This is an area that will be unfamiliar to a number of companies if you have only exported within the EU. Companies will need to decide who they want to use as a customs agent, a list can be found here https://www.gov.uk/guidance/list-of-customs-agents-and-fast-parcel-operators
. It would also be beneficial for your company to also have knowledge within this area and there is funding available to support this training.
You can apply for 3 grants to help your business complete customs declarations.
You can apply to get funding for:
- training that helps your business to complete customs declarations and processes
- hiring new staff to help your business complete customs declarations
- IT improvements to help your business complete customs declarations more efficiently
What you must use the grants for:
You must use the funding to cover the recruitment and salary costs of new employees, where the new employee started on or after 12 June 2020, who will help your business complete customs declarations.
You can also use the funding to cover the salary costs of employees who are redeployed from another part of your business in order to undertake customs declarations. These employees new roles must increase the capacity of the company to deal with customs declarations.
The training must give you or your employees the skills to:
- complete customs declarations
- carry out customs processes – this can include relevant training in safety and security
The training does not have to lead to a formal qualification.
If you want to arrange the training internally, you can use the funding for the
cost of delivering the training, like related stationery, room hire, catering and travel and subsistence costs.
If the training will be delivered by an in-house trainer, you can also use the funding to cover the (reasonable) day rate of the trainer.
You cannot use the funding for other unrelated training
You can also use the grant to reimburse what your business has spent on relevant training since 12 June 2020.
You must use the funding to buy software that will help your business to complete customs declarations more efficiently.
It must be a ready-made solution – you cannot use the funding to commission bespoke software.
You can also use the funding to:
- buy hardware that’s needed for the software to run
- install and configure the software and hardware
- buy the first year licence
- train employees to use the software
You cannot use the funding for unrelated networking costs.
You can also use the grant to reimburse what your business has spent on relevant IT improvements since 12 June 2020.
You can apply for the funding here https://www.gov.uk/guidance/grants-for-businesses-that-complete-customs-declarations
Trade with non-EU countries at the end of Transition.
the UK is pursuing its own independent trade policy, having left the EU, including the Single Market and Customs Union (in the case of GB, at least). The UK had signed, in principle a new free trade agreement with Japan which, though not a like-for-like replacement of the EU-Japan FTA which came into force in February 2019, it is largely based on its provisions. This will come into force for the UK once we leave the Transition Period. The removal of tariffs as part of the agreement was destined to take many years, with full application of a tariff-free agreement for seafood not expected until 2033, it is understood that the UK-Japan agreement replicated the EU-Japan agreement with regard to seafood tariffs.
the UK was also now in trade negotiations with the United States, Australia and New Zealand, and seeking accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP). This agreement includes countries like Mexico, Australia, Japan, Singapore and Canada and is the third largest free trade area under an overarching agreement in the world. RL also added that the UK was additionally in bilateral negotiations to try to replicate as far as possible EU agreements with the likes of Canada, Mexico and Vietnam. RL went on to confirm that trade agreements with two of the three EEA-EFTA countries (Iceland and Norway), as well as agreements with Turkey and a number of countries in the Western Balkans, were still under negotiation, while a trade and cooperation agreement with Ukraine has actually been announced earlier in the day. RD confirmed that Ukraine was one of the main export markets for Scottish mackerel.
Negotiations with Iceland and Norway are closely linked to the negotiations with the EU before adding that rollover trade agreements had already been negotiated and agreed with Switzerland, Liechtenstein, the Faroe Islands and various North African and Middle Eastern countries. RL confirmed that, in total, there were about 19 finalised rolled over agreements with about 18 others that are still being negotiated but with no guarantees that these will be finalised by the end of the Transition Period.
sometimes there is a lack of clarity on the practical implications of agreements either being signed or lapsing but that DIT has improved their reporting of details on their website recently. Without an agreement, it should be expected by companies that WTO Rules would underpin the trade relationships in question and that Most Favoured Nation (MFN) tariffs would apply.
Information on UK trade agreements with non-EU countries – this information is available here:
https://www.gov.uk/guidance/uk-trade-agreements-with-non-eu-countries ; https://www.gov.uk/government/news/negotiations-on-the-uks-future-trading-relationship-with-the-australia-update ;
Companies need to familiarise themselves with databases and commodity codes covering tariffs if they haven’t already, and likewise any Rules of Origin that may apply in any new trade agreements, either with the EU or other blocs or countries. These are important both for the purposes of exporting and importing.
