Ireland Q & A document
Sections:
• General
• Direct Ireland-GB Movements and West Coast
• Transit
• Technical, Systems and Support queries (and unanswered queries)
General
Are these changes going to go ahead?
Yes, the guidance for businesses is that Government IT systems and infrastructure will be in place to ensure delivery of the BTOM milestones as set out in the BTOM.
The Government made the decision to delay the introduction of controls in 2022 as we were faced with a range of new challenges from ongoing supply chain disruption as a result of Russia’s invasion of Ukraine to wider cost of living pressures.
This led us to conclude that, before we make any further changes to controls, we needed to implement these improvements together with a proportionate, risk based approach to controls to avoid serious disruption to our critical supply chains and at our ports.
We want to minimise disruption to industry in the long term and ensure we are supporting supply chains.
The Government remains committed to delivering the most effective border, and the BTOM is key to achieving this.
What level of engagement with Ferry Operators has there been?; What guidance has been issued to the FOs regarding boarding in Ireland if a GMR is not provided?
The government engages with Ferry Operators through a variety of means and is confident they are prepared for the changes. Vehicles presenting at the border without a GMR will be refused entry and will need to exit the port site to resolve their customs formalities and get a GMR before returning.
When exactly will the changes come into place?
00:01 31 January 2024
Does business-to-consumer trade or do small commercial movements (i.e. parcels) have to comply with the same SPS and S&S requirements?
Business-to-business post and parcels are subject to commercial import requirements. Parcel imports of animal products, plants and plant products can carry significant biosecurity and food safety risks. Currently, any movement of parcels from outside the EU containing animal products, plants or plant products must comply with the same sanitary and phytosanitary (SPS) controls as any other commercial import of these commodities, subject to limited exemptions. From April 2024 the same will apply to commercial imports from the EU. This requirement has also been in place for high-priority plants and plant products from the EU since 1 January 2021. As part of the UK Government’s ambition for a world leading border, Defra is working with others to develop policy on the delivery of a robust and efficient SPS regime for the movements of non-commercial parcels into Great Britain. A further announcement will be made in the new year.
Is the OV Capacity sufficient in Ireland to cope with the need for EHCs?
The published details about risk categorisation and the newly simplified health certificates will assist the relevant authorities in the Member States and the EU commission to ensure that vet capacity is in place. The risk-based approach implemented through the BTOM ensures that most imports of plant and animal products will not require health certification. All our evidence suggests that member states will be ready with the necessary veterinary capacity in place.
EU competent authorities are responsible for authorising and supervising certifying officers in the EU. We remain in contact with the EU Commission and DAFM to discuss and review the availability of Irish certifiers to exporters, as it is the responsibility of the exporter to identify a certifying officer in Ireland.
The UK government will work closely with Irish officials and industry to ensure that the capacity and availability of certifiers for Export Health Certificates does not become a barrier to trade.
Do EU traders need to be established in the UK to meet the necessary export requirements?
Traders wishing to import plants and plant products to the UK must meet the registration requirements set out in Article 65 of the Plant Health Regulation 2016/2031.
All professional operators must supply via their PEACH account, either:
• a valid UK registered address; or
• a valid UK registered proxy address
The full requirements to import into the UK and further information can be found here: https://planthealthportal.defra.gov.uk/trade/imports/imports-from-the-eu/registration-requirements-for-importers/
How are you planning for disruption at the border? Will there be queues?
Our new model reduces the need for checks at the border for many types of goods.
Government departments will engage with stakeholders across all affected sectors and all parts of the United Kingdom and the EU to ensure that they understand the coming changes and are ready to continue to move goods across the border.
Information will be shared through a series of live and virtual engagement events and communications detailing actions required as a result of the new changes. Online guidance is available on GOV.UK.
We are also taking a pragmatic approach to phasing in these controls to give businesses the opportunity to prepare.
Irish businesses should note that the deployment of GVMS at the short straits and other UK pre lodgement locations in January 2022 was a success and we are anticipating a successful rollout once again on Ireland-Great Britain routes.
Direct Ireland-GB Movements and West Coast
When will West Coast BCPs be operational? When will a decision be made as to when West Coast BCPs will be operational?
The date for the commencement of physical checks for non-qualifying goods moving from the island of Ireland will be confirmed in due course. The UK Government will work closely with the Scottish and Welsh Governments to develop plans for delivery of checks, as required. These checks will not be introduced before the 31st October 2024.
What do traders and hauliers moving goods directly from IE-GB need to do to prepare for full customs controls?
Traders who are sending goods from Ireland into GB should consider how they are going to provide the necessary information to the person making the import declaration.
Those importing goods into GB from Ireland should consider how they are going to submit their customs declarations and pay any duties that are due. They can appoint an intermediary, such as a customs agent, to deal with declarations on their behalf or submit them themselves.
