July. The EU Chief Negotiator, Michel Barnier, made a Statement to a press briefing at Europe House, the EU Delegation’s London Headquarters. He noted that: Prime Minister Boris Johnson told us that he wanted to reach a political agreement quickly.
On two important subjects, transport and energy, Michel Barnier said there were “intense and useful discussions” although Mr Barnier said that the UK side continued to request ‘Single Market like benefits’. Given that it is expected a deal needs to be achievable by October in order for it to be ratified in the UK and EU it is increasingly unlikely that a comprehensive free trade arrangement can be achieved within the timeframe. Consequently, we must redouble our efforts to prepare. Irrespective of whether or not there is free trade agreement trade with and through Great Britain is changing from the 1 January 2021.
Revenue have provided an update on Customs Roll-On Roll-Off Service that will be available on the Revenue website
It consists of 3 functions:
- Pre Boarding Notification (PBN)
- Channel Look Up Facility
- Parking Self Check In Facility
If Just in Time Logistics is to survive for Ireland / GB trade and indeed Ireland continental Europe trade stakeholders must comply with the new administrative customs and where necessary SPS requirements.
Stakeholders in the import / export process:
- Ferry Operators
- SPS Agency
Developing relationships between all stakeholders is necessary to ensure that everyone is in the ‘loop’ and aware of obligations when travelling through our ports. All bodies have an obligation to progress this relationship.
New Process – PRE-BOARDING NOTIFICATION (PBN)
- Additional administrative process – the PBN is similar to an ‘virtual envelope’ to hold all declarations per vehicle (MRN – safety and security and import / export declarations)
- PBN can only be created once at least one MRN is to be added
- 1 PBN is per load
- Must be submitted to revenue (online) prior to boarding a ferry – operators will not have to do separate electronic notifications.
- Ferry operators will request the PBN number at check in – pre boarding and this information will be provided to revenue from the revenue operators
- Anyone in the supply chain can create the PBN, including – Logistics Company or Vehicle Driver or Declarant or Importer or Customs agent.
Pre – arrival at Dublin / Rosslare Port
- 2 hours out Revenue will determine the routing for drivers based on the information that has been submitted. Information will be sent to the declarant
- 30 minutes out – Arrival
o Driver made aware of vehicle/trailer channel
- Driver checks the Channel Look-Up on the Revenue website to see Channel: or
- Logistics company checks the Channel Look-Up on the Revenue website and informs driver: or
- Customs agent checks the Channel Look-Up on the Revenue website and informs driver: or
- Declarant checks the routing of their declarations and informs driver
- Where a vehicle gets a Call to Customs Channel and the driver knows that the goods are subject to a physical inspection then the driver can use the Parking Self Check-In function.
- The driver inserts the PBN Reference ID or Vehicle Reg Number or Trailer ID; and
- Parking Bay Number; and their mobile phone number
- When space becomes available in the relevant inspection area, the driver: will receive a text message with details of the inspection area they should proceed to; and will follow signage to the relevant inspection area.
Increased cost to distribution, more administration, more delayed deliveries and a reshaping of the supply chain will be inevitable. The risk of this must be negated by preparation and consideration for the issues at hand.