Since the commencement of my career in freight forwarding in 1985, in Dover Eastern Docks, many changes in the customs process have occurred. Back then, Customs Clearance was a slow and laborious task requiring the completion and manual processing of C10 and C12 import customs entries and export transit documents.
This often caused long delays to the movement of cargo through the port that had arrived or departed from European countries and the Eastern Bloc. In fact, the average time to obtain clearance and release would be three to four hours but this changed with the introduction of a computerised system in 1988.
The implementation of CHIEF with the C88 Simplified Administration Document (SAD) seriously increased the speed at which cargo could transit through the port, however the implementation was fraught with challenges. Only a small number of port agents were authorised to use the new system which did at times cause chaos and delays in the clearance and release process.
Eventually, once the system was 100% up to speed, a large percentage of shipments were released within an hour and the volume of trucks passing through Dover Eastern Docks could increase. At this time approximately 1,000 trucks would pass through the port in a 24-hour period, compared to the circa 10,000 that pass through today.
Under current plans we are set to go full circle, with the UK set to leave the European single market and the Customs Union as we know it, in March 2019. At this moment the release of information regarding the changes needed for the deployment of a new HM Revenue & Customs system, the Customs Declaration Service (CDS), has been very limited.
It could be potentially catastrophic if the new system is not ready in time and there is no viable fallback option. In 2015 around 55 million Customs declarations were submitted by 141,000 traders. After the UK exit from the European Union (EU) the number of customs declarations to be processed by HMRC per annum will potentially increase to around 255 million by a 5-fold rise of around 275,000.
The Port of Dover currently processes 10,000 freight vehicles every day. Therefore any system issue could lead to huge disruption. We have already witnessed regular problems with the current system, with measures such as Operation Stack needing to be implemented.
It is scary to imagine the issues that would arise if a robust system is not in place to deal with the large volume of trucks and personnel coming through the port that are required to clear Customs. Any severe delays could lead to massive queues at the border resulting in food and other perishables being left to rot in trucks. Looking farther, you could then have a situation where ships cannot berth because there is nowhere to position incoming vehicles.
Complications have arisen due to the uncertainty regarding the outcome of the UK-EU negotiations. It is essential to find a viable contingency plan before January 2019 so there are no barriers to the continuity of service. HMRC need to ensure they have a flexible service which can handle the increased volumes of Customs declaration at all airport and sea ports, as I use Dover as just one example.
HMRC confirmed that it had not yet completed the integration of all the CDS components but had integrated three of the eight required, into a live environment. The expected time line was for the remaining five components to be deployed and integrated is mid-November 2017.
HMRC also need to work with the affected industries, be it traders, forwarders or air/sea port authorities, to ensure an effective CDS is in place and on time and give sufficient time to train users how to effectively utilise the new system. Hopefully by July 2018 the results from the progress review will report back that the CDS system has been tested and works as intended.
NNR Global Logistics is already analysing the potential challenges of post-Brexit Britain. From there we can evaluate any risk in not having representation at all the UK point of arrival or exit, etc., to ensure a smooth flow of goods to minimise the impact to our customers. Our vigilance and expertise will ensure we will be ready. Will you?