There has been a number of problems regarding transit procedures. HMRC have been assessing the issue and have issued the following update, which includes some informal guidance.
Key actions to prevent delay
- Presentation of Local Reference Numbers: HMRC have heard reports that hauliers are arriving without the correct transit or import documentation. Some hauliers are presenting one Local Reference Number (LRN) when starting transit movements at GB Offices of Departure. This is not a problem if a vehicle is travelling with all of its consignments captured under one Transit declaration. However, if a vehicle is carrying multiple consignments under different transit declarations but does not present all of their LRNs, the goods will be held on arrival in in the EU.
- They have amended their guidance to frontline HMG staff at OODs so they will now prompt every driver to present all of their LRNs. They are publishing leaflets with updated guidance in several languages for drivers. They are monitoring the effects of these changes, but would like to remind exporters that every LRN must be presented at the Office of Departure or it likely the goods will be held on arrival in the EU.
- Office of Transit ‘Box 51’: French authorities have notified HMRC that several vehicles have arrived in France either without an Office of Transit listed in Box 51 or with an incorrect Office of Transit. If a trader arrives in France without the correct Office of Transit listed, they understand that SI Brexit – their new digital border system – will hold the goods. This is because the local NCTS will not have a record of the transit movement or be able to complete Office of Transit digitally, unless this location is declared at the Office of Departure. The French system will need to manually request this data from the original Office of Departure and then process the movement. To avoid this issue, we are asking traders to ensure that they are declaring every Office of Transit en route – this means listing the port of entry into every new customs territory. HMRC have agreed a temporary measure with French officials to allow Calais and Dunkirk to be entered as Offices of Transit on crossing from Dover. https://www.gov.uk/government/publications/community-common-transit-and-tir-newsletters/newsletter-3-january-2021
- Export Accompanying Documents: Across both the French (SI Brexit) and UK systems (GVMS) they have noticed that traders have been inputting Movement Reference Numbers (MRNs( from Export Accompanying Documents, rather than from Transit Accompanying Documents. This means that the Office of Transit cannot be completed on arrival into the new customs territory and is creating systems errors which may result in goods being held. The French have published high level guidance on this – HMRC have taken away an action to provide more detail on the error and provide clearer guidance to traders. Please note that for transit arrivals in GB, GVMS requires that traders moving goods under transit must submit a Goods Movement Reference at the EU port of departure – this must contain all transit accompanying document MRNs and should not contain EU EAD MRNs.
- Box 44: There has been some confusion over the requirements at Box 44 which is completed dependent on the type of goods and where they are going rather than mandatory in all cases. HMRC and Border Force have worked together to clarify when checks would be required, and the Transit Manual Supplement will be updated.
Starting Transit Movements
- If you are an Authorised Consignor – you can start the movement from your own premises including printing Transit Accompanying Documentation. If you are not Authorised Consignor you need to provide relevant information at Office of Departure to have documentation produced.
- In order for a trader to start a movement under Transit in the UK they must have a Transit Guarantee registered on NCTS and linked to the EORI that they are using to start the transit the movement. This has always been the case and no change has been made to this requirement. This guarantee must be sufficient to cover the maximum amount of duties suspended under transit at any single point in time. The duty is calculated according to the tariff of the country of departure without taking into account any preferences.
- On the 14 January the NCTS system was updated to require traders to enter a value for the level of duties deferred under each movement when they lodge their declarations onto NCTS. This change allowed NCTS to track each traders usage of their guarantee, and would prevent traders from starting new movements if the guarantee they have registered onto NCTS was not sufficient.