TOM common user charge (CUC) consultation - CILT(UK)
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LATEST NEWS

TOM common user charge (CUC) consultation

27 June 2023/Categories: Freight Forwarding, Logistics & Supply Chain, Operations Management


DEFR published the CUC consultation on Monday 12 June as set out in the Borders Bulletin of 23.06.23. Submission of this important consultation is by 09.07.23.

After initial publication in the TOM draft engendering substantial criticism in the April 17 stakeholder meeting it has now become a consultation containing a number of detailed explanatory documents that set out the terms of reference and terms of use.

It is clearly intended as a blanket tax to pay for the operation of Sevington IBF and no doubt White Cliffs BIP if it is brought into use (neither mentioned by name - just Government-run BCPs) which although likely to be imposed on the Welsh BIPs too, is primarily intended to impact the Short Straits EU SPS/phaetosantitary imports.

The charging model is included in the consultation document (p6 - 7 of 15). It is still by consignment - each eligible item listed in a Customs declaration- irrespective of whether eligible consignments are selected for BCP checks or just passing by.

There is a potential discount structure for “low risk” animal product consignments unlikely to be inspected at the BCP - but not a waver - they mention £10/ consignment rather than £20-£43 - all to be administered by a third party, TBC.

On p8 under Trusted Trader (TT) - still being developed under the Eco-System of Trust- it implies that under membership of the TT scheme ("selected by a clearly defined set of robust criteria") certain consignments may be exempted from the CUC.

The key to calculating the cost effect that the CUC will have on the perishable supply chain will be the tariff classification for SPS commodities: I e the CUC value of a “consignment” of perishable produce - and whether a consignment will be accepted as a pre-registered trailer load of the same SKU although from different grower sources as certified as with Spanish produce by a government registered consolidation centre or not. The potential risk for unwary importers is considerable, but at the stakeholder meeting a DEFRA rep admitted to wanting to incentivise transport by the larger transporters registered under the Trusted Trader scheme. So it is vital that the consignment and tariff band definitions are clarified before making the response.

The status quo for SPS with all the current safeguards allowing registered (trusted) traders to deliver directly to registered distribution premises, given that FSA intelligence is already in place, operates perfectly well for Short Straits RoRo imports. This is just a revenue recovery exercise. Potentially impacted CILT members should call it out.

Jolyon Drury FCILT

 

 

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