Firms need to prepare for new import controls

Firms need to prepare for new import controls

Brittany Ferries is one of the ferry operators currently operating around 68 RoRo freight sailings between Ireland and the continent.

GOVERNMENT departments and agencies are encouraging export businesses to prepare for the next phase of UK import controls which are coming into effect on April 1, 2021.

It’s now over eight weeks since the end of the Brexit transition period, and with one month to go until the imposition of further UK import requirements, exporters in Ireland need to engage with everyone in their supply chain, including their UK importers, to ensure that they are clear on their roles and responsibilities and have the capacity to meet them.

These new requirements will impact exporters of all products of animal origin, including all meat, dairy, fish, and composite products incorporating products of animal origin, as well as regulated plants and plant products.

Over the past two months, we have seen businesses and individuals adapt to the changes brought about by Brexit, and while challenges remain, Government Departments and agencies are continuing to engage with stakeholder groups, sectoral representative bodies, businesses, and individuals to assist and support them.

Freight vehicle movements into Ireland from Great Britain have increased from 1,423 movements in the first week of the year, to 7,263 movements last week. There are however indications that the rate of growth is now flattening. The situation continues to be monitored closely.

For the eight-week period in 2021 (Jan-Feb), ROI-GB freight volumes are down by around 40% and up on direct Continental services by around 80% compared to the same period in 2020. This is due to a number of factors in addition to the new Brexit-related checks and controls, including significant stockpiling at the end of 2020, greater use of direct routes, and the continuing impact of the COVID-19 pandemic.

We are also continuing to monitor outbound trade volumes, in advance of the introduction of new UK Checks and Controls. Outbound movements into Great Britain from Ireland have increased each week since the end of the transition period, with a daily peak of 1,388 movements on February 25th. We continue to see strong demand for direct maritime services to the continent.

New UK Import Controls 1st April While the EU-UK Trade and Co-operation Agreement provides for tariff-free, quota-free trade and for sectoral cooperation in a number of important areas, Brexit has a far-reaching and lasting impact on business and citizens in Ireland and across the EU.

The UK is no longer a member of the Single Market or Customs Union, which has resulted in new customs and SPS requirements These requirements came into force on 1st January 2021 across the EU, and the UK will introduce its next phase of import controls on exports from the EU from 1st April 2021.

It is absolutely necessary that everyone in the supply chain - from the exporter to the customs agent, to the UK importer, to the logistics, freight forwarder or haulage business, to the driver - knows and understands these new requirements and the role they will play or actions they will be required to take to ensure the supply chain operates and functions as an integrated whole and that the relevant customs and other regulatory formalities are completed on a timely and efficient basis.

Export certification requirements will have to be fulfilled for exports to the UK, excluding Northern Ireland. These requirements are set by the UK authorities.

Since the 1st January exports of live animals and germinal products have required export health certification; marine-caught fish and fishery products must be accompanied by IUU Catch Certificates; and high priority plants and plant products must be accompanied by a phytosanitary certificate. The Department of Agriculture, Food, and the Marine is providing most certification with the Sea Fisheries Protection Authority (SFPA) providing the IUU Catch Certificates.

On 1st April, the UK will introduce new import controls on products of animal origin, including all meat, dairy, fish, and composite products incorporating products of animal origin, as well as regulated plants and plant products.

This will mean that, in addition to the necessary customs formalities, Irish exporters exporting to or through the UK, excluding Northern Ireland need to comply with a number of new UK requirements. Your UK importer will have to pre-notify the UK authorities of the goods, you will have to get the appropriate Health Certificate(s) from the Irish authorities and you will have to move the goods together with this Health Certificate(s).

It’s crucial that exporters fully understand these new UK import requirements and ensure everyone in the supply chain, including your UK importer, is clear on their roles and responsibilities and can meet them.

The HSE has been engaging with food businesses under its supervision which export to or through the UK regarding export certification. However, in light of the Protocol on Ireland and Northern Ireland, none of these new controls apply to North/South trade.

Exporters under HSE supervision who may require export certificates should contact exportcertificates@hse.ie to signal their certification requirements.

