BPDG Shorts Straits Webinar: Moving goods from the EU to Great Britain - CILT(UK)
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BPDG Shorts Straits Webinar: Moving goods from the EU to Great Britain

25 November 2021/Categories: CILT, Industry News, Freight Forwarding, Logistics & Supply Chain, Brexit, Corporate News


Following its Short Straits Technical Webinar, the government has created a frequently asked questions document, with links to further guidance as well as a summary of the main topics. 

 

For those of you who were not apple to attend the full event, or who wish to watch the webinar again, a YouTube link is available here

The government received a high volume of questions during and after the webinar and would like to share the answers in the attached xls document. 

This document is in two parts:

Part 1 - a summary of the main question themes on the call

Part 2 - a list of links and FAQ document

Part 1 - Key questions themes

Themes in questions and answers

GVMS

● Clarity on the changes for 1 January for customs agents. HMRC clarified for movements between EU & GB a GMR will be required for all goods moving through GB ports that have adopted GVMS from 1 January 2022. A GMR should contain the following types of detail for the following movements:

○ Imports declared into CHIEF or CDS (Entry Reference Number for CHIEF (ERN) or Movement Reference Number (MRN) entered into GMR

○ Entry in declarants records (EIDR) where Trader declares into their own records (Trader EORI entered in GMR)

○ ATA or TiR Carnet movements (Carnet reference numbers entered into GMR)

○ CTC Common Transit convention movements (Transit Accompanying Document (TAD) MRN entered into GMR

○ If you need to make an oral or declaration by conduct or are moving empty vehicles/trailers/containers , then you will need to complete a GMR too. Further options will be made available to enable such movements through GVMS. Please refer to the guidance: goods that can be declared orally or by conduct.

● ‘Testing’ for users of GVMS. There is no test environment for GVMS, however HMRC are currently recruiting hauliers to take part in testing of movements from EU to GB. If you would like to participate, please contact: euliveproving@hmrc.gov.uk

● Training resources for using GVMS. GVMS "Show and tell" webinars will start from the end of November.

● Overall responsibility for registering for GVMS. The Haulier moving the goods is responsible for registering for GVMS and creating a GMR, but that can be passed to a 3rd party such as an agent or other intermediary.

● Implication for failure to register a customs reference. Declarants have a legal obligation to pre-lodge declarations if they are moving their goods through a location using the pre-lodgement model. Hauliers have a legal obligation to carry evidence that a pre-lodged customs declaration is in place for all of the goods they are moving. This is met by hauliers carrying a GMR which must include a declaration reference for each consignment as proof that a pre-lodged declaration has been made. HMRC reserves the right to apply penalties if these obligations are not met by traders and hauliers.

● How the driver will check GVMS.

○ The driver can check this information themselves, without access to GVMS, using the "check if you need to report for an inspection" service on GOV.UK. They will require a device such as a smartphone with a  WiFi/Cellular connection. If the driver is unable to access the "check if you need to report for an inspection service" they will need to contact their haulier or 3rd party to check the status of the GMR.

○ Some ferry companies also pass held/cleared messages, for example by displaying on screens in driver lounges. Please contact your carrier to find out if they offer such a service.

○ The responsibility for ensuring reasonable steps are taken to ensure a driver knows they need to report for an inspection lies either with the haulier or 3rd party appointed to complete the GVMS actions by the haulier.

● Liability for users who do not attend inspection. The Haulier responsible for bringing the goods into GB if they have been advised of a control would be liable to present those goods.

Other parties are at risk of incurring penalties and liability is dependent on a case by case basis based on roles and responsibilities.

Inland Border Facilities

● Communications to if a consignment is required to be inspected. The Driver / Ferry Operator (for unaccompanied) must check the status of the consignment(s) on GVMS and GVMS will notify haulier / carrier / port operator with tentative routing outcome

● Timings at IBFs. Vehicles are instructed to leave the site after 2 hours

Safety and Security issues

● Fewer forms. Participants questioned the need for ENS and EXS entries and why these could not be included in import or export declarations.

● EXS requirements for empty vehicles. Normally an export of goods will have a full customs declaration which includes the necessary safety and security information. In the case of empty vehicles, containers or reusable packaging, where a full customs declaration is not in place, the EXS is required if you are moving under a transport contract.

