Moving goods under Transit Procedure via the UK landbridge: Ireland – Great Britain - Netherlands

The UK Government announced on 28 April 2022 that no further import controls on EU goods will be introduced in 2022. The new target date for the introduction of controls that had been due to be introduced throughout 2022 is the end of 2023. Further information is available here.

Background

Since 1 January 2021, a range of new steps must be completed in order to move goods under the transit procedure via the UK. Depending on the model used by operators to manage the transit (e.g. in-house or via a customs agent), there is flexibility as to who completes a number of steps. It is therefore vital that all actors in the transit chain (e.g. traders, logistics companies, customs agents, hauliers etc.) understand and agree in advance who is responsible for each of the steps along the route. Failing to clarify this will disrupt your trade and lead to possibly severe delays including not being given permission to enter Ports or board ships.

The term “Responsible Operator” is used below to cover all relevant actors within the transit chain (e.g. traders, logistics companies, customs agents, hauliers etc.) who, depending on circumstances, may complete the required processes and steps.

Set out below is an overview of the steps traders should take when moving goods under transit between Ireland and The Netherlands. The example is for illustrative purposes and should be taken as broad advice only. It is up to the responsible operators to ensure that they understand the precise steps required to move their specific consignments across their chosen transit route and who will be responsible for completing the various steps.

For the purposes of the examples, the traders involved are considered to be customs compliant (i.e. has an Irish EORI number and is VAT registered), and has made provision to have a financial guarantee in place and is not an authorised consignor.

In order to avail of the flexibilities provided for EU-EU transits, vehicles should only contain Union goods i.e. goods that are in free circulation in the EU. Where operators consolidate loads in Great Britain, separate processes to the ones described below apply – in effect, these full consignments will be considered imports into the EU and non-Union goods i.e. Great Britain goods, will be subject to import procedures, checks and controls at the point of import to the EU rather than transit procedures meaning the vehicle will have to stop on re-entry to the EU.

The list of designated BCPs in The Netherlands is available here.

Ireland – Great Britain

1. Live animals and germinal products must always be accompanied by the relevant intra-EU trade certificate. The responsible operator must give prior notification to the BCP in The Netherlands of the arrival of consignments of live animals, germinal products and high risk animal by-products (Category 1, Category 2 and Category 3 processed animal protein [PAP]) by submitting Part 1 of the Common Health Entry Document (CHED) in TRACES NT.

Note: The Dutch authorities do not require prior notification in TRACES NT of consignments of products of animal origin, composite products, animal by-products and derived products, and hay and straw.

2. Consignments of animal by-products must be sealed.

3. The Responsible Operator submits a combined exit summary declaration and transit declaration onto the NCTS system. Where required, the CHED reference number generated at step 1 above must be included on the transit declaration. This generates a S(TAD) – a Transit Accompanying Document (TAD) that contains safety and security information - with a unique Movement Reference Number (MRN).

4. Create a Pre-Boarding Notification (PBN) on the Customs RoRo service. The PBN must include the MRN of the (S)TAD. If the vehicle contains several consignments, the MRNs of all the declarations must be included in the PBN.

5. Once the PBN is completed, the driver can check if they may proceed to Dublin or Rosslare Port using the Customs RoRo Service. The hard copy (S)TAD must travel with the goods. The driver provides the PBN details to the Ferry Operator at check in. If all is in order, the vehicle will be allowed to board the ferry.

6. The haulage company also must lodge the details of all the (S)TADs on the vehicle onto the UK’s Goods Vehicle Movement Service (GVMS). This will require a UK EORI number to access the GVMS system.

Note: If you are moving animals/ SPS goods as part of the transit UK transit requirements also apply. These are detailed in the table here.

In Great Britain

7. Upon arrival in Great Britain, if all in order, driver does not have to interact with Border Force as the office of transit function will be completed digitally using the GVMS information. GVMS is in operation at Holyhead, Liverpool and Fishguard. If GVMS is not operational, a call at an Office of Transit is required to have the (S)TAD stamped

8. From 1 October 2021, safety and security declarations will be required for goods leaving Great Britain, including in RoRo vehicles, and for empty containers, pallets and vehicles moving to the EU under a transport contract.

Goods moved under common transit procedures from Great Britain to Ireland, where the goods are destined for Northern Ireland are permanently exempt from these UK safety and security export requirements.

9. Hauliers moving goods through the UK may wish to be aware of the operation of a number of UK Government haulier advice site locations throughout the UK where hauliers can check their documents prior to travelling to the port. Hauliers can also take a free covid-19 test at some locations.

As of 20 April, there is no longer the requirement to obtain a ‘Kent Access Pass’ prior to travelling to ports in Kent.

Great Britain - Netherlands

10. The entry summary declaration will be submitted by the ferry operator based on information provided by the driver/haulage company. Details of the Transit Accompanying Document (TAD) need to be pre-notified to Dutch customs using their Portbase system by the driver/haulage company.

11. Prior to arrival in Belgium, any accompanying drivers should check the status of the lorry to confirm whether it is required to call to Dutch customs.

12. Once no issues are noted by the Dutch authorities, the responsible operator(s) have completed all the stages correctly and the load is moving under transit, the driver should be given a 'green' routing and will be allowed to leave the port without interacting with Dutch customs and proceed to close the transit.

13. If the goods are being delivered to an Authorised Consignee, the goods can proceed directly to the traders’ premises. The Driver hands over the TAD with the delivery to allow closure of the Transit. If the customer is not an authorised consignee, the Driver must call at an Office of Destination to complete the transit formalities. Once all of the steps are performed, the transit is closed on the NCTS system and the financial guarantee is automatically released.