Information on tariff databases – this information is available here:
What UK Government proposed in their Consultation
We outlined that there may be a need for a contingency plan which would provide certain commodities the opportunity to bypass part of the Operation Brock system if queues build up.
We set out the government’s view that prioritisation of goods would be justifiable if 2 or more of the following criteria were met:
- the goods are highly perishable and will lose most of, or all their value, within 5 days or less (for example, without additional refrigeration, freezing or other intervention, which would not be possible)
- the ‘perishable’ goods concerned are live animals and would give rise to animal welfare concerns if not moved in a timely manner
- delays to the goods would give rise to a disproportionate economic impact on a geographical area of the UK
Based upon the criteria above, the government identified 2 sectors where a contingency to prioritise goods would be justifiable. These were single loads of live or fresh seafood products for human consumption, or of day-old chicks. These products are highly perishable and are highly dependent upon being exported through the Short Straits (as the most efficient route to the EU market, or as transit for onward movement to third countries) in a timely and financially viable fashion. DOCs are live animals and must arrive at their destination within 72 hours of hatching, to ensure compliance with animal health legislation. They cannot be fed in their vehicle and delays risk dehydration and mortality.
The overall response to the proposed contingency arrangements for prioritising these goods was positive, so we’ll be taking forward our proposals.
Defra estimates that on average about 70 HCVs a day would be carrying live or fresh seafood products or DOCs. In the context of the overall volumes of vehicles using the Short Straits, we consider that this is a small enough number to accommodate such arrangements. A specific route for the prioritised vehicles has been agreed with the KRF, with use of the contraflow past the Operation Brock queues by outbound HCVs conditional on having a ‘priority goods permit’. Using the contraflow without the requisite permit could see the HCV driver stopped and fined.
In summary, implementation of a prioritisation approach will work as follows:
- a driver of a prioritised HCV would need to obtain a valid KAP from the ‘Check an HGV’ service
- they would then be instructed to travel to a Prioritisation Control Site (PCS) where the presence of a valid KAP would be confirmed. If they do not have a valid KAP, they’d be liable to be issued with an FPN and fine. Further guidance on the location of the PCS and the instructions on when the site is in use will be confirmed shortly
- if the ‘Check an HGV’ service were unavailable, a manual border readiness check would also be conducted at the PCS
- an HCV carrying prioritised exports that was deemed to be border ready and with a valid KAP, will be issued with a physical Priority Goods Permit and 2 retro-reflective stickers (one to be displayed at the front and back of the vehicle), and would be allowed to proceed down the priority route to the border, using the contraflow to bypass the Operation Brock queues
To reduce the risk of abuse, document checks and some spot checks (that is, physical inspections of the cargo of the HCV) would be conducted at the PCS to ensure the load is as stated, and qualifies for prioritisation.
Those found to be abusing the system, that is, not carrying only priority goods, would be issued a £300 fine and instructed, if in possession of a valid KAP, to proceed via the normal, prescribed route, joining any queues that have formed
No further commodities have been deemed to meet the criteria for prioritisation for the purpose of this contingency plan
Migration Advisory Committee (MAC) Final Report on UK Shortage Occupation List (SOL) – recommendations to UK Govt, the MAC’s recommendations relevant to the seafood sector are:
- The MAC recommends partially adding SOC code 5119 (agricultural and fishing trades n.e.c.) to the UK SOL only for those in the fishing industry.
This occupation is ranked low on the RQF3-5 shortage indicators and the vacancy to employee ratio is well below the median for eligible occupations.
However, stakeholders in the fishing industry have stated their concerns and there is evidence to suggest a UK-wide shortage in this part of the occupation.
Job roles including ‘captain’, ‘skipper’ and ‘fisherman’ are classified under SOC 5119.
- The MAC recommends classifying ‘deckhands on large fishing vessels (9 metres and above)’ under SOC code 9119 as RQF3 and therefore to be eligible for the Skilled Worker route.
For this job title, they recommend including a requirement for the applicant to have at least three years full time experience using their skills.
The MAC said they recognise that there may be operational challenges given the rules on operating inside compared to outside territorial waters, which the Home Office will want to consider. Other relevant roles under code 9119 (including fish husbandry in the aquaculture sector) are not recommended for classifying/upgrading to RQF3.
- All jobs in occupation code 2112 (biological scientists and biochemists – includes broodstock geneticists) are recommended to go on UK SOL (relevant to aquaculture).
