On the 25th November 2018 European Union (EU) leaders approved the agreement on the UK’s withdrawal and future relations with the EU.
The Tank Storage Association (TSA)1 recognises that the agreement still needs to go through the UK Parliamentary process before it is approved, but cautiously welcome this positive progress. It is essential for TSA members to ensure access to as frictionless a border with the EU and the Rest of World (RoW) as possible following the 29th of March 2019. We do not believe this is possible without a deal in place.
If the UK Parliament approves the deal on the 12th December, there will be a significant amount of work required during the transition period to finalise the details of our trading relationship. We have highlighted several areas with UK Government where detailed discussion and analysis is required, these include:
- interpretation and implementation of the revised Union Customs Code (UCC)
- clarity of processes – it is critical to understand what will be in place once access to the Excise Movement and Control System (EMCS) has been lost. The Customs Handling Import Export Freight (CHIEF) system is scheduled to be replaced by the Customs Declaration Service (CDS).
- ensuring administrative burden is kept to a minimum (and even reduced) relating to the handling of import and export transactions (for example declarations)
- ensuring there are no delays at border crossings caused by the need to process declarations
- duties and duty collection by HMRC are efficient and transparent
- changes that may affect cash flow (for example duty deferments), that may have a significant impact on the cost of business for importers and exporters operating in the UK, are kept to a minimum
- clarity on replacement for REACH
We also recognise that freedom to negotiate the UK’s own trade deals following BREXIT may introduce opportunities for business, for example:
- to end tariffs on bulk liquid imports from outside the EU (where those tariffs are currently in place)
- the potential to align systems and speed up related processes to account for customs duty like that currently in place for excise, i.e. via a scheduling process with relevant customs duties paid on delivery from warehouse rather than upon receipt
- a simplified customs declaration process utilising technical solutions (and potentially mirroring EMCS) that can be applied to all imports and exports
- potential to grow Generalised Scheme of tariff Preferences (GSP) partners to assist in country development and encourage tariff free movement of essential goods into the UK
We seek to ensure a frictionless efficient movement of goods and services in and out of the UK, with zero tariffs (where appropriate) and no delays at the point of import / export.
It is critically important to work with industry to understand any unintended consequences of changes to trade arrangements and customs policy. To this end we stand ready to work with Government to ensure the very best outcome.
Notes to editors:
1The TSA represents the interests of 50 member companies engaged in the storage of bulk liquids and the provision of products and services to the sector. Collectively members operate over 300 terminals and distribution hubs in the UK and have over 8.5 million cubic metres of storage capacity in the United Kingdom (UK) and Republic of Ireland (ROI). Our members provide and support an essential interface between sea, road, rail and pipeline logistics for many different substances including transport and heating fuels, chemicals, animal feed and foodstuffs.
For more information about TSA please visit the TSA website www.tankstorage.org.uk or contact:
Tank Storage Association
Devonshire Business Centre
Letchworth Garden City
T: +44 (0)1462 488232