Safety & Security Declarations Questions
Can you do an S & S for me if there is no customs declaration required?
So this would be a Standalone S &S , and might be required for the movement for example, of a containers or pallets under a transport contract and where a customs declaration is not required. So yes, we can do this.
Will you be able to help with doing the S & S in EU?
YES, definitely for Irish and Channel crossing, we can help and we are looking into how we can assist with the North Sea and Spanish crossings with those ferry operators.
Will an S &S be required for each consignment?
YES, they will be required for each consignment, in the same way a customs declaration will be required. If fact, the information asked for is very similar. And, Yes, we do understand that this has the potential to be a nightmare for groupage loads!
Will there be a full written process to know what has to be done from start to finish both for haulier and the client
In relation to using the brokerage APP/platform, then yes, training will be available.
What is the safety and security declaration
Border Authorities are responsible for performing risk analysis based on information supplied in either the EXIT or ENTRY Safety & Security Declaration. This is NOT the Customs entry but a SAFETY & SECURITY Declaration. Consider it a pre-alert to the border post through which the goods will pass.
So based on the information and, in some cases intelligence, they may decide stop the vehicle for an inspection.
You’ll actually notice that much of the information that is required for the S & S declaration is on the customs declaration.
Is there any indication that the deadline (31st December) could be extended due to Covid-19?
Government has already said there will be not extension to the Transition Period. The only allowance that has been granted is the staging of the UK import customs requirements.
For temporary exports that will visit multiple countries in the EU and outside the EU, would there be a requirement for each country we visit to ensure safety and security declarations are pre-lodged?
The EU inbound Safety & Security declarations will be for the point of entry and will cover for the whole of the EU. If you go to countries that are not in the EU, eg Turkey, then an S & S will be required in & out of those countries.
Where can I register for future webinars, the eventbrite booking system is not showing further sessions?
We have moved away from Evenbrite in favour or ‘gotwebinar’. All the webinars are being promoted through our media channels and the recordings will be on the RHACustom website shortly.
Re groupage - what’s the situation if the load is made up of personal effects (so not new items, and for private customers)?
We are waiting clarity from HMRC as to what type of customs declaration (if any) will be required, but it is expected that a Safety & Security declaration WILL be need regardless. Therefore the haulier will have to provide the consignor/consignee details, along with description of goods as well as other information. Your customers should already be providing you with information for a delivery note and inventory list of some description.
Is the managed telephone service available 24/7?
Yes, it will be a 24/7 service.
Where are the examples we need try?
Whilst there will be training provided to use the RHA Brokerage platform, unfortunately there is no way of ‘try before you buy’ for the S &S requirements. However, if you want to see the information that will be requested for the Safety & Security declaration, examples can be found via the following document.
https://ec.europa.eu/taxation_customs/sites/taxation/files/docs/body/doc1250-05-annex.pdf
Funding Questions
Do you have a list of training providers?
Yes. You could try https://www.export.org.uk/ or https://www.bifa.org/home
Is there a limit on company size, minimum or maximum?
No. There’s no limit on company size.
Can you apply for any of this if you’ve only been trading four months, but your sole business is international?
No. You need to have a registered office or branch in the UK for at least the past year. More details here: https://www.customsintermediarygrant.co.uk/
How long can we expect it to take for these grants to fund once applied for?
It should take four to six weeks.
Can you form a new company between hauliers to do customs paperwork?
No. The business applying needs to have had a registered office or branch in the UK for at least a year
Can we apply for grant for expenditure which we incurred before the grant was announced this year?
Possibly, we would recommend you discuss with the funding administrators before applying – details here https://www.customsintermediarygrant.co.uk/
Are these grants available to businesses in Northern Ireland
Yes, anywhere in the UK.
Will I receive all the funding I have applied for?
Depends. Each case is assessed on its own merits.
Can I apply for all the grants?
Yes, so long as you do not exceed state aid limits (200,000 euros).
Border Ready Questions
What actions should we take if no deal is reached? And what happens if we are unable to get permits?
Regardless of whether the UK and EU strike a deal, huge changes are coming, and you will need to be ready. We will keep you updated and help you prepare.
It is still not clear if ECMT Permits will be the only way of getting into Europe after 1 January or if they will even be necessary. In the meantime, we strongly advise you to apply for them here.
The application ‘window’ to apply for permits closed on Friday 20 November.
Please note, Government will not be announcing who will be allocated permits before that date.
Why do I need an EORI number if I am not an importer or exporter?
You as the haulier are responsible for completing safety and security declarations and you will need an EORI number. An EU EORI number will be needed for the return trip. You can only apply for an EU EORI number if you are already in possession of a GB number.
