Brexit – Exporting goods through Dover and Eurotunnel on ‘T’ Forms

Hello, its David here,

The government has recently released new information as to how exports to the EU via Dover or Eurotunnel will work post-Brexit.  The release seems incomplete [deliberately?] and can be found at:

https://www.gov.uk/guidance/moving-goods-through-the-port-of-dover-and-eurotunnel-using-common-transit

We believe trucks will be screened to ascertain what export documents the driver has.  There could be three categories:

  1. The driver has all forms present and correct with documents already set live at an approved inland location.  The driver may proceed direct to Dover or Eurotunnel to board in normal manner.
  2. The driver has all export documents, but they are yet to be set live.  Driver must report to one of three addresses to have documents set live – Epping, Ebbsfleet or the ‘Stop 24’ facility on the M20 near the Eurotunnel entrance.  After documents have been set live, the driver may report to Dover or Eurotunnel to board in normal manner.  This strikes us as incomplete and confusing – Stop 24 is where drivers currently go if they have a Customs requirement only when using Eurotunnel.  Drivers would not understand why they had to report to what is seen as Eurotunnel when they are to catch a ferry in Dover.  At Dover, there is an existing export Customs facility in Dover’s Western Docks.  Yet the release makes no mention of this.  These new arrangements are for EU destined freight only.  It is possible the authorities consider the Dover Western Docks facility already at full capacity dealing with non-EU exports.  Certainly, post-Brexit capacity will quickly be reached as it seems obvious to us many drivers will transit direct to Dover rather than stop at one