Brexit is headline news again, all of the politicians are talking about, the media are engrossed in it, but for truck and bus companies it is about preparation. Surviving the transition, deal or no deal will only be possible if the small details are addressed and managed, according to the Freight Transport Association Ireland’s Aidan Flynn.
We have reached a critical point in the negotiations and as they rumble into London for the latest talks it is really no surprise that news from Downing Street over the last number of days is creating a stir. Any attempt to undermine withdrawal agreement and renege on the international treaty negotiated and signed by the British Government will have profound consequences and undermine the credibility of the UK as a country you can trust. The bottom line at the moment is that nothing is agreed until everything is agreed and we are in the midst of a negotiation that will go to the wire before we hope deliver an agreement that delivers minimal trade barriers. What is certain though is that we in the freight distribution and logistics sector must continue to focus on our preparations for the new trading environment from the 1 January 2021. The COVID pandemic has created a lot of difficulties for everyone and it has diverted focus away from Brexit. It is now time for each business to reassess their supply chain and dependence on Britain as a trade partner or indeed their reliance on the Landbridge for connectivity with continental Europe and assess their options.
The Irish Government are introducing its long overdue Brexit preparedness plan that will outline the support and guidance available to assist with getting Brexit ready! There will be much change when it comes to import and export activity with Great Britain and Revenue have advised that the following three functions will be available on its website: Pre-Boarding Notification (PBN); Channel Look Up Facility; Parking Self Check In Facility. To develop efficiency in new systems will take a period of time and trial and error. The new regulatory environment imposed as a consequence of the UK decision to leave the European Union will have a serious impact on the movement of good between Ireland and Great Britain. There will be a requirement for everyone in the Supply Chain to understand their roles and their obligations for the smooth passage through customs and border checks at ports. No longer will a manifest with limited information be acceptable, the new normal will require detailed information and pre notification of the goods to be moved to ensure smooth passage.
Key stakeholders in the movement of goods are the Driver (of the HGV); Ferry Operator; Declarant; Customs & SPS Agency (Department of Agriculture). It is vital that the haulage company and the consignors and the other parties involved in the declaration of imports/exports and safety and security declarations work closely. Where there are delays caused by incorrect paperwork or because of normal physical checks the drivers must have the necessary information and paperwork to hand and the declarant must be available to deal with any issue that may arise. The trader/their representative will share the Movement Reference Number (MRN), Entry Number or EORI number with the Haulage Company or Driver as proof that a customs declaration has been made. The driver will need to carry evidence that Customs formalities have been met for all goods being imported and that safety and security declarations have been made. This will mean an MRN(2), Entry number or EORI Number for each customs declaration submitted. All this documentation will now need to be placed into a virtual envelope called a ‘Pre-Boarding Notification’ (PBN) (Only 1 PBN per vehicle / Trailer per journey). The PBN data is re-used by Revenue to create the Presentation Notification. It gathers together all of the declarations for a vehicle/trailer for a particular journey and it enables a channel to be assigned to that vehicle/trailer based on all of the declarations. 30 minutes before arrival into Irish ports drivers and declarants will be made aware of their routing, Green channel to exit port immediately or Red channel to call at customs for inspection. Change is coming and it will be onerous. How onerous will depend on how prepared we are and how pragmatic the enforcement authorities will be! But for now we need to review and utilise the supports available through local enterprise centres and other supports such as:
- Local Enterprise Offices: Brexit Supports for your Small Business
- InterTradeIreland: Brexit Advisory Service
- Enterprise Ireland: Prepare for Brexit
- Skillnet Ireland: Clear Customs
For International haulage operators the FTA Ireland has developed a bespoke online training programme called ‘Customs procedures for the haulage operator’ https://www.ftai.ie/customs-procedures-for-the-haulage-operator this course will provide you with all the information and tools necessary to deal with the trading reality.
Finally, it is important to consider the following questions when it comes to your Brexit preparedness:
- Have you identified the training and upskilling requirement for your staff? Are you going to do the Customs declarations in house or contract third parties?
- Have you discussed Brexit preparedness within your supply chain and worked on them together?
- Have you considered who is responsible for Movement Reference Number generation (MRN) import/ export declarations; safety and security declarations etc.?
- Are you aware of additional costs these new requirements will impose?
- Do you Understand the roles and requirements of the declarant, driver, consignor?
- Have you adequate insurance in the event of delays at ports on the road that leads to rejection of loads – What insurance does the consignor / consignee have to cover carriers liability Insurance?
- What IT solutions are available to support and streamline this new process?
- Do all your drivers have smart phones / laptops / tablets in order to check their routing on the ferry?
- What alternative routes/options are there for Irish businesses to get goods to and from the EU market post Brexit, road, sea and air?
- How many hours delay on the landbridge is tolerable to continue to make it a better option than going direct to continental Europe by ship?
- If your drivers don’t hold an Irish or UK passport, what additional complications (if any) will this pose when moving goods into and out of Britain?
- For a haulage company based in Ireland, is the transport managers qualification, Transport Manager CPC issued from the UK? If so, this will no longer be valid in the EU. The transport manager will have to sit this trade exam in the member state in which they reside.