Transit

● Offices of Departure. HMRC confirmed Stop 24 and Dover can both be used as Offices of Departure for CTC as a commercial function.

● Multiple Transit Accompanying Documents (TAD) for one transport/load. All Transit Accompanying Document (TAD) on the trailer / container do need to be entered into GVMS. As GVMS is currently only required for Transit movements it will be updated from 1 January 2022 to allow the entry of all other types of customs references that are required from that date

Other customs rules

● Timing to receive an EORI number. You'll usually receive the EORI immediately unless HMRC needs to carry out checks in which case it can take up to 5 working

French processes

● Unclosed EADs. Unclosed EADs can cause problems with French customs. Drivers will need to scan all export MRNs at the border so that exports are discharged correctly.

Part 2 - FAQs and links

GVMS

Q. Do I need a GB EORI to register for GVMS? If so, how long will it take to receive it?

A. Yes you will need a GB EORI.You usually receive the EORI immediately unless HMRC needs to carry out checks in which case it can take up to 5 working days https://www.gov.uk/eori/apply-for-eori

Q. Will there be training for traders and hauliers?

A. The following video shows how GVMS works and the haulier’s responsibilities.  https://www.youtube.com/watch?app=desktop&v=yhkHEckLCcg.With

Q. Is HMRC carrying out testing on GVMS?

A. There is no test environment for GVMS, however HMRC are currently recruiting hauliers to take part in testing of movements from EU to GB. If you would like to participate, please contact: euliveproving@hmrc.gov.uk

Q.When does the agent actually lodge the Import declaration with CHIEF?

A. If you are moving goods through a pre-lodgement port then you must make the import declaration in CHIEF/CDS before the goods move - you then pass the Movement Reference Number (MRN) to the haulier so they can use this in GVMS.  Details on when and how to submit a full import declaration can be found here: https://www.gov.uk/guidance/making-a-full-import-declaration

Q. Can only one GMR be submitted by the haulier/driver?

A. More than one GMR can be raised.  Please find more information on GMR here: https://www.gov.uk/guidance/get-a-goods-movement-reference

Q. Which UK ports are using GVMS?

A. There is a list of GVMS using ports available on gov.uk and this will be updated further with additional ports using GVMS before 1 January 2022 https://www.gov.uk/guidance/list-of-ports-using-the-goods-vehicle-movement-service

Q. How will I know if I have to go to an IBF for an inspection?

A. Drivers will be notified through GVMS. Please see link on how to check if you need to report for an inspection: https://www.tax.service.gov.uk/driver-inspection-notification/start 

Hauliers/Drivers

Q. What happens if a driver is running out of duty time whilst at IBF?

A. We wouldn’t force or ask drivers to leave if that meant them breaking the law, but it’s encouraged that break times are taken before arriving. https://www.gov.uk/drivers-hours/eu-rules 

Safety and Security Declarations

Q. Will an EXS declarations (GB>EU) for the empty trailers be required if moving under a transport contract?

A. In the case of empty vehicles, containers or reusable packaging, where a full customs declaration is not in place, the EXS is required if you are moving under a transport contract. https://www.gov.uk/guidance/find-out-when-to-make-an-exit-summary-declaration

Q. Where do we submit the EXS declarations?

A. Exit summary declarations are submitted on the Customs Handling of Import and Export Freight (CHIEF) system, in the same way as an export declaration, for goods exported from Great Britain: https://www.gov.uk/guidance/find-out-when-to-make-an-exit-summary-declaration

Q. If a Haulier doesn't know how to submit an ENS, can a custom broker submit it on their behalf?

A. The legal requirement to submit a declaration lies with the operator of the active means of transport on, or in, which the goods are brought into the Customs territory. A third party may lodge a declaration as long as this is done with the carrier’s knowledge and consent, but the legal responsibility remains with the carrier. Further advice can be found on gov.uk at this link: https://www.gov.uk/guidance/appoint-someone-to-deal-with-customs-on-your-behalfA list of software developers providing customs declaration support can be found on gov.uk at this link: https://www.gov.uk/guidance/list-of-software-developers-providing-customs-declaration-support

Q. What information has to be submitted in the entry summary declaration (ENS)?

A. There is a full list of data items on gov.uk for ENS here https://www.gov.uk/government/publications/safety-and-security-requirements

 


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