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.
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.
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.
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.
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.
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.
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.
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
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.
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.
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.