Steps will be required whether there is a Brexit trade deal or not © Christopher Furlong/Getty Images
Steps will be required whether there is a Brexit trade deal or not © Christopher Furlong/Getty Images

Q&A: what you need to know about the new Border Operating Model

posted by Will Green and Charlie Hart
9 October 2020

The UK government has released details of 10 potential inland sites that will perform border functions for freight from July 2021.

Six sites are in the Southeast and the others are in Birmingham, Warrington, Holyhead and South Wales.

The government said infrastructure would be needed from July 2021 when full border controls come into force at the end of a phased introduction from January.

The infrastructure is part of the UK’s Border Operating Model, first announced in July. The updated model contains detailed information for importers and exporters that will apply whether there is a Brexit deal or not.

“These steps will be needed regardless of whether we reach a trade agreement with the EU,” said the Cabinet Office.

Under the “core model”, from January traders importing goods will need a Economic Operator Registration and Identification (EORI) number, the Commodity Code of their goods, and the customs value of goods. There will be additional requirements on some commodities.

Under a phased introduction until July 2021, traders can make a record at the point of entry of goods into the UK and then make a customs declaration within six months.

There is also a requirement that all outbound HGV drivers taking goods from the UK to the EU using the Short Straits crossing will need a Kent Access Permit to use roads such as the M20.

Michael Gove, chancellor of the duchy of Lancaster, said: “Our updated Border Operating Model provides further detail on how the GB-EU border will work after the transition period ends on 31 December and the actions that traders, hauliers and passengers must take.

“With fewer than three months to go, businesses need to prepare now for new procedures whether or not we reach a trade agreement with the EU, so that they can seize the significant opportunities that lie ahead.”

Dave Howorth, executive director at logistics consultancy Scala, said the plan “appears extremely last minute and more than a little desperate”.

“Notably, it points to an expectation from the government that there is going to be severe border disruption come January – which we, as an industry, have been warning about for years to no avail,” he said. 

“The impact of this level of disruption is enormous. For example, the ramifications of short shelf-life perishables being delayed by even a day – which, given drivers’ hours, may be caused by a delay of just hours – could be hugely significant. Furthermore, the increased time it takes to travel to and from these inland border sites will also disrupt transit times, as well as both delivery and collection schedules.”

Howorth warned queues of 7,000 trucks at the border would cost £3.5m per day. 

Richard Burnett, chief executive of the Road Haulage Association, said: “The message is clear – if the paperwork’s not right, the goods won’t cross.”

Elizabeth de Jong, UK policy director at Logistics UK, said: “This clarity on trading arrangements from 1 January 2021 is welcomed by logistics businesses and it is now vital that all businesses trading with the EU use this guidance to make sure their staff and systems are fully prepared.”

Robert Keen, director general of the British International Freight Association (BIFA), said: “BIFA members are looking for assurance from government that the new IT and other systems being introduced will actually work, and will be able to do what is necessary.”

1. Who can export goods from the EU, and do they need to register? 

Following the end of the transition period, UK businesses will need an EU-registered company to act as an exporter or representative in order to export goods from the EU. 

EU businesses exporting goods will need to have an Economic Operator’s Registration and Identification (EORI) number from a customs authority in the EU. After the transition period, only EORI numbers issued by an EU member state will be acceptable in the EU. 

2. Should I agree trading terms and conditions with the EU exporter or their agent in advance? 

The GB importer and EU exporter should agree terms and conditions so that the responsibility for tariffs, duties and border formalities is clear. It is important to determine which party will be responsible for any consequences of customs checks, and who will be financially responsible in case of any issues. 

3. If I am importing controlled, restricted or prohibited goods, what do I need to do to prepare my goods for export from the EU? 

Certificates or licences will be required to export certain goods and types of products including food and feed, live animals, endangered species, dual-use goods, drugs and chemicals. Certificates will need to be applied for at least two weeks in advance.

UK authorities will need to be pre-notified through the UK’s import of products, animals, food and feed system (IPAFFS) about the arrival of some goods and the relevant licences or certificates will need to accompany them. 

4. Has the exporter or their agent submitted the customs declaration(s)? 

The exporter or their agent must submit the customs declaration at an EU office of export, and produce an Export Accompanying Document (EAD), a Transit Accompanying Document (TAD)/Movement Reference Number (MRN) or a Combined Transit (Security) Accompanying Document (TSAD)/MRN.

If there is no customs declaration, there is a requirement to confirm that a separate Exit Summary Declaration has been lodged into the Member State Export Control System. The EAD produced will contain the MRN (a number and barcode) that the haulier should present at the EU border. 

5. Has the exporter provided the haulage company / driver with all the necessary documentation prior to them setting off for the EU border? 

The EU exporter or their agent must make sure that they provide the following documents and / or data to accompany the consignments, to be presented at check in at the EU border:

• The original, wet signed, EHC, if one is needed; 

• Any CITES (endangered species) documentation required; 

• One of the three Movement Reference Numbers (a barcode) (EAD, TAD/MRN or the combined TSAD/MRN) 

If there is no customs declaration, there is a requirement to confirm that a separate Exit Summary Declaration has been lodged into the Member State Export Control System.

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