It is still uncertain if the UK and the European Union will be able to strike a deal on the UK leaving the EU in March 2019. A communication from the UK government last December made clear that in case of a no deal, many UK businesses will need to apply the same processes to EU trade that apply when trading with the rest of the world. The same goes for companies on the European mainland that need to apply the proper processes when bringing goods into the UK. Businesses and carriers using roll-on-roll-off locations to transport goods between the UK and the EU will have to submit customs declarations and pay any customs duty, excise duty or VAT that is due.
For most companies this is common knowledge. However, it is less well-known that exporting goods to the UK will also require a security filing. The UK has put the haulage companies (or someone acting on their behalf) in charge of submitting safety and security information through an Entry Summary Declaration before the goods arrive in the UK.
Security filings air and sea
Security filings are meant to enable authorities to determine the risk of a shipment. They have become commonplace in international trade after the attacks of 9 September 2001 on the World Trade Center in New York. The filings are well-known in worldwide air and sea transport. For companies that only trade within the EU, they are less familiar as they are not required within EU borders. They only apply to goods entering the EU by road from for example Russia or Turkey. Even non-EU members Norway and Switzerland do not require security filings, thanks to agreements with the EU on this matter.
There is an important distinction between the regular customs declaration and security filings, as the latter need to be submitted at least two hours before the goods are due to arrive in the UK when transported by truck. If the goods are being transported through the Channel Tunnel by Eurotunnel, a declaration must be submitted at least one hour before check-in at Coquelles. This makes security filings more critical than the regular customs declaration, which can also be submitted when the goods are already delivered in the UK in a bonded warehouse.
Prepare security filings now
Haulage companies should not underestimate the consequences of this new rule. They need to have a process in place to support security filings that can only be submitted electronically. In general, there are two main ways to submit these filings: find a service provider and process all filings manually through the service provider’s network. Obviously, this can be very time-consuming for companies that have a main focus on the UK. A better alternative is adding security filings to their existing customs systems and have their service provider take care of processing their submissions. Descartes for example supports the security filing process with its Descartes Import Control System™ (Descartes ICS™) and Descartes Export Control System™ (Descartes ECS™) Solutions. They help carriers and logistics intermediaries overcome the complexity of ICS compliance by providing a single point of access to manage ICS filings according to specific requirements. These solutions leverage the power of the Descartes Global Logistics Network™ (Descartes GLN™), enabling carriers to electronically connect with brokers, shippers and regulatory authorities around the world through a single portal, without having to worry about data formats or specific state requirements. This results in reduced risk and improved compliance, as well as in improved efficiency and productivity.
For haulage companies it is advisable to prepare for security filings now, so they are ready in case of a no-deal Brexit. They should not wait until the last moment as the consequence could be that it will not be possible to submit filings at all, which means goods cannot enter the UK.