With around 4 million tonnes of waste exported from the UK every year, European energy recovery and recycling facilities play an important role in enabling us to manage our waste in an efficient and sustainable manner. The new year, however, has brought some major changes to the process of exporting material.
The most significant change is that material which had previously been able to move freely across EU borders now requires customs clearance at both the point of exit and entry. Additional paperwork is also required for material transiting through another country en route to its final destination. These checks are necessary to ensure that any duties due are collected in the right country.
Our experience to date is that the procedures which drivers are now required to follow (especially if they require a T1) are significantly more time consuming and result in a material increase in costs for every load.
Upgrade
Whilst the Government is in the process of updating the system which previously handled the export of goods to non-EU countries, this is a significant upgrade that will need to cope with the huge increase in throughput. Although we hope the new system will do away with most of the physical requirements for the drivers, it is certainly not guaranteed and no completion date has been given.
Fears that every load would need to be physically checked have not materialised but there remains a very real prospect of serious delays at all our inland customs posts. In order to “take the pressure off Kent” (home to Dover – the UK’s busiest roll-on/roll-off port), a new ‘Kent Access Permit’ has been created. This will enable the Police to turn away vehicles without the correct paperwork and in effect create a border within our border.
Paperwork
The increased levels of administration and paperwork have in turn created a serious shortfall in resources. An additional 50,000 new customs agents are thought to be needed to meet the extra demand but, despite a £82m Government training scheme, we are still well short of this number.
There is also an increased burden on businesses. HM Revenue & Customs has estimated that UK exporters will have to complete 260 million more customs forms a year, many of which will need the help of intermediaries. However, nearly two-thirds of customs brokers have admitted to not having enough staff to process any additional paperwork. The claiming back of VAT charged by the receiving country on part of the transport journey is also going to be a substantial challenge for companies who have no experience in this field.
The good news is that it’s still not too late to prepare your business and seek help to deal with the added export and customs burden. Here are some of the key considerations:
● Take the time to understand what and exactly how these changes may impact on your business
● Review Incoterms and how this will affect your paperwork and customs clearance process in the country of destination
● Communicate with your customers, offtakers and service providers and develop contingency plans based on realistic scenarios, to help deal effectively with the financial impacts
● Consider alternative routes, including the increased use of unaccompanied ports like Immingham, Felixstowe or Harwich, to avoid ‘pinch points’ such as Dover
● Ensure you are adequately resourced to cope with increased administration and paperwork
● Work together and share experience and expertise. A good example of this collaborative working is WasteCare’s recent appointment of Totus to provide its export logistics services in preparation for life after Brexit.
Pandemic
As if Brexit wasn’t hard enough, the situation has of course been further compounded by the impact of the Covid-19 pandemic. This has led to a perfect storm which could be hugely costly, both financially and reputationally.
There are, however, practical steps that all exporters of waste can take to prepare and mitigate any potential risks. In fact, for some businesses, Brexit may provide the opportunity to undertake a broader review of their existing export operations. In addition to ensuring a fully compliant export process for the future, this may well also identify significant commercial and environmental improvements outside Brexit and its specific challenges.
For more information, visit: www.totusenvironmental.com
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