Many companies are failing to properly describe goods being moved within the European Union. Whilst there is no requirement from HM Revenue & Customs to give accurate descriptions for intra-EU traffic, it is still important for other reasons: especially where fragile, high-value goods and foodstuff-based products are concerned. Moreover, with the UK’s impending exit from the EU and the reintroduction of full customs controls, such casual enforcement must, in any case, soon come to an end.

The maritime industry has SOLAS (Safety of Life at Sea) requirements and, more recently, those for Verified Gross Mass (VGM). Furthermore there is, quite rightly, an increasing emphasis on the mis-declaration of dangerous goods. So why is it ‘accepted’ practice in the forwarding industry to have so little regard for the correct cargo description when moving goods within the EU?

Ital Logistics, one of the leading carriers of dangerous goods between the UK and continental Europe, and which frequently moves shipments on behalf of other operators, often receives bookings (mainly from fellow forwarders) which describe cargo only as either ‘spare parts’, ‘non-hazardous goods’ or something similarly vague.

It is becoming rather tedious. Those same companies have to declare correctly when shipping outside the EU, so why not exercise the same professionalism when moving goods around the EU? Just because there have been little or no customs requirements when trading with the EU for the last 25 years or so, it doesn’t mean that it ‘doesn’t matter.’ One would not ship a container of sulphuric acid and not say what it was (at least, I would like to think not). There are financial and legal consequences for doing so, in fact.

As for non-hazardous goods, whilst there are no reasons in law or regulation to accurately declare them and it has become accepted practice by many to give descriptions such as ‘parts’, it is highly desirable, from the forwarder’s perspective, to know what they are. This is particularly true of foodstuffs (or goods that have to be treated as foodstuffs) or fragile, high-value or theft-attractive goods. Shipments of that nature that are not so declared could be uninsured under general CMR cover, which insures goods under a limited liability.

If we do not know what we are transporting, we cannot take the necessary precautions. We cannot ensure that the haulier takes rest breaks in secure parking facilities, for example. We cannot advise our customers that their goods have a value exceeding CMR liability. And we cannot ensure that the packaging for your cornflakes does not get loaded adjacent to a Class 6.1 toxic chemical.

Ital Logistics has designed software to include commodity categories and, where any type of product could be considered ‘high value’, the customer gets an automated additional note regarding insurance. The haulier is also instructed accordingly. The same applies to fragile goods that should not be stacked, for example. And where goods need to be treated as foodstuffs, both haulier and warehouse are automatically notified.

However, if we do not know what we are transporting, then we cannot take the relevant precautions.

Whilst some people may fail to declare goods properly because they misguidedly believe that it can help disguise theft-attractive goods, I suspect that it has simply become habitual following the cessation of customs formalities. With a view post-Brexit and the re-imposition of customs clearances for goods moving between the UK and EU from 1 January 2021, requiring shippers to provide full descriptions of goods and full documentation, they would be well advised to start preparing now.

Phil Denton, MD, Ital Logistics