According to The Telegraph (HERE) and The Daily Mail (HERE), Jean-Marc Puissesseau, president of Port Boulogne Calais, has dismissed concerns about preparations for a no deal Brexit. He says "nothing is going to happen the day after Brexit." Everything will be perfectly OK apparently. This has been greeted by those Brexit supporting newspapers as confirmation that all the dire warnings of chaos were just project fear 2.0 and more scaremongering.
Is it the all-clear then for Dover? Mmmm. I'm not altogether convinced. Remember he was the person who admitted afterwards that a no deal Brexit in March would have been a 'huge problem'.
First of all. let's read M Puissesseau's little get-out clause. Everything will be fine and traffic will be completely fluid, "If both sides do their homework". I daresay he has done his homework since we know ferry operators have been told that trucks that haven't got all the correct paperwork will not be allowed on the ferry. This tweet from Peter Foster explains it:
As Richard Burnett @RHARichardB the chief executive of the Road Haulage Association tells me, there won't indeed be any delays at Calais, because British trucks/merchants who have not pre-registered all their consignments for customs/reg checks...WONT BE ALLOWED ON THE FERRY/12— Peter Foster (@pmdfoster) June 27, 2019
Do not forget that of the 240,000 companies that trade with the EU, only 70,000 have applied for the very easy to obtain EORI (Economic Operators Registration and Identification) number. And Duncan Buchanan, policy director of the Road Haulage Association is quoted in the Mail's report saying the EORI is just one piece of the puzzle and the larger issues are the import and export documents.
He said: 'If everybody turns up in Calais with the right documents there will be no problems but even today you cannot find out from the government what you need and what qualifies you for 'lorry ready'.
'It's an information black hole. Some people may have to engage a customs clearance agent.'
So, as far as I can see if everybody has indeed "done their homework" - an absolutely heroic assumption in my opinion - there is probably likely to be little chaos, but there will be a significant drop in the flow of goods since documents will need to be checked and this adds time and introduces friction. Some trade will be lost forever because EU customers will source from alternative suppliers. Food shortages may well be the result.
'If everybody turns up in Calais with the right documents' is a bit like saying if there are no problems there won't be any problems.
But Mr Buchanan is, I suspect, closer to the truth and hits the nail on the very large and obvious head. Most trucks will turn up without the right documents, either because they couldn't be bothered, didn't know they were needed or didn't know where or how to get hold of them. This always was and still is one of THE PROBLEMS.
The key word in the statements of M Puissesseau and Mr Buchanan is IF. It's a big word isn't it?
The key word in the statements of M Puissesseau and Mr Buchanan is IF. It's a big word isn't it?
How things will change on November 1st in a no deal scenario is set out on the government's website and I can't help notice that worryingly, whole sections keep getting withdrawn and replaced by other hastily rewritten sections, presumably as officials become aware of errors in the original advice or new information comes to light.
Go to this government page HERE and this is the advice you are given for exporting goods from the UK to the EU after a no-deal Brexit:
Getting started
- Get an Economic Operator Registration and Identification (EORI) number that starts with GB.
- Decide if you want to make customs declarations yourself or get help.
- If you’re making declarations yourself, you’ll be able to do this using the National Export System. If you do this yourself, you’ll need to enter the right data needed on an export declaration. You’ll find this in Volume 3 Part 1 of the Tariff.
- Research the destinations you want to export to. This background information, along with the commodity code of the goods will help you work out if the goods will incur import duty in the destination country.
- You could be entitled to financial help to help your business complete customs declarations.
- If you already have authorisations to use special or simplified procedures check if they still apply.
Making a declaration
- Find the commodity code for your goods. This will help you fill in your export declaration accurately.
- Check if you need an export license for your goods.
- Choose the right customs procedure code for your goods which will help you work out the customs or excise processes that you may want to use.
- If you use roll on roll off ports or the Channel Tunnel you or your customs agent must complete a combined safety and security and customs declaration before the goods get to the departure port. If you’re using other routes you’ll need to do this before your goods board.
- Make your customs declaration if you’re doing this yourself. You’ll need to use the UK Trade Tariff volume 3 to help you complete the declaration. If you’re using a haulier, you’ll need to tell them the any required actions and outcomes from the declaration.
- Check the rules if you’re exporting excise duty suspended goods.
Moving goods under transit
If your goods are moved under transit arrangements, there are less border checks and you won’t need separate export declarations. You’ll need to provide:
- a commercial invoice showing the value of the goods
- a certificate of insurance for the goods
- export licence
- an Exit Summary Declaration through the National Export System
After your goods leave the UK
- Keep records of commercial invoices and any customs paperwork.
- Pay any tax or duty you owe in the destination country - you won’t usually pay UK duty on exports.
- If you’re registered for VAT, you can zero rate the VAT on most goods you export. There will also be changes to the way you pay or reclaim VAT if the UK leaves EU-wide VAT IT systems.
The very first step is getting an EORI number and we know about two thirds of companies still haven't done that. If M Puissesseau in Calais is hoping we've done our homework he is in for a shock. A dog ate it.
Note also the advice doesn't even mention the problem of proving that wooden pallets, 3 million of which move between the UK and the EU each month, have been heat treated to avoid bark beetle and fungal infestation, as required by community law. We don't need to do it now but on November 1st we will need to start.
Note also the advice doesn't even mention the problem of proving that wooden pallets, 3 million of which move between the UK and the EU each month, have been heat treated to avoid bark beetle and fungal infestation, as required by community law. We don't need to do it now but on November 1st we will need to start.
Is it likely things will go smoothly? Personally I am very doubtful. Getting thousands of companies, with millions of pieces of paper and their associated goods all together and correct and in the right place at the right time, all at the last minute with nothing but wings, prayers and crossed fingers is the stuff of Star Trek, not reality.
Finally a nice piece by A C Grayling in the Sydney Morning Herald trying to explain the insanity of Brexit to an increasingly puzzled audience down under. Well worth five minutes. G'day.
