James Hookham Director, Global Shippers Forum
As this article was written, it was widely expected that the UK Government would announce a further delay to the introduction of documentation requirements and physical checks on certain types of goods imported from continental Europe.
Although no official statement had been made, media reports speculated this was partly because the costs of compliance would add further to a cost-of-living crisis the government is hoping to bring under control. The fact that new border checks on goods could move the dial on consumer price inflation says something for the complexity of the new controls and the scale of the added costs they are likely to impose on Industry. Furthermore, the costs to Government’s costs of implementing and enforcing them was also expected to be recovered from importers and hauliers through new fees and charges.
The reported delay was greeted with relief by British business groups. There will possibly be mixed reactions from the service operators and ports through which much of this traffic will pass and where the border checks would be carried out. Relief no doubt that potentially disruptive checks have been postponed, but possibly some frustration that the investment of time, money and effort made in preparing for the expected introduction of these processes from 31 October this year, has yet again been in vain.
The postponed controls are the final layer of border checks on goods that the UK needs to introduce as a result of leaving the Single Customs Union and the Single Market of the European Union in 2021. The checks would be on shipments of foods, animal and plant products, to ensure they comply with the UK standards for safety, hygiene, welfare and absence of pests, contaminants or prohibited items. Physical checks by UK Border Officers would be carried out on selected goods vehicles arriving in the UK, either by ferry or via Channel tunnel shuttle trains, based on review of pre-submitted Customs declarations, or other intelligence.
Whereas the checking of passports still takes place in the country of departure, border checks on goods must take place on the territory of the receiving nation. For Cross-Channel ferry operators and for Getlink, the operator of the Channel Tunnel freight shuttle, this means finding sufficient space in their already constrained UK facilities to accommodate new physical accommodation and inspection areas for government agencies to carry out these checks.
These constraints are particularly acute at the Port of Dover, where its location at the foot of the ‘White Cliffs’ makes detaining too many vehicles within the Port itself a ‘non-starter’. Space availability is not much easier at Getlink’s Folkestone terminal, confined as it is by the North Downs and the M20 motorway.
Nevertheless, much thought and planning by port and service operators has gone into providing the UK government with the facilities it has specified, whilst maintaining the free-flowing traffic conditions essential to the smooth operation of service schedules.
The sensitivity of Cross-channel operations to ‘border delays’ was revealed in Summer 2022, when processing of outbound passengers through passport control had been insufficient to match scheduled service frequencies, resulting in long queues on the approach roads to Dover and Folkestone.
The need for border checks was only confirmed quite late in the Brexit process. Until the General Election in 2019, the UK government’s official position had been to exit the EU Customs Union and Single Market, but to negotiate a ‘frictionless’ trade deal where none of these controls would be necessary. After the election, and the acceptance of hard borders in the Trade and Co-operation Agreement (TCA) struck by the UK and EU, industry had barely a year to devise, implement and adapt its EU import and export procedures for the new border regime.
The EU duly implemented full border requirements for all goods from the UK from 1 February 2021, whereas the UK government has introduced its border controls in stages, with the final requirements for sanitary and phytosanitary checks on animal and plant products, plus the re-introduction of Safety and Security declarations scheduled for implementation still outstanding.
The onset of border controls has prompted many businesses to rethink the routeing of their UK-EU movements. This has also been driven by an acute shortage of truck drivers willing to travel abroad, plus a reluctance by EU drivers to lose up to a couple of days’ work waiting on border queues. The option to use short-sea services for unaccompanied trailers has become more attractive, with volumes growing as service operators respond to demand. Government agencies have also been required to find, recruit, and train the border staff necessary to implement and enforce the new controls.
The commissioning of a new UK Customs Declaration System (CDS) through which all import and export transactions would be made has also added to the pressure. These internal factors, as well as the time needed for industry to adapt, will have been influential in deciding the timing of the introduction of the new controls.
Brexit did not stop goods being traded with Europe, but the TCA did introduce a host of new administrative procedures costs that previously were not considered necessary.
Europe remains the UK’s biggest trading partner by some margin and the ports and operators serving the cross-Channel and North Sea routes have a common goal in making navigation of the UK-EU border regimes as seamless an experience for their freight customers, as and when they are fully introduced.
GSF is the global trade body that speaks up for and advises shippers and cargo owners in the conduct of international trade. For more information, please visit: www.globalshippersforum.com