The UK left the EU on 31 January 2020 and entered a transition phase, which ends at 11pm on 31 December. From that time, the UK will be outside of the Customs Union and Single Market. This will result in the biggest changes in international trade since in at least 50 years, and most of the changes will happen suddenly. Tim Hiscock looks at the new requirements as they affect international hauliers.
Export and import declarations
All goods moving between the UK and the EU 27 will need export and import declarations. This represents about 50% of UK international trade. Even trade between mainland Britain and Northern Ireland will be affected. The Government is introducing a series of new systems that will affect the road haulage industry.
The road haulage industry carries the vast majority of goods travelling between the UK and the 27 countries of the EU, mostly using RoRo crossings. The first change the industry will face is that every export to an EU country will need an export declaration. The exporter is responsible for the accuracy of the declaration, while the information will usually be input by a freight broker or customs agent via the HMRC CHIEF system. Evidence of the CHIEF entry will be needed before a vehicle can board a ferry or the cross channel tunnel, together with any certificates of licences that may be required (these depend on the nature of the goods being carried and is determined by their tariff number).
The Government is introducing a new IT system called GVMS (Goods Vehicle Movement System) which will streamline the checking procedure. The system will be introduced in January 2021 only for goods moving under the Common Transit System and to Northern Ireland.
Before a vehicle taking goods to an EU country can depart its base, the CHIEF declaration must have been completed. The details must be registered on the “Check an HGV is Ready to Cross the Border” service if the vehicle is departing via Kent, and it can be a useful check for departure via other ports. This will verify the export declaration and produce a green, amber or red status.
A green status means that the vehicle can move directly to the port of departure.
An amber status means that the vehicle must travel to an HMRC office of departure for customs process and to receive an MRN Barcode.
A red status means that some or all documentation is missing, and the vehicle must not travel to the port.
Kent Access Permits and Transit Accompanying Documents
If the vehicle is departing the UK from a Kent port or via the Channel Tunnel (this represents about 80% of movements to the EU) then the vehicle must have been registered for a Kent Access Permit. A green or amber entry on the “Check an HGV is Ready to Cross the Border” will generate permit, details of which must be carried with the vehicle. No HGV must enter Kent with the intention of departing the UK without a Kent Access Permit. Any driver doing so will risk incurring a £300 fine.
It’s expected that the use of the New Computer Transit System (NCTS) will become quite common for deliveries to the EU. This system is already in place and will continue to be available for UK exports and imports after 31 December 2020. It allows goods to transit EU countries en route to their final destination in an EU country or a country bordering the EU. When using the NCTS, the vehicle must carry a Transit Accompanying Document (TAD) that is generated by the NCTS entry and present the document at every customs point. Note that the Kent Access Permit will be required for every HGV moving to the EU via Kent including if the goods are moving under the NCTS. It will also be required for goods moving on ATA or TIR Carnets.
Clearing goods on arrival
EU countries of arrival will each have their own systems for clearing goods. Unless the goods are travelling on a TAD or Carnet, the import declaration must have been completed to allow the vehicle to continue. EU countries are introducing their own IT systems for this purpose. If the goods are subject to a TAD or Carnet, the documents must be presented at the point of entry to the EU.
Goods travelling to Northern Ireland will be subject to controls, and the procedures will be facilitated by the Trader Support Service (TSS). Companies transporting goods between Great Britain and Northern Ireland should register for the Trade Support service, which will provide detailed guidance and free training.
Driver qualifications for drivers working for a UK employer will not change from 1 January 2021. But UK drivers working for EU employers will need to check they have the right qualifications, because a UK driver Certificate of Professional Competence may no longer be recognised by EU employers.
Some countries will require all drivers to carry an International Driving Permit. These can be purchased at main post offices for a fee of £5.50.
Depending on the outcome of the UK-EU negotiations, drivers may need immigration permits or visas to drive in EU countries. If this is not covered by any EU-EU agreement, drivers will need to check and comply with requirements in each EU or EEA/EFTA country they plan to enter.
Drivers from EU/EEA countries entering the UK can do so using a national identity card as at present. But from 1 October 2021, they will need a passport.
Hauliers undertaking international work will need to have the correct permit. Hauliers with a Community Licence will automatically be issued with a new permit. “UK Licence for the Community” for use from 1 January 2021. A copy of the new UK Licence for the Community should, in all circumstances, be carried on board all vehicles when working in the EU from 1 January 2021.
Possession of a UK Licence for the Community will not necessarily guarantee the right for UK hauliers to do business to, from and within the EU. This will depend on the outcome of UK-EU negotiations. This guidance will be updated as soon as the new rules are agreed.
UK hauliers travelling to or through the EU may require a European Conference of Ministers of Transport (ECMT) permit for some journeys from 1 January 2021. The journeys for which ECMT permits are required will depend on the outcome of UK-EU negotiations. This guidance will be updated as soon as the new rules are agreed. The process for applying for ECMT permits for 2021 closed on 20 November 2020.
UK registered vehicles and drivers must carry motor insurance green cards from 1 January 2021. These are issued by the insurer.
Vehicles must carry a GB sticker on the rear of the vehicle. This applies even if the licence plate includes the GB identifier on the EU logo.
Many of the requirements for haulage companies travelling to EU countries have yet to be determined because they are subject to the outcome of the UK/EU negotiations during December 2020. Companies should refer to the Government website for information and to the topics in the Operating Overseas section of Croner-i. Keep an eye on the Croner-i home page for the latest announcements.