Q. 57 So when will the relevant info for fresh produce etc be available? A. Defra are in the process of developing guidance for inspection of mixed load consignments and how they will be carried out in line with service standards. More information will follow shortly.
Q. 56 The presentations appear to apply for meat products only - please advise your groupage solutions for import of fruit ,veg flowers and plants. A. DEFRA are currently reviewing their guidance regarding groupage import scenarios. This will be communicated to trade and stakeholders in due course.
Q22: Will the private attestation avoid documentary (or physical) customs checks at the border crossing point eg. EUROTUNNEL and divert the checks at the destination point?
A: Unless specifically exempt from border checks, all consignments of composite products exported to the EU will be subject to veterinary checks at an EU Border Control Post (BCP), including those exempt from certification where a private attestation is also required. If the final composite product is shelf stable and does not contain processed meat products but is not on the EU's list of lower risk products it must be subject to BCP/Point of Entry checks and accompanied by a private attestation. Only those composite products that are specifically exempted, in the legislation, from that checks at BCPs are exempted from checks at the border. Checks may be carried out at the place of destination, the point of release for circulation in the EU or the warehouses or the premises of the operator responsible for the consignment.
Q21: There are some real logistical challenges with the Private Attestations. Operationally the data needs to be prepared by the exporter but an original needs to be signed by the importer and available at the point of placing on the market which includes placing into free circulation. Getting a signed original copy and having that available at the BCP at the time of import is virtually impossible. If electric copies were to be accepted in all Member States this would be helpful and make the task easier. Has this issue been raised with the Commission?
A: A private attestation can be uploaded (via a scan) in TRACES instead of a paper presentation at the Border Control Post (BCP) where border controls are required, however it cannot be electronically signed. Importers should check with the relevant BCP to understand if they expect the original hard copy of the Attestation to follow after the consignment has arrived. For composite products exempted from official controls at the BCP, the private attestation shall accompany the products at the time of the placing on the market.
Q20: We are concerned about resourcing from various govt departments to provide approvals in time for import border controls from 1st Jan 2022. For example, we have had zero response from the National Frontiers Unit on port approvals. Can we have assurances that a response will be given in a timely manner?
A: HMRC continues to support traders following the end of the transition period and we are helping them to prepare for the ending of staged sutoms controls, with extensive engagement and communication campaigns, guidance and educations resources, working in collaboration with other government departments.
In HMRC we build flexibility into our plans to ensure we have the necessary resources to meet future requirements as well as more immediate delivery demands. We routinely run regular recruitment campaigns for operational delivery staff to ensure we have a steady pipeline of supply to meet a range of business needs.
Border Force colleagues have responded to outline that it is confident that it has the adequate Regional Operational Staff in place to undertake any site visits, where necessary, as part of the approvals process, provided that these are commissioned in a timely manner and are not compressed into the final few months of the year.
Q19: Is there a clearer timescale for the steps toward the Strategy 2025 implementation?
A: Government is currently taking forward significant areas of the strategy such as the development of a Single Trade Window, beginning to pilot Electronic Travel Authorisation through the Home Office's Universal Permissions to Travel reforms, and establishing a Border
Innovation Hub. Following further engagement with the border industry, we aim to publish an indicative delivery roadmap later this year.
Q18: How assured are you in planned customs, testing and sampling arrangements are progressing with responsible parties for the Oct and Jan go live dates?
A: HMRC will be delivering around 40 functional changes (15 scope items related to GB Import/ Export and Transit; 25 scope items related to NI Import/ Export) between October and January with majority of the scope items now completed their scoping/ discovery activities.
- Testing for October and January release - Detailed test planning, scoping, preparation activites and test coverage required for the individual scope items are in discussion/ early draft. Although test progress is at the initial planning phase, there are no issues at this stage that might impact the planned testing schedule.
- Sampling arrangement - The objective of Live Proving is to ensure external parties and HMRC are as ready and prepared as possible for the implementation of Full Customs Controls on 1st January 2022. Live Proving will assure that the E2E business processes and the enabling technology are working in live. Using customer jounrey scenarios will enable us to assure the readiness of externals within our proving. This activity will give the end users, such as hauliers, traders, supermarkets, carriers and port operators, confidence on how the process will work in real life scenarios. We are in the final stages of publishing the Live Proving approach and engagement with the external Traders/ EO/ Carriers/ Hauliers are due to start week commencing 17th May. Live Proving activity is scheduled to start from 16th August and continue until middle of December. All arrangements within HMRC have been agreed and will be in place to support the external parties or resolve any incidents that are raised during the testing window. Communication and engagement to all friendly traders and other external parties for this Live Proving test are expected to start this month providing sufficient time for all external parties to be ready ahead of testing start in August.
Q17: Can you give an indication on when the tariff for the inland BCP's will be shared?
A: No decisions have been made on the rates for charges at HMG inland sites. The BPDG Infrastructure team are still in the process of finalising the details which will become available in due course.
Q16: BIFA has raised the question since late January of import non-compliance relative to the Delayed Declaration regime with BPDG and HMRC, but as yet no response has been forthcoming. Please do you know when Government will be able to give guidance to allow customs agents/traders etc to regularise individual consignments. This is a significant issue.
A: HMRC is actively considering this, and has had very helpful discussions with BIFA colleagues and members about these compliance issues. HMRC is expecting to revert back to BIFA, and wider stakeholders, in due course.
Q15: UK touring companies that used to support cultural industries and carry equipment across multiple concert, sports and other event venues across Europe simply can’t operate under the TCA rules. This is an existential threat to a successful sector of the economy where the UK has unparalleled expertise and experience. Do you intend to seek a renegotiated approach to this with the EU to save this sector? What other steps are you considering?
A: The Government recognise the importance of touring and cultural sectors, and is committed to helping them navigate the new rules under the TCA. The UK pressed for a special derogation from the cabotage restrictions for hauliers carrying equipment for the purpose of concert tours and similar activities however the EU rejected this. DCMS and DFT are working with industry to understand the implications of the new rules and discuss options for support.