An EORI number may be needed to move goods to or from Northern Ireland – but not if you move goods between Northern Ireland and the Irish Republic.
More details on this will be circulated shortly.
When can we register for the Goods Vehicle Movement Service?
The Goods Vehicle Movement Service is still at the beta testing stage but if you want to see what it will look like, HMRC is looking for firms to test the system and provide feedback.
Contact our International Group Manager, Heather Wallace for more details.
Kent Access Permits
Vehicles of more than 7.5 tonnes that are exporting goods through Eurotunnel or the Port of Dover from 1 January must have a Kent Access Permit (KAP).
These can only be obtained through the Government’s ‘Get an HGV Ready to Cross the Border’ service. There is also still Beta testing taking place and you can get involved – contact our International Group Manager, Heather Wallace for details
ANPR will be used to check that vehicles arriving into Kent have completed the ‘Get an HGV Ready to Cross the Border’ check. An electronic version of the KAP will be available to the driver.
We aim to cover this topic in more detail on one of our forthcoming webinars.
How many ECMT permits are available to UK hauliers?
A maximum of 2,088 annual lorry permits are available for all UK operators to enter the EU – nowhere near enough.
Great Britain has 8,348 operators with International Operator licences – 83,522 HGVs.
Northern Ireland has 1,830 operators with International Operator Licences – 10,688 HGVs.
We continue to urge the UK Government to strike a deal which allows all UK firms who operate across borders to continue to do so after 1 January.
Will an ECMT permit be needed for the Republic of Ireland?
Potentially yes. If you are travelling from Great Britain. However, ministers announced that ECMT permits will not be needed when crossing from Northern Ireland to the Irish Republic if you have a Northern Irish ‘O’ Licence.
More on this to follow.
Own Account Operators. Will my company need ECMT permits if we pull our own product, manufactured on site, but delivered to different customers?
The International Transport Forum document which governs the ECMT quota scheme (pages 11 & 13) gives a list of transport movements that are exempt for the need to have ECMT permits.
Own account movements is item 10 on the list. However there is a caveat, item 7, that lists the countries that do not recognise this exemption – Austria, Belarus, Bulgaria, the Czech Republic, Estonia, Finland, France, Hungary, Italy, Lithuania, Poland, the Russian Federation, Sweden and Turkey entered a reservation under item 10.
Who will be responsible for completing the customs declarations needed for collecting Ro-Ro trailers from ports?
The importer will be responsible for the inbound customs declaration. You, as the haulier, must make sure the declaration has been completed when you collect a trailer.
Will I need Transit Declarations as well as export entries?
Yes. If you are using the CTC or TIR transit systems, we can help. We’ll cover this in detail in the coming weeks on our webinars and across our other communications. In the meantime, go to our Customs Brokerage site and find out more about our two services.
How will the new processes work for live event touring work?
We understand it that event/exhibition/sporting work will be achieved under the ATA Carnet system.
What will the processes be for events such as motor racing?
If you are moving as part of a team to a sporting event it is likely that you will need an ATA Carnet.
We will know more shortly.
Why do I, as a haulier need a customs broker? Isn’t that the responsibility of the importer or exporter?
If you have agreed to complete the customs declarations, then you will need the services of a customs broker. It is the responsibility of the trader to provide details relating to the load.
The conventional way of doing so is with a commercial invoice. The RHA can help you with through its own customs brokerage service.
There may be occasions when you, as the haulier, will have to complete your own safety and security declaration – even if the trader has given you all the completed customs documents. For this you will need the services of a customs broker.
Example. We move boats to and from the EU. Will each item need to be itemised? And what will be the customs process for private clients who want to move their boats between seasons?
If you are fully exporting the vessel, you will need to submit a customs declaration for all the items carried.
However, if you are sending it out temporarily (it will be returning to the UK) you will need to complete a Temporary Export Arrangement – probably with an ATA Carnet – and list the items carried.
What is vehicle repatriation process?
We anticipate receiving guidance from HMRC shortly.
It is not yet clear yet if a customs declaration will be required but it is very likely that as the haulier, you will have to complete a safety and security declaration.
The RHA Customs Brokerage services can assist you with this.
Transporting live fish and shellfish to the EU – will there be checkpoints to inspect the consignment?
Yes; here in the UK and on arrival in the EU. All fish and shellfish arriving in Calais will, most likely have to go to Boulogne for inspection – other border control points may become available. Various health certificates will also be required.
These processes must be completed before the goods are dispatched.
The RHA Customs Brokerage will cover border patrol points through its webinars in coming weeks.