The type of health certification is different for different categories of the product of animal origin therefore consignments with different products may require a number of health certificates.

Further details with regard to the Import of Products of Animal Origin for human consumption to GB and the documentation required can be viewed at available on http://apha.defra.gov.uk/ A major government campaign aimed at exporters is underway across all platforms: print, radio, and digital advertising. This will be complemented by ongoing stakeholder engagement at both national and local levels including a broad series of webinars throughout February and March including joint webinars, between Revenue and DAFM, and with UK HMRC and DEFRA.

Operations at the Ports & Trade Flows Customs and SPS formalities are now an integral part of trade with Great Britain following the UK’s departure from the EU.

These customs formalities and other regulatory requirements form part of Ireland’s responsibility, as a member of the EU, to maintain the integrity of the Single Market and the Customs Union.

In practical terms, these requirements mean there will never be a scenario where all goods (100%) arriving into Ireland from Great Britain will be able to move as seamlessly as they did when the UK was a member of the EU. Revenue’s approach to this new trading environment is designed to facilitate legitimate trade.

The submission of accurate and complete customs declarations in advance of moving the goods and the creation of the relevant pre-boarding notification before the goods leave for the departure port are effective measures in facilitating the speedy movement of trade through our ports.

Trade is adapting to these new requirements as evidenced by the fact that approximately 80% of freight vehicle movements into Ireland from Great Britain are now getting a green routing and can immediately leave the port.

For the remaining, approximately 20%, certain goods are orange routed meaning they need a documentary check or similar control and some goods are red routed meaning there is a requirement for a physical examination or inspection of the goods.

Since 1 January 2021, there have been over 47,200 freight vehicle movements into Ireland, across 824 ferries, from Great Britain - 79% were green routed, 17% orange routed, and 4% red routed.

In the same period, there have been almost 43,600 freight vehicle movements out of Ireland to Great Britain.

Since 1 January, Revenue has successfully processed over 2.6 million import declarations of various types, including for example in relation to both freight vehicle movements and postal parcels and safety and security declarations.

Additionally, over 320,000 export declarations for goods movements to Great Britain were also processed.

A total of 13,650 calls to Revenue’s 24/7 Customs Helpline were answered for the period 1 January to lunchtime 25 February 2021.

Traffic volumes within Dublin Port and the surrounding road network continue to be monitored on a daily basis. The Port has remained at status green since the 1st of January, with no escalation beyond that. Traffic management plans remain in place to deal with traffic congestion, should it occur at Dublin Port and by extension impact on Dublin City (particularly the Dublin Port Tunnel and motorway system).

Sanitary and Phytosanitary (SPS) Checks In addition to customs procedures, the EU’s SPS rules now apply to all imports of animals, plants, and products of animal and plant origin from Great Britain, just as they do to goods coming from other non-EU countries.

The volume of goods requiring SPS import controls at both Dublin and Rosslare ports has been relatively low. However, and despite good efforts in general by operators to comply with EU requirements, there has been incidence of non-compliance with pre-notification and documentation requirements. This has led to the checks taking longer, or to some consignments being detained until the issues could be resolved.

The challenge the new checks due to Brexit create for traders is fully acknowledged – and there is ongoing intensive engagement with stakeholder groups, sectoral representative bodies, businesses, and individuals to assist them through the new processes.

Traders are reminded of the importance of registering with the Department of Agriculture, Food and the Marine and on the EU TRACES system, and of submitting all required documentation in a timely manner.

The Department of Agriculture, Food and the Marine continues to provide advice and support to agri-food businesses at Border Control Posts and through a dedicated Brexit support line on 076 106 4443 and email Brexitcall@agriculture.gov.ie, Direct Routes & Additional Capacity Ireland’s economic success is dependent on its ability to trade internationally. Sea-borne freight accounts for 90% of Ireland’s merchandise trade in volume terms.

We have witnessed throughout 2020 and at the beginning of 2021 an unprecedented response from the shipping industry in terms of increasing capacity to match market demand. It has occurred across all relevant modes and has drawn from all available responses. These responses include (1) utilization of surplus capacity, (2) increasing capacity by altering schedules, (3) redeploying vessels within their fleets, and (4) adding new capacity in the form of additional vessels.

