The UK has entered the next stage of Brexit. As part of the phased implementation of the UK Operating Border Model, most of the simplifications for entering and exiting goods in the UK have now been removed.
The changes include the introduction of customs controls, the pre-lodgment notifications via the good vehicle movement service (GVMS), as well as pre-notifications for sanitary and phytosanitary goods. In the first months of 2022, this has led to significant challenges and delays with importing and exporting products in the UK.
GVMS is the UK platform for moving goods into or out of Great Britain via most ports and the Eurotunnel. For Transit movements, GVMS has been in use since 1 January 2021. From 1 January 2022, GVMS is also required for all import and export movements that require a pre-lodged customs declaration; this includes all movements via Dover and Eurotunnel. More than 80% of all shipments into and out of the UK now require a GVMS entry to be lodged. Up to 10% of these shipments fail to clear customs, resulting in lorries/trucks being refused permission to board the ferry or train.
A key issue is failing communication between the parties involved in importing and exporting products. The haulier is responsible for lodging the GVMS entry, but the haulier often does not have all the required information (on time), which makes it impossible to lodge the appropriate GVMS entry.
The customs reference number that needs to be used to create the GVMS entry depends on the type of movement (e.g. transit) and/or the customs declaration system that is used in the UK (i.e. CHIEF or CDS). This may confuse EU hauliers and lead to GVMS entries being invalid and/or not linked to the relevant customs declarations in the UK.
Furthermore, it appears that the GVMS system and communications with the customs declaration systems occasionally experience technical issues. This results in mismatches in GVMS, missed arrival clearances, as well as ‘ghost’ clearances of shipments that have not arrived yet, making the submitted GVMS entry invalid for the shipment itself.
In each of these situations, the only resolution is for all the parties involved to work together and to establish transparent lines of communication.
The partial introduction of sanitary and phytosanitary controls also leads to additional red tape for importing products into the UK. All products that are subject to sanitary and phytosanitary controls now require a pre-notification to enter the UK.
Products originating from the EU and most products that have undergone sanitary and phytosanitary controls upon their importation into the EU can – until 30 June 2022 – enter the UK without presentation of the shipment to the Border Control Post (BCP).
All other products already need to be presented to the BCP, in addition to the requirement of pre-notification to enter the UK.
It is important that the traders, the hauliers, and the customs clearing agents have a full understanding of the products being shipped, including whether any sanitary and phytosanitary controls may apply. Otherwise, the goods are at risk of being stopped, seized and potentially destroyed when arriving in the UK.
The next phase of the UK Customs Border operating model will commence on 1 July 2022, which will introduce further certification and border controls on imports. This will include controls on sanitary and phytosanitary products as well as ‘organic’ products originating from the EU.
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