Q.23 Currently BCPs on North Sea cannot accommodate live animals, this is of concern. What is government doing to facilitate the continued carriage of live animals?
A. Since 1 January imports of live animals from the EU have been required to be pre-notified using IPAFFS at least one working day before the expected time of arrival at the point of entry, and be accompanied by a GB health certificate. Identity and physical checks are carried out at destination. Once there is sufficient BCP capacity, live animals will need to enter GB via an established point of entry with an appropriate BCP.
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. 22 To what extent can DEFRA's groupage solution be read across to non-animal products?
A. The policy options presented are restricted to imported grouped consignments and/or mixed loads of animal products (POAO or ABP).
Q.21 Please re-clarify the definition of a carrier as the definition in Article 5 section 40 of the UCC is clear and different from what was just stated. However, Article 5 Section 40 (a) (ii) states ""in the case of maritime or air traffic under a vessel-sharing or contracting arrangement, ""carrier"" means the person who concluded a contract and issues bill of lading or air waybill for the actual carriage of the goods into the territory of the Union (in the SI's this now means the UK&I)"" . For my sector the airline is the carrier both for the aircraft movement and where we move good via our surface transport and/or RoRo, the Eurotunnel.
A. The description of the carrier as the "operator of the active means of transport" is a reference to the UCC Article 5 Section 40 (a) (i): "carrier" means the person who operates the means of transport which, once brought into the customs territory of the Union, moves by itself as an active menas of transport.
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.
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.
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.
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.
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.
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.
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: https://www.nicustomstradeacademy.co.uk/resources/ens-2/