Hello it’s David with apologies for going over old ground.
We have previously blogged about Transitional Simplified Procedures (TSP,) but I feel it’s worth revisiting as TSP appears to have some pretty glaring holes. I wonder if customs are aware and just don’t care? It’ll all sort itself out – or HMR&C will get lots more juicy fines…
TSP is a temporary arrangement introduced by the UK Government to aid the flow of import cargo through RoRo ports (including the Channel Tunnel) post-Brexit.
TSP approval allows the importer to avoid the need to present a full Customs entry at the time of the goods being physically present in the UK port of arrival. Some goods will still need a simplified form of frontier declaration – these are goods liable to excise duty, controls or licences.
The TSP approved trader’s EORI number is given to the driver who will be challenged for this when arriving in the EU port of departure.
On arrival in the UK port, the driver may proceed directly to delivery with no checks other than those which already exist for preventative measures.
The TSP approved party must make an entry in to their commercial records detailing when the driver disembarked from the ferry or train on arrival in the UK.
The TSP approved party must then present a ‘supplementary declaration’ to HMR&C by the 4th day of the month after the month of arrival. This is effectively the import entry. Any taxes due (customs and/or excise duties) must be paid at this point. The TSP approved party will be issued a duty deferment account for this purpose. At first no guarantee will be required, but after an initial period of three months, the trader must provide a suitable guarantee from a bank or financial institution acceptable to HMR&C.
The main issue with this system is the TSP approved trader’s ability to submit the required supplementary declaration. Most importers will lack the customs knowledge, software and computer links to do this. Many importers may also have more profitable things on which to spend their time.
Consequently it seems HMR&C has agreed to allow a customs clearance agent or freight forwarder to complete the supplementary declaration on behalf of the TSP approved trader.
There is also a question mark over the discharge of the transit document which will guarantee taxes whilst TSP cargo is in transit to the UK. We await news from HMR&C as to how this will be managed.
If I were a cynic, I would put two and two together and make five. Allowing the inexperienced to complete customs declarations and having no method of discharging transit documentation correctly? What a way to tee up lots of nice extra civil penalties, whilst marketing TSP as helpful trade facilitation.
Hellmann UK stands by ready to assist with TSP supplementary declarations.