Number of Sailings As of February 2021, there are around 68 RoRo freight sailings between Ireland and the Continent in a typical week. This includes five shipping operators, Irish Ferries, Stena Line, DFDS, Brittany Ferries, and CLDN offering both accompanied and unaccompanied freight. This represents an increase of around 34 sailings per week, or around 150% increase in continental RoRo frequency compared to February 2020.

Freight Capacity The increase in choice and frequency in the RoRo freight market over the past year has had a very significant impact on freight capacity to continental EU ports. Weekly RoRo freight capacity to continental EU ports has doubled in the past 12 months.

The largest increase in capacity has come on RoRo services to Northern France. In January 2020, capacity to Northern France represented 35% of all continental EU capacity. As of February 2021, it now accounts for around 49%.

Unaccompanied RoRo freight is an essential component of continental RoRo capacity. In 2020, unaccompanied RoRo freight made up over 80% of all continental RoRo volume.

Overall weekly RoRo freight is up on direct routes to the continent while it is down on GB/Ireland routes due to a combination of factors such as COVID 19 restrictions, seasonality, stockpiling in 2020, shifts to direct RoRo routes to the continent, shifts to unaccompanied freight (both RoRo and LoLo) and new customs arrangements.

Details of growth in direct services There have been 22 separate interventions by Ro/Ro+ Lo/Lo freight operators in the past 12 months in response to Brexit. What the last number of months have demonstrated is the resilience and responsiveness of the Irish Shipping Industry. It has adjusted swiftly and comprehensively to the changes in demand from business and provided a range of additional services, frequency and capacity options to transport goods to continental markets.

These new direct routes set out in the table below* have given Irish importers and exporters additional choices and a range of effective and efficient options to avoid any current disruption being experienced on the UK landbridge. The market remains dynamic but has demonstrated it is willing and able to respond to the changing needs of business.

Supply Chain Close engagement with the retail sector, wholesalers, and grocery distributors is continuing, and the Department of Enterprise, Trade and Employment’s Enterprise Information Centre helpline is assisting businesses and consumers on a daily basis.

Government Departments and agencies are working with retailers and colleagues here and in the UK to ensure continuity of supply. Supply chains have been built up over time and will take time to readjust. Any isolated issues are being worked through and we continue to be assured by retailers that supply is robust and strong at shelf level and stores are well stocked.

Government Supports A range of Government supports, including advisory, upskilling and financial supports are available to assist businesses in responding to the challenges of Brexit.

The Department of Enterprise, Trade and Employment (DETE) has been to the fore in helping businesses to deal with Brexit and continues to provide grants and training to assist with new customs arrangements arising from Brexit.

Uptake of the €9,000 Ready for Customs grant (for each new employee hired into a customs role), has increased and is assisting businesses with staff training as they adjust to the new trading environment and changes to their supply chains. Businesses have recruited over 1,300 staff using this grant to date. The Brexit Loan Scheme, made available in cooperation with the SBCI and the European Investment Fund, continues to offer low-cost finance of up to €1.5m to eligible Brexit-impacted businesses as they pivot and adapt to new markets and suppliers.

The Local Enterprise offices have seen significant interest in the online Customs Workshops with 425 businesses attending 32 workshops across the country. Further events are scheduled over the coming weeks. InterTradeIreland events have also explained and assisted on issues specific to the Northern Ireland Protocol and trade across the border.

Businesses and consumers engaging in business online have been guided on complex issues of consumer rights and potential additional charges by ongoing updated advice from the Competition and Consumer Protection Commission (CCPC).

A number of webinars, including webinars specific to the UK Import Controls that will be introduced from 1 April, are being run by the Irish Government or by the UK Government.

Bord Bia offers training in customs and tariffs, supply chain management, and Sanitary and Phytosanitary (SPS) requirements tailored for the needs of the food and drink sector.

Bord Iascaigh Mhara helps to develop the Irish Seafood Industry and has further information on its Brexit Hub.

Clear Customs training delivered through Skillnet Ireland continues to be available to Irish businesses, and includes a dedicated module on import and export for the agriculture sector in which participants can enroll.

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