- The MAC does not recommend adding SOC Code 5433 (fishmongers, fish processors and poultry dressers) to the UK SOL but does recommend inclusion to the NI-only SOL.
- The MAC does not recommend adding SOC code 4134 (transport and distribution clerks and assistants) to the UK SOL.
The online job posts to employee ratio is above the median, however, the occupation ranks low by RQF3-5 shortage indicator rank and pay growth has been negative (2016-2019). Although some stakeholder evidence highlighting difficulties was received, on balance there was not enough evidence in the MAC’s view to indicate a UK-wide shortage.
- It is unclear/not explicit but SOC Code 8211 (drivers of large goods vehicles) does not appear to be recommended for classifying/upgrading to RQF3 and thus is not eligible for inclusion on the UK SOL.
- Occupations below RQF3 have never been eligible for the current Tier 2 (General) route and will not be eligible for the new Skilled Worker route.
The report is available here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/922019/SOL_2020_Report_Final.pdf
Government publishes updated GB-EU border operating model
On Thursday 8 October the Government published an updated Border Operating Model, which provides further detail on how the GB-EU border will work and the actions that traders, hauliers and passengers need to take.
The updated GB-EU Border Operating Model:
- Maps out the intended locations of inland border infrastructure. The sites will provide additional capacity to carry out checks on freight.
- Announces that passports will be required for entry into the UK from October 2021 as the Government phases out the use of EU, EEA and Swiss national identity cards.
- Confirms, after extensive engagement with industry, that a Kent Access Permit will be mandatory for HGVs over 7.5 tonnes using the short strait channel crossings in Kent. The easy-to-use ‘Check an HGV’ service will allow hauliers to check if they have the correct customs documentation and obtain a Kent Access Permit.
Exports of seafood to the EU
Exporters are encouraged to take three simple steps:
- Go online and apply for a GB EORI number (a number which helps customs identify their goods). You will need this to trade with the EU after 31 December 2020.
- Decide how you want to fulfil new customs requirements – some businesses will do this themselves; many will want to use a customs agent or intermediary and should identify one now.
- Talk to businesses in the EU you trade with to ensure they are familiar with the new import requirements from the end of the transition period.
Details of the specific requirements for exporting fish and shellfish are provided from page 167 of the Border Operating model.
Imports of seafood from the EU
The UK Government has taken the decision to introduce the new border controls in three stages up until 1 July 2021to give industry extra time to make necessary arrangements.
The stages are:
1. From January 2021: Most imports of marine caught fish and some shellfish will need to be accompanied by a Catch Certificate (and other relevant IUU documents as required).EU-registered fishing vessels intending to land their catch directly into GB must land into an appropriately designated port in line with IUU fishing rules and the North East Atlantic Fisheries Commission (NEAFC) convention.
2. From April 2021: there will be new requirements for fishery products for human consumption to be accompanied by an EHC. There will also be new requirements for importers to submit prenotifications for fishery products via IPAFFS in advance of the goods’ arrival
3. From July 2021: Commodities subject to sanitary and phytosanitary (SPS) controls, these must arrive at an established point of entry with an appropriate BCP.
Further details of the import requirements for seafood are on pages 61, 94 and 123 of the Border Operating Model.
EHC Online registration now open
From 1 January 2021 all exports of fish and seafood, including aquaculture products, except direct landings of fish from UK-flagged fishing vessels to the EU will require an Export Health Certificate (EHC). Exporters can apply for EHCs online and can register for the online service before their first application is made. You can prepare now by registering via gov.uk. Guidance is available on how to get an EHC and when is the right time to apply here. You can also view examples of EU EHCs on Defra’s Form Finder.
Protecting food and drink names from 1 January 2021 – new UK GI logos
On 28 September the new UK GI logos were made available to download on GOV.UK. These logos, and the rules for using them, were shared with GI producers, retailers and enforcement bodies via email. The GIs policy team will be hosting an online teach-in session on the new UK GI schemes. Please contact the team at email@example.com if you would like to attend.
Funding Support for Remote Training in Scotland’s Seafood Industry
There is still a very limited amount of funding support available for seafood companies to undertake training. Full details of the courses can be found here
Production Staff Wanted
There is a growing number of companies throughout Scotland making contact with vacancies within their operations. If any companies are making redundancies or knows of anyone looking for employment can they please contact firstname.lastname@example.org