UPDATE 29/04/2022

The requirement for further Sanitary and Phytosanitary (SPS) checks on EU imports will no longer be required in July 2022. This customs control requirement has been pushed back to the end of 2023.

In order to maintain the smooth movement of goods it is important that supply chain members are fully informed about all of the new customs rules to avoid delays at ports, especially when it comes to sanitary and phytosanitary goods.

Common Mistakes

Customs documentation is a critical aspect of the new customs procedures. Unfortunately, there have been a lot of issues with the submission of these documents, leading to fines and goods being held at port.

The most common issues for GB exports include:

• Incorrect/invalid EORI numbers

• Lack of SSD (ENS) documents

• Incorrect information on documentation

• SPS (Sanitary and Phytosanitary) issues – missing/incorrect documentation, BCP (Border Control Post) appointment not booked and no notification of arrival to BCP

• Understanding of REX (Registered Exporter) system processes

Common issues for exports from the EU include:

• Incorrect document submissions

• Incorrect information

• Contractual issues - who is authorised to export goods etc

• Understanding of Rules of Origin

Sanitary and Phytosanitary

There are a lot of new regulations surrounding the movement of goods that fit into the category of SPS (Sanitary and Phytosanitary). These new procedures need to be followed completely or goods will be refused entry upon arrival in the EU.

Competent Authority

SPS products need to have appropriate approval in order to be transported into the EU. This means that the establishment that the goods are being dispatched from needs to be listed on the EU Approved Establishment List.

To be added to the Approved Establishment List, a business must gain approval from the APHA (Animal and Plant Health Agency), FSA (Food Standards Agency), FSS (Food Standards Scotland) or another relevant local authority, depending on the product being transported. This process can take up to 30 days. Goods must not be exported to the EU until this is complete.

Pre-Notification of CHED

When products of animal origin and SPS goods are being moved from GB to the EU, exporters will need to pre-notify EU authorities of their arrival using TRACES NT or equivalent system.

The EU importer will need to complete Part One of CHED (Common Health Entry Document) to pre-alert authorities of the arrival of the goods. This will generate a CHED number, which the declarant must add to the pre-lodged import or transit declaration.

The Economic Operators must add the pre-lodged customs/transit declaration to Part One of CHED. They should not wait for Part Two and Three CHED to be processed prior to doing this.

When the truck driver/trailer operator makes the ferry booking it is their responsibility to inform the ferry operator that their consignment is submitted for SPS control. This will ensure that the truck is presented in front of the BCP.

The BCP must be pre-notified 24 hours prior to the arrival of the goods.

If these steps are not followed, the goods will be refused entry to the EU. You are unable to send notification once the goods are in the EU.

Customs and Transit Movements

Ensuring that the correct customs and transit procedures are followed is vital to allow trade to continue.

Moving Transit

When a transit movement is started, there must be a transit guarantee in place. This will cover all live transit movements and will include coverage for customs duty, excise duty and import VAT.  The transit movement must be logged in the NCTS (New Computerised Transit System), which will generate a LRN (Local Reference Number).

It is vital that the goods being transported and the LRN are shown at the same office of departure as the one which is specified on the Transit Declaration. This will enable the office of departure to activate the transit accompanying document (TAD) alongside the appropriate Movement Reference Number (MRN). The haulier will then be given a physical version of the TAD, which will have the MRN on it, which they can carry with their consignment.

Documentation

Inaccurate documentation can lead to fines and will prevent your consignment from being allowed entry into the EU.

C88 - Box 51

Box 51 of the C88 should always be completed. This should always be the next transit office outside of Great Britain. Currently, French Officials are allowing people to refer to both Calais and Dunkirk for codes in box 51 for freight travelling on the Calais-Dunkirk route.  This is a temporary measure.

Inland Border Facilities (IBF)

If you are starting or ending a CTC movement (Common Transit Convention), you will need to make sure that you get CITES (Convention on International Trade in Endangered Species) checks. You will then need to get you ATA Carnet or TIR Carnet stamped.

It is important that you let the HMRC know that you are attending an IBF in advance via the Government website. You will need to:

• Know your arrival time

• Have LRNs, MRNs and any additional reference numbers

• Have the vehicle registration number and the phone number of the driver