The Tank Storage Association (TSA) welcomes further details from the UK Government regarding its plans for customs checks following the exit of the UK from the European Union. However, we have concerns over an innovative but untested approach put forward in the paper ‘Future customs arrangements: a future partnership’. Should the UK lose access to the single market through the Excise Movement and Control System (ECMS), all imports from outside the UK would need to be processed using these alternative approaches. Processing customs declarations is complicated and importing is likely to take longer and cost more.
We urge government to ensure that an end-to-end declaration processing service is put in place allowing the efficient passage of legitimate imports and exports to and from countries outside of the UK. Consideration should be given to the following suggestions as part of the development of such a system:
- Limit the use of the existing Customs Handling of Import and Export Freight (CHIEF) system to the declaration of goods to customs, as it is likely to struggle with the increased volume of transactions carried out by the existing ECMS.
- Move the payment of customs duty & VAT from the border to when goods move to home use (as with excise duty).
- Use commercial documents/self-assessment for transaction tracking and duty payments and audits for compliance.
- Remove restrictions placed on how goods are held in a customs/tax warehouse. Primarily this would mean allowing common storage and co-storage of UK and non-UK goods in the same tanks.
- Simplify the process of gaining customs warehouse approval and limit the need for warehouse guarantees (make extension to the tax warehouse approval).
New customs arrangements will take time to fully implement. Therefore in order to avoid a cliff-edge for businesses and individuals on both sides, transitional agreements extending the use of current systems and processes will be required.
We look forward to working with Government to further develop its plans for future customs arrangements.