On the summary exit declarations, @SteveBarclay mentioned today. It's important to understand what they are, why they are submitted and how they differ from #customs declarations.
/1
@SteveBarclay Exit/entry declarations are slightly different than customs decs. Before import/export there is a requirement to submit a pre-arrival, pre-departure notification - info that allows authorities to control what's moving across borders from a safety and security perspective.
/2
@SteveBarclay This information is mainly used for risk analysis and not to calculate the amount of duties due or apply other trade policy measures as in the case of customs declarations.
In principle, they are submitted by the carrier not the importer/exporter
/3
@SteveBarclay For imports, the process is slightly different as you need to submit them before the goods arrive (as the name pre-arrival suggests). Deadlines depend on the mode of transport - up to 2h before arrival
/4
@SteveBarclay On export, in theory also needs to be done before the goods depart but that is usually done at the same time when submitting a customs export declaration. For obvious reasons, the procedure here is less strict as the goods are leaving the territory.
/5
@SteveBarclay So very different from import where it's a separate doc with separate data fields - for entry summary decl info that needs to be provided is all around the mode of transport and parties involved with only some customs info included (HS code).
/6
@SteveBarclay On export, this can be done on the same form as customs declaration.
So in terms of NI and Secretary's comments, the short answer is we don't know what this will look like - it will be discussed and agreed by the Joint Committee during the TP if the deal passes
/7
@SteveBarclay The normal procedure is to have both entry/exit decl and customs declarations.
However, countries like Norway and Switzerland have reached an agreement with the EU that allows them to wave that requirement when trading with the EU
/8
@SteveBarclay Instead, pre-arrival notification is submitted once - for example when goods enter Norway from a third country.
So that could be one option for NI-GB trade. However, there is an alternative.
/9
@SteveBarclay With earlier versions of the proposal, i.e. the backstop, there was this notion of trying to use pre-notifications instead of customs declarations.
/10
@SteveBarclay That was slightly different as there was also the A.UK document as a result of the UK being in a customs union with the EU under the backstop- getting bit technical
/11
@SteveBarclay But basically, there potentially could be an option to do that - perhaps for the goods that are not considered high-risk and are exempt from tariffs under the new deal? We really don't know what the thinking is here
/12
@SteveBarclay And as mentioned - all the customs technical details to be agreed by the Joint Committee under the TP. It seems clear, however, that there will be some paperwork for goods going both ways (NI to GB and GB to NI)
/13
@SteveBarclay So whatever these forms will be - it will be very different from what we have now - additional paperwork and time required. Not because of what the Secretary said today but because the new Deal includes a de facto customs border in the Irish Sea
/14
@SteveBarclay And that's what having one means. I think it's just now starting to slowly sink in.
That is why all the details that are not currently in the #BrexitDeal - the things to be negotiated by the JC - are so important.
/15
@SteveBarclay Without knowing HOW all this is going to be implemented, it's really hard to understand how this will impact businesses, hauliers etc. It's also why 14 months might not be enough to discuss, agree and implement all that needs to be put in place.
/end
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