Hauliers moving goods through ports that use GVMS need to have registered for the service and know how to get a goods movement reference. They must be prepared from 31 January 2024 to follow instructions to find out if they need to get their goods checked by customs on arrival, or if they’re able to continue their journey. This includes making sure drivers know to check the status of their GMR before disembarking and can use the ‘check if you need to report for an inspection’ service to understand if goods are held.
Update on the expected timeline for entry into operation of Border Control Posts in Wales and Scotland and entry into force of physical checks?
The date for the commencement of physical checks for non-qualifying goods moving from the island of Ireland will be confirmed in due course. The UK Government will work closely with the Scottish and Welsh Governments to develop plans for delivery of checks, as required. These checks will not be introduced before the 31st October 2024.
What engagements with Irish industry stakeholders are planned prior to 31 January 2024? Are these aligned with Irish government communications?
Defra are engaging stakeholders across all SPS sectors within the United Kingdom, across the EU and with trading partners around the world, to raise awareness of the Border Target Operating Model (TOM).Information will be shared through a series of live and virtual engagement events and communications detailing actions required as a result of the new changes. Online guidance will be available on GOV.UK. Future DEFRA webinars can be found here: https://www.eventbrite.co.uk/o/defra-stakeholder-engagement-and-readiness-team-70015158213
Transit and CTC
What requirements will there be for goods using Transit ?
There will be some new requirements for goods transiting GB from continental EU to Ireland and for Irish goods transiting GB to the continental EU or elsewhere.
We have published streamlined transit health certificates and move towards a proportionate level of checks on entry and exit for animal products classified as medium risk. These health certificates will be required from 31 January 2024 for EU goods, and we anticipate that seal checks on EU transits of medium risk consignments will begin from 30 April 2024. All transit movements through GB will be subject to seal checks at the BCP in Sevington to ensure they align with new SPS controls. Check rates will align with those applied to imports into GB, based on risk category. The date for the commencement of physical checks for non-qualifying goods moving from the island of Ireland will be confirmed in due course.
Low-risk animal product consignments using GB as a landbridge will require pre-notification on IPAFFS and will be subject to surveillance and occasional intelligence led checks only. As low risk plant products will be exempt from import health controls into GB, they will not be controlled when transiting either.
Live animals are inherently high risk and cannot be kept in sealed consignments. We will therefore require transit health certificates and 100% documentary, ID and physical checks on entry for live animals using GB as a landbridge but will consider reduced check frequencies for species with additional assurances e.g., high health horses and zoo animals, in line with imports.
When will seal checks be introduced for CTC movements?
Seal checks will take place at Sevington for all EU-GB-EU movements from 30 April 2024.
Is cabotage allowed for CTC movements?
No, for CTC movements a seal must remain intact. If a portion of a consignment is being exported into the UK, then all the products in that consignment must undergo the relevant SPS and customs checks associated with exporting into the UK.
Technical, Systems and Support queries
How will drivers/ ports / hauliers know that goods are required to go for an inspection?
From 30 April 2024, hauliers and drivers moving SPS goods into the country using the Goods Vehicle Movement Services (GVMS) to clear customs will be notified of inspection requirements and location via the existing Inspection Location Service. In cases where SPS goods being imported under CTC transit are required to attend an inspection a new IPAFFS messaging service will be utilised. The alerts will be delivered by text or email depending on the contact details provided when the CHED pre-notification is submitted.
HMG continues to engage with GB port and airport operators about developing the functionality of GVMS available to them.
Consignments entering through non-GVMS ports should request that the importer checks the status in IPAFFS to confirm if they need to report for an inspection.
Are the systems resilient enough to withstand the significant increase in use from 31 January 2024?
Systems are currently undergoing significant testing in order to ensure that they are resilient to changes in 2024. The GVMS system has been in use at other pre-lodgement ports of entry since January 2022 and the Government is therefore confident it will function.
Has testing been completed to ensure the IT systems are able to cope with new users all using the system at once?
Systems are currently undergoing significant testing in order to ensure that they are resilient to changes in 2024.
What is the timeframe for prenotification prior to goods arriving at the exporting port?
It depends on the commodity and mode of transport. For containerised goods, at least 24 hours notice is required. For RoRo goods, this is as short as 2 hours for those arriving via short sea. Further detail is found in the Border Target Operating Model.
Customs and IPAFFS interaction – what happen when the IPAFFS is filled out wrong / does the customs declaration get impacted (can the load still get on the boat?)
If there is no associated IPAFFS declaration then it will not be possible to lodge a declaration on the Customs Declaration Service (CDS). If there are issues with the IPAFFS declaration, the goods may be impacted at place of destination (for goods arriving from Ireland).
Will HCs be issued in the form of digitally signed PDF docs direct from TRACES, or will there be traditional signed & stamped physical HCs issued?
GB have stated that they will accept Export Health Certificates generated electronically in TRACES. These Health Certificates can be eSigned & eSealed. This eSigned & eSealed Certificate can be downloaded from Traces. This certificate can then be uploaded by the importer to IPAFFS.