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Posted Fri, 30 Jul 2021 11:12:11 GMT by HM Government Admin1
Q1. There appear to be problems with IPAFFs which could restrict the flow of crucial data to BCP's. Also some BCP's are yet to be built with less than 6 months to go. Will the transition be extended? If not what are the contingencies? A. The simplified pre-notification process that POAO traders will use from October does not go directly to the BCPs as traders are able to enter at any Point of Entry and do not have to route through a designated BCP until 1st January 2022. From the 1st of January when BCP routing requirements and inspections at the PoE are introduced, PHA’s / LA’s operating the BCP will have direct access into IPAFFS to see all relevant notifications, and this is an established process already used for third country imports. BCP designation progress is monitored closely and we expect all BCPs to be ready by 1st January.
Posted Fri, 30 Jul 2021 11:12:47 GMT by HM Government Admin1
Q2. A technical point, sorry, but can we please ensure pre-declared goods on vessels at temporary storage ports are 'arrived' at point of no return as GVMS goods will be to avoid delays and ensure level competitive playing field. A. Under the Temporary Storage model we will allow GVMS to be used to control goods at Temporary Storage berths but only for RoRo accompanied movements, which would enable you to arrive these goods at the latest point of no return. We are however restricting this easement to accompanied RoRo movements and unaccompanied goods will not be allowed to be controlled by GVMS at TS berths. Unaccompanied goods will still however be able to be pre-lodged into TS.
Posted Fri, 30 Jul 2021 11:13:21 GMT by HM Government Admin1
Q.3 An observation : whilst simplifying the guidance to give an overview is acceptable. It should be regarded as an introduction , not a replacement for the detailed guidance that is required, for instance on customs intermediaries. We have seen many essential Public Notices withdrawn and not replaced. HMRC refer us to the guidance which simply lack the detail that is necessary to assist clients and complete customs declartaions correctly. This is a frequent observation/complaint from BIFA Members. A. For HMRC guidance, HMRC are keen to listen to BIFA feedback and get the balance right. BIFA are a key partner working with HMRC on guidance and that input is much appreciated.
Posted Fri, 30 Jul 2021 11:13:48 GMT by HM Government Admin1
Q.4 Does the government expect all the licenses and approvals, and staffing of facilities to be ready in time for 2022 and is the UK likely to look to renegotiate the UK-EU deal to align on animal and plant product standards?

A. All systems and BCP designation, including PHA and APHA recruitment, is on track for the introduction of physical checks on all sanitary and phytosanitary goods from 1st January 2022. DEFRA continues to engage with the EU on steps we can take to reduce trade frictions. At the first meeting of the TCA Partnership Council on the 9th June, the UK emphasised the importance of cooperating to avoid unnecessary SPS barriers and reiterated that we are open to an SPS agreement based on equivalence. While we welcome furhter discussions with the EU, these cannot be based on future alignment with EU rules. This would compromise UK sovereignty over our own laws. Our Trade and Cooperation Agreeement (TCA) provides a framework for agreeing trade facilitations going forward. Over time, this will help to reduce the burden on businesses from border controls and certification requirements. We will seek to reduce checks safely through the dialogue both sides have committed to in the agreement. 
Posted Fri, 30 Jul 2021 11:14:32 GMT by HM Government Admin1
Q.5 SPS checks in GB ports must be a slick operation if delays and disruption are to be avoided. UK border readiness is heavily reliant on EU Border readiness and there is a sense that this is not happening A. DEFRA remain in close contact with our EU counterparts and continue to monitor flow through EU borders. Volume has steadily increased since the 1st January, whilst instances have dropped to less than 1% of those consignments checked. The UK's phased introduction of import controls is designed to ensure the continued smooth flow of goods.
Posted Fri, 30 Jul 2021 11:15:18 GMT by HM Government Admin1
Q.6 How will HMRC deal with delayed import declarations for non-UK registered entities where UK organisations are not prepared to act as an Indirect Representative - can further facilitations be expected in this regard to clear this backlog? A. HMRC have been clear that those EU traders using delayed declarations will need a UK Established Agent (under indirect representation) and HMRC continue to encourage those businesses to take action in good time. The improved UK agent list that has been published is designed to help businesses identify agents to help in their circumstances. BPDG, with support from HMRC, are delivering awareness across EU Member States (including at EU Industry Day events) and this includes providing messages on the steps needed when EU traders are considering using delayed declarations.
Posted Fri, 30 Jul 2021 11:15:48 GMT by HM Government Admin1
Q.7 I suspect this is a lost cause, but 1 January 2022 is a Saturday - not ideal for going live with new systems, even without the complications of Christmas and New Year holidays A. HMRC have noted this but there are some advantages in that traffic would be lower that day so HMRC would have staff on hand to support low volumes and any issues that arise that weekend.
Posted Fri, 30 Jul 2021 11:16:35 GMT by HM Government Admin1
Q.8 Currently a shipper can use a UK EORI without authorisation can we adopt an authorisation process like deferment accounts? A. An EORI is a registration, whereby a person (e.g. business) registers with HMRC and on validation of the information supplied, HMRC will issue them an EORI number. This number is then used to identify them when they undertake customs activities. This number is unique to the person registered and should not be used by anyone else. The registration process for a GB EORI (i.e. UK EORI) remains the same as it was when we were a member of the EU and, is therefore, the same for someone registering for an XI EORI (or any EU EORI to a member state customs authority). In summary, it is a registration rather than an authorisation and HMRC are not looking to change to this.
Posted Fri, 30 Jul 2021 11:17:04 GMT by HM Government Admin1
Q.9 Noted that a lot of effort has been put into writing guidance. However, the guidance can fall well short of that needed to enable working practice. Also - some guidance is completely inaccurate. Details of Customs Procedure Code (CPC) use still relate to the UK being part of the EU. This essential coding on a declaration could have been amended well inside of EU end of transition date. A. HMRC will pick the CPC point with the HMRC guidance team.
