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Andrew Graingergrainger [a] tradefacilitation.co.uk
Brexit
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
The five stages of grief
2
https://www.youtube.com/watch?v=jYN4CllWuiM
• Denial
• Anger
• Fear
• Bargaining
• Acceptance?
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
The UK’s Political Landscape
3
May
Fox / Davis / Johnson
Osborne
Treasury
Corbyn
Cable
The
backbenchers
• 5000 customs officers?– Experts in key areas such as valuation and origin are scarce
• Uncertainty about applicable rules, procedures and systems– Subsequent uncertainty about demands upon the private sector
• It takes years to bed-in new systems
• Additional cost of making export declarations to our main markets
• Additional cost of making import declarations in our main markets
• Risk of delay and the additional cost of hedging strategies (e.g. holding buffer stock in warehouses)
https://theconversation.com/the-unforeseen-cost-of-brexit-customs-62864
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
What does the Customs Manager do?
5
Source: Grainger, A (2016) “Customs management in multinational companies”,
World Customs Journal, 10(2), pp.17-35
[http://worldcustomsjournal.org/archive/volume-10-number-2-september-2016/]
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Trade compliance is complex
6
Rural Payment
Agency
HM Revenue
Customs
Port Health
Authority
Port
Importer applies
for licence
Sets up security
Importer receives
RPA’s confirmation
Agent makes declaration
to HMRC (incl. reference
to RPA licence)
RPA returns security
after licence is used up
Importer receives from
Exporter the original
Veterinary Health Certificate
Importer/Agent prepares
CVED and submits to the
PHA using TRACES
Agent sends a paper copy of
the CVED with supporting
documents to the BIP
Agent collects/receives
stamped CVED
Shipping line pre-notifies HMRC
with the Shipping Manifest
Agent pays all
applicable PHA fees
Agent sends supporting
documents to HMRC’s
National Clearance Hub
Importer send all relevant
documents to agent
Agent sends stamped
CVED on to final
destination
(HMRC may conduct an inspection)
Agent faxes/e-mails copy of
stamped CVED to HMRC’s NCH
HMRC release their
hold on cargo
(Agent books and pays
for VBS premium
collection slots;
optional)
Agents pays applicable
port charges
Agents arranges for
collection of cargo
from port using port
community system
(Appointed haulier
collect and delivers
cargo to final destination)
Mo
nth
s
ah
ea
dW
ee
ks
/ D
ay
s a
he
ad
At
arr
iva
l
Po
st
-
Cle
ara
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e
Entry Into the UK
Shipping
Line
Importer/Exporter/Agent
books vessel
Importer/Agent receives
Shipping Line’s ETA
(Ship arrives and the port’s
stevedore off-loads cargo)
Agent pays port related
shipping line charges
Shipping line
releases cargo
(PHA conducts
applicable checks)
and stamps CVED
Agent/Haulier
return empty container
to the shipping line
(usually at the port)
(Final destination
keeps copy of CVED
for one year)
(If released from port into any
procedure other than
Free Circulation
compliance with relevant
procedures applies)
Importer/Agent keep
applicable records
(Importer receives EUR1
Certificate of Authenticity,
and Origin Documents;
if applicable)
HMRC request copy of CVED and
supporting documents, if not
already submitted by agent
EXAMPLE:
UK meat imports
Andrew Grainger (2013) http://eprints.nottingham.ac.uk/2143/
Exporter 1-2
Importer 4-7
Agent 10-13
Shipping
Line
3
RPA
(import
licensing)
2
Port Health
Authority
2
HM
Revenue
and
Customs
2
Total 26
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Brexit from the inside…
8
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Take back control…
At the border this is about:
• The Goods, the Vehicles that move the goods, and the People that operate the vehicles
• The administration and enforcement of trade and customs controls
• Customs procedures, Non-customs procedures, Trade facilitation
It concerns:
• Imports and Exporters
• Their intermediaries
• The providers of supporting infrastructure
• Public and private
• Customs and other government departments
• In the UK and with partner countries
• The wider public where costs are passed on
9
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Impact on Logistics operations
Related issues:
• Transport regulation
• Operating licences and cabotage
• Freedoms of the sky
• Labour
• Drivers, warehouse staff
• Technology
• Automation, disruptive technologies
10
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Impact upon the supply chain
Production Networks and Supply Chains
• National content requirements
• Access to preferential duty rates
• Impact of higher logistics and compliance costs upon location and investment decisions
Related issues
• Industrial strategies
• Time frames for Brexit negotiations
• Research and innovations
• Interim arrangements
• The form and shape of future trade and partnership agreements with the EU
11
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Impact upon Compliance Systems
Legal Framework
Supporting services
offered by intermediaries
Supporting electronic systems
(Public and private)
Staff and resources
Education and training
12
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Mitigation
Trade Facilitation Principles
Simplification
Harmonisations
Modernisation
Standardisation
Significant improvements in
border management
Inter-agency
Intra-agency
With the private sector (eg. AEO)
Cooperation agreements
Across both sides of the boarder
Along trade lanes
Mutual recognition of controls and
procedures
Fu
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er
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Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Problem Statement
• Protectionist vs Liberal
• Trade policy, customs policy, non-trade and customs policy
• National security
• Global security
• “Take back control” and sovereignty
Political Issue
• Laws, regulations, guidelines
• Local, National, Bilateral, Regional, International Legal Commitments
Legal Issue
• Customs and Other Government Departments
• Inter-agency co-operations
• Interagency co-operation
• Cross-border and International co-operations
Administrative Issue
• Market access and opportunities
• Competition and competitiveness
• Economic growth
• Trade winners
• Trade losers
Economic Issue
• Transport and logistics systems
• Border management systems
• Public sector operations
• Private sector operations
• Public Private Partnerships
Operational Issue
• Data sharing
• Supporting information infrastructure
• Electronic standards and computer systems
• Legacy systems
• Innovation
Technological Issue
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
Resilience and Continuity Planning
Capacity / Performance
measure
Time
Threat
Response
Period of disruption
Loss in capacity
Dr Andrew Grainger | TU Delft | Trade Facilitation Consulting | Contact: grainger (a) tradefacilitation.co.uk
https://scholar.google.co.uk
16