From a forwarder
"I made a precis of the UK’s ‘Border Operating Model, a 206-page document. Even the precis is 13 pages long & highly technical. I feel sure you probably can’t be bothered. It is difficult to read even for the experienced. More to t'point, it’s riddled with holes
So why bother? At least until those behind it wake up & smell the coffee. We have created basic process maps for what they are worth. Unfortunately, the Model displays such deficiencies that I was forced to use best guesses, the experience of my colleagues and myself and logic
to try to plug the gaps. The trouble is, those advising the government don’t appear to be using a lot of logic.
Neither do they seem to be asking the people on the ground who have the right knowledge? It is without surprise that it has emerged that version two of the Model
will be released end of October, according to our sources. In other words it’s a moving target. I wonder how many versions will be needed? Anybody been around long enough to remember ‘Dad, I think I got it wrong again’?A flavour of some of the shortcomings in the current version
No word on where import T forms will be discharged under the ‘Pre-lodgement Model’
No mention if T forms are needed under the Pre-lodgement Model
The assumption inland approved sites can cope with vast columns of uncleared import freight using the ‘Temporary Storage Model’.
I can answer this simply. They can’t. Warehouses don’t have elastic sides. Control measures are draconian at best. This model is unsuitable for full loads and large part loads. Hauliers are expected to take responsibility for inputting multiple data elements in a new IT platform
GVMS still not finalised. Hauliers having to complete EU equivalent systems of GVMS such as the French ‘SI Brexit’; systems which do not talk to each other.
The deferral’ of import entries for the first 6 months of 2021 via ‘CFSP’. Current regulations make this worse than useless
clunky & unyielding, actually increasing, rather than decreasing workload. Import Safety & Security Declarations, required from 1.7.21. No IT platform for these. Why are they even necessary? The haulier is responsible for Safety & Security Declarations – completely unworkable.
Hauliers having to use a second IT platform ‘SFS’, which is also still not available. For exports, ‘Permission to Proceed’ status being required before loading – current regulations do not permit this unless the origin warehouse is specially approved. I wonder how the border
survived since 1993 – and continues to do so to this day – with trade between the UK and non-EU European countries? Makes you wonder, doesn’t it?
I know – why not ask someone in Dover who makes this work? No – that would be too obvious. Let’s bury our heads in Whitehall;
the inexperienced know best.
Am I alone in suspecting a ‘white noise’ Remainer plot to sabotage Brexit?

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More from @vivamjm

5 Oct
Ok so statements of the bleeding obvious that were somehow successfully dismissed as 'project fear' (now 'project here')

1/ leaving CU & SM will cause intractable problems over border in IRL. Automatic, now different customs & regulatory zones, border posts need to go somewhere
2/ leaving CU & SM means automatic need for greater space, staff & time for customs & regulatory processes at ports of entry/exit. (that UK doesn't have)

3/ leaving the CU means an extra 220m customs decs pa costs adding up alone to more than UK former EU annual contribution.
And to rules of origin complications far in excess of these costs

4/ leaving the SM means duplication of regulatory bodies & NTB/SPS compliance costs at vast expense, which combined with leaving CU (NTB) costs, meaning very obvious business job losses, contractions & failures
Read 6 tweets
2 Oct
I sometimes hesitate to tweet for "fear" of repeating myself too much....BUT...I feel the need !!!
There are 145,000 UK businesses that will need to complete customs formalities for the first time on 1/1.
There will be an additional approx 230m customs declarations a year...
Needing that approx additional 50,000 customs staff (& 5000 customs officers) . It takes at least (with continued supervision) a year (I'm being optimistic) to train an individual to handle relative routine inquiries given complexity of customs entries/correct accompanying dox
esp on SPS.

Without long extended continued "transition", it is *impossible* (along with needed interfaced IT processes & necessary oganised infrastuctue/processing sites) for whole UK (not just NI) to be customs capacity ready for 1/1
(or even 1/7 for that matter IMO)
Read 4 tweets
24 Sep
Further to Morrisons/Gibraltar .. from a friend "There is broader piece here about UK retailers supplying EU stores from UK warehouses, as many do at present. I know JD Sports is looking at ways to avoid potential of (eg) paying tariffs on trainers made in China on entry
to the UK, then again on entry into EU. Basically means building out distribution infrastructure in EU - Belgium seems a popular choice. And jobs there instead of jobs here. But hey, blue passports"
Their interim results statement: "We are very conscious that the UK's transition
period with the EU ends at the end of this year and, at this stage, there is a significant risk that the UK may exit that transition period with either no agreement or with perhaps just a very basic and limited free trade agreement. Given the current status of our supply chain
Read 5 tweets
23 Sep
It's gets better folks *REF GIBRALTOR* ..
A friend just brought to my attention the Gibraltar technical briefs and hasn't stopped laughing. Basically non animal goods from UK are subject to BCP in France, however animal/plant origin will have to (SPS) clear EU/Gib BIP
and the border between Spain and Gib is not a BIP and never will. So they goods will have to go to....... Wait for it..... The Port of Agetcira!
And then shipped across to Gibraltar.
That's Morrisons fucked!
Read 5 tweets
22 Sep
I have just watched the recent Treasury Select Commttee..

I do wish they would invite on EX customs officers, EX port authority representatives & EX logistics/forwarding representatives for more honest appraisals (inc "Light Touch" smuggling) rather than career orientated ones.
@AnnaJerzewska about the only one to convey gravity of situaton UK in

and she made a very good point about the NI TSS .it *had* better be successful
From a friend .."Watched it for 2 hours, then lost will to live. Port guy"smug" lots of "if, buts, maybe, possible, when, need more detail. The point I took away was, like an orchestra, you need whole lot playing in tune to possibly succeed. he odds? Pie in the sky. Not a prayer"
Read 5 tweets
19 Sep
From an American friend: "Are you reading all the fascist shit that is going on here? Essentially eugenics being practiced by our govt—ICE detention centers in Georgia holding South American women that crossed our borders have been subjected to hysterectomies without consent.
Trump admin denied plans to send masks to every US household back in April “to prevent panic.”
.. Our entire West Coast (California, Oregon, Washington State) is on fire and trump refuses to declare a state of emergency which would release much needed funds to these states.
Ruth Bader Ginsburg died today — she was one of our Supreme Court judges who stood in the way of such craziness as overturning Roe v. Wade (abortion become illegal again). Also, trump supporters are out of control here — the hatred they spew is becoming more and more violent.
Read 5 tweets

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