Posted Fri, 30 Jul 2021 11:17:56 GMT by HM Government Admin1
Q.10 Are there any differences in the types of goods that can go through a port if it is GVMS versus temporary storage or are they both ok for everything? A. There are no restrictions on the type of goods which can be moved through ports. Certain types of commodities (e.g. bulk movements) may mean that a particular customs model is more appropriate than another.
Posted Fri, 30 Jul 2021 11:18:36 GMT by HM Government Admin1
Q.11 With the reductions in PIF, live animal capability in planned BCPs other than Irish Sea seems to be focusing on short straits; is this regarded as acceptable nationally? A. DEFRA are committed to maintaining the highest biosecurity standards at our borders and to facilitating trade with the EU to support UK industry. As part of this DEFRA is continuing to assess the national picture of planned live animal Border Control Post capability. DEFRA are exploring options to increase BCP capacity in England for live animal imports, and are in the preliminary stage of gathering data from ports and commercial operators to inform and enhance decision-making.
Posted Fri, 30 Jul 2021 11:19:11 GMT by HM Government Admin1
Q.12 Accurate data on the number of checks to be carried out at BCPs is still not available, nor has there been any confirmation on hours of operation or resourcing. When will these be confirmed? A. BCP operating hours area commercial decision for Port Health Authorities (PHA) to determine. DEFRA expects PHAs to support their individual port operating models and to publish opening hours very shortly. As per the Border Operating Model, all POAO consignments will be liable to documentary checks from 1st October and physical checks from 1st January 2022. We have provided PHAs with the latest data for consignment.
Posted Fri, 30 Jul 2021 11:20:10 GMT by HM Government Admin1
Q.13 We have a major client importing a variety of POAO, HRFNAO etc via Dover. To our knowledge Dover BCP is Western Docks, and EU traffic is currently via Eastern Docks. Dover BCP current published hours are Mon-Fri 9-5, and in fact according to published info no BCP's are currently 24/7. Isn't this a massive escalation needed between now and 2022? A. From 1 October you can continue to import animal products via any point of entry (POE). From 1 January you will be required to arrive at a POE with an appropriately designated BCP. Defra is working closely with Port Health Authorities to ensure they are sufficiently resourced to carry out the checks in both October and January.
Posted Fri, 30 Jul 2021 11:21:13 GMT by HM Government Admin1
Q.14 Hauliers taking goods from GB to NI are typically using the TSS to make S&S declarations. For the trader receiving the goods they become locked into using the TSS for any further customs clearance, excluding other FF and Customs agents from the market. Are there any plans to unlock this monopoly and to open up the market? A. HMRC appreciate that businesses want to have the choice to use either the TSS or another way to make customs declaration for GB-NI goods movement. The TSS has recently launched new functionality to address this issue, and the haulier now has the option to make a standalone ENS that will not also submit a customs declaration. A business opting to use this approach will need to ensure that they provide the haulier with the MRN for the customs declaration for the goods (either a full declaration or simplified frontier declaration) before the goods reach the port of exit in GB so the haulier can include it in their GMR. Further details can be found here:
Posted Fri, 30 Jul 2021 11:21:43 GMT by HM Government Admin1
Q.15 What is the process when Hauliers do not complete the transit on entry into GB - the process appears to differ from border post to border post? A. All hauliers must complete an Office of Transit on entry into GB. This is a legal obligation. A haulier must complete the Office of Transit, either by entering their GMR into GVMS, or by physically presenting their TAD at a port which offers a manual Office of Transit.
Posted Fri, 30 Jul 2021 11:34:18 GMT by HM Government Admin1
Q.16 Are there changes to the process to be envisaged on Small Parcels process into UK and NI? How about IOSS in NI using CDS? A. For now, there will be no changes to the processes for small parcels entering the UK (inc NI). The UK is implementing the EU’s eCommerce package in NI and guidance on the current application of the package can be found here. If processes do change, additional guidance will be made available.
Posted Fri, 30 Jul 2021 11:34:54 GMT by HM Government Admin1
Q.17 To the HMRC Transit team - do you have data on whether the Hauliers referred to are EU hauliers or UK based? If the former, for you have info, on which Member State? That would help industry target comms via our partner organisations. A. The issues seem to apply for both EU and UK hauliers, but HMRC have very limited information on the home state of the EU hauliers. The Transit record only shows the location of the declaration itself (so the trader) where as the provision of haulage service across the EU is very fluid between MS. Industry comms are key, but HMRC are aware that you need us to provide clarity of messages and obligations to do this.
Posted Fri, 30 Jul 2021 11:35:24 GMT by HM Government Admin1
Q.18 When will final guidance on fields required for ENS declarations be available? We cannot be expected to be ready by the end of the year if not given time to develop. A. HMRC are in the process of updating S&S guidance and will have more clarity around timelines shortly.
Posted Fri, 30 Jul 2021 11:35:44 GMT by HM Government Admin1
Q.19 Will GVMS validate a CHIEF entry number? (to auto arrive the pre-lodged entry) A. GVMS will validate CHIEF entry numbers when they are entered into a GMR. This will allow GVMS to arrive the declarations in CHIEF.
Posted Fri, 30 Jul 2021 11:36:14 GMT by HM Government Admin1
Q.20 On the TSAD's my understanding was that there were 2 EU member states only that could not accept TSAD's but would once the 5th iteration of NCTS came out. But should we not be pushing for this. A. This is a statement about EU acceptance that is understandable but factually incorrect. However HMRC are pushing for EU alignment and have specifically pressed the CTC on this.

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