What is the cost of the RHA Customs Brokerage service?
Pricing for both our services will be announced shortly. In the meantime, go to our Customs Brokerage service website on a regular basis for updates on our webinars which will explain how our services can help you manage customs requirements next near.
If we use the RHA Customs Brokerage service, are we entitled to claim the training grant?
Yes. The grant is for staff training and IT so it will depend on how you plan to structure your business.
We are hosting a webinar on this on Thursday 12 November at 2pm.
Does RHA Customs Brokerage have badges for all UK ports?
Yes. The RHA Customs Brokerage covers all Ro-Ro ports.
Do we need commodity codes for each part of the trailer?
Yes. Commodity codes are required for the goods being transported on the trailer. The trailer itself does not need a commodity code.
Will transit documents be needed if we, as the haulier, take goods further than the country of entry?
Yes. Transit Accompanying documents will be required. The RHA Customs Brokerage can help with this.
As an importer/exporter as opposed to a haulier, I note that each individual item has its own, long, number. Will the RHA Customs Brokerage be able to help to determine which number has been allocated to which item?
Yes. RHA Customs Brokerage can provide commodity codes.
These will be covered on our webinars in the coming weeks. Details of commodity codes, duty and VAT rates can be found here.
Is the UK EORI number different to the EU EORI number?
Yes, it is, but you will not be able to apply for an EU EORI unless you already have a GB one. Go to www.gov.uk/eori to apply for a GB number.
How do I apply for an EU EORI?
The EC Europa site lists all the EU taxation offices.
The RHA will be providing links to assist members. You only need to apply to one member state, as each member state will recognise each other.
As a transporter, why would we need an EC EORI number?
You need the EU EORI number because it is required for the Safety & Security declaration that you will have to complete on arrival or when leaving the EU.
Are your solutions tailored to specific industries? For example, we are a removal company, so the documents are slightly different.
We cannot tailor to specific haulage types.
When it comes to removals, we are still waiting clarification from HMRC as to what declaration will be required. It is expected that a Safety & Security declaration will be required, even if a customs declaration is not. BUT as mentioned, we are waiting clarity.
Will this only apply to HGV’s? How does it affect vans? How will declarations for exhibition goods need to be handled. These goods will return to the UK in the same manner as they were exported.
Any freight vehicle, regardless of size, transporting loads to/from Europe will require a customs declaration.
Items for exhibitions/concert tours/sporting events will need ATA carnets to cover the loads and everything that goes out, must come back again. There is some allowance within the customs regime for samples etc., but this will have to be treated separately from the ATA carnet.
Do third party hauliers have to complete safety and security declarations on behalf of exporters?
Any haulier will have to make sure they have been given the details relating to the customs declaration, because if they are the vehicle that is carrying the goods across the border to the UK, the vehicle details will need to be on the customs declaration, and YES, the safety and security declaration will be their responsibility.
Please define Agri-products?
We suggest you refer to information provided by DEFRA
Is the app web-browser based?
Yes, whilst we have referred to the service as being an APP, it is actually web-based but accessible by any device.
Do I need to prepare some extra documents if I will send a lorry to EU in November this year to bring a steel structure?
NO, customs declaration and safety & security declarations will not be required until 1 January 2021.
Will the managed brokerage be a 24/7 operation?
Yes, it will be.
We will be dealing exclusively with aircraft tyres wheel and brake units. Is there an exemption for duty on this?
Yes. However, customs declarations are the default position on all goods moving after 31 December. For aircraft parts there are options around special procedures that can be applied for in advance there’s information at both Special Procedures guidance https://www.gov.uk/guidance/check-if-you-can-pay-less-duty-if-your-goods-are-imported-into-end-use#civil-aircraft-and-aircraft-parts
Also relevant is ‘Aircraft parts imported with an Authorised Release Certificate’ https://www.gov.uk/government/publications/uk-trade-tariff-suspensions-from-customs-duty/uk-trade-tariff-suspensions-from-customs-duty#aircraft-parts-imported-with-a-certificate-of-airworthiness which will be bound up in ongoing negotiations.
What about goods that are transiting the UK. Would they need customs export declarations?
If transiting the UK for Ireland, then Yes, customs declarations will be required. The TSS service is there to help with this. A Northern Ireland importer will require a different EORI number starting with XI and if you register to the TSS site, this will be automatically issued.
What is the cut off point for entering data on the system before entering the clearance point?
For exports from UK via Eurotunnel – 1 hour and from Dover 2 hours.
For other points of exit, either UK or EU 2 hours.
Would the App automatically register the export on the HMRC CHIEF system?
Yes.
