Third up in our Brexit blog series this week, we take a look at a letter written to the Chancellor last week from the Treasury Committee. Highlighting a number of outstanding concerns for the UK’s new external border, the letter asks some really good questions of when and how these outstanding issues will be addressed. With just 65 days to go the until the end of the transition period time is tight.
The letter signed by Mel Stride MP specifically addresses issues deemed unsolved following a Treasury Committee evidence with Lord Agnew. The letter identifies nine areas that that the committee are left troubled by, as well as a series of questions from the session where the committee is still seeking further information. The letter sent on 22 October 2020 can be found here.
Some of the key IT systems and tools to support traders including the GVMS system and How to Check an HGV are currently undergoing testing and new functionality continues to be requested. The Committee is concerned that the IT will not be ready in time to allow companies to prepare sufficiently. This is echoed by key software developers.
The letter explicitly asks what contingency plans have been prepared in case the systems are not ready for the implementation of customs declarations.
Border Operating Model (BOM)
Following the publication of the BOM V.2 the Treasury Committee is concerned that there is no guidance yet on which Ports will be operating under the new GVMS scheme as this is a commercial decision for Ports to make. The letter also questions when remaining gaps in the BOM V.2 will be reviewed and resolved.
Northern Ireland Border Operating Model
We await the publication of the NI BOM, and the letter calls for this to be published by the end of the month in order to support firms in NI that are facing changes to trade from 1 January 2021.
Reliance on Customs Agents
Current Government guidance for trading with the EU at the end of the transition period urges businesses to use Customs Agents. However, the recruitment and training of these third-party providers is out of Government control and there will likely be a shortage due to increased demand levels. The letter to the Chancellor asks explicitly what the back up plan is if the supply of new Customs Agents doesn’t materialise.
Worst Case Scenario Emergency Measurers
Linked to the high-profile outcries from hauliers about the conditions they will find in the proposed HGV holding parks, the committee requests assurances the necessary facilities will be in place.
In line with information provided in the BOM V.2, the letter raises concerns that sites are currently incomplete with very few days left before they will be required to be used. The committee have requested a list of every new physical site required to support the new UK border.
Additionally, the committee are concerned about the planned use of Kent Police resources to manage vehicles on the motorway with incomplete or incorrect paperwork and want to know when the ANRP technology will be able to communicate with the Smart Freight systems too.
In the evidence provided by Lord Agnew he expressed concern at the lack of trader readiness. Whilst the Committee share this worry, the letter suggests businesses can’t prepare for certain outcomes still unknown to them. The committee urges Government to focus efforts on finalising guidance, reading systems and completing negotiations before accusing companies of lack of preparedness.
EU Port Preparedness
The fact that there is little oversight on the level of preparedness at EU ports is extremely concerning given the impact this could have on UK traders. In the letter, the Committee ask for confirmation on EU ports preparedness compared to the UK and the expected processing speeds for inbound vehicles.
Additionally, in the evidence session Lord Agnew suggested that a lack of agreement with the EU would result in life being ‘more difficult’ with regards to EU customs checks, and the committee wants to know if the Chancellors agrees, ADS certainly does.
Lastly, the Committee is looking for fortnightly updates on the recruitment process within HMRC. With around 1,000 roles still to fill there is a concern this won’t be complete (with training) by 1 January 2021.
Why this is important for ADS
As noted, this letter is addressing a huge number of the issues ADS and our members have been raising with government departments at every opportunity.
Securing a reasonable response from the Chancellor with genuine contingency plans outlines and gaps in guidance filled would be huge for our sectors at this crucial time. Hopefully by now readers know to head to the ADS Brexit Hub and Risk Register, to keep up to date on the latest developments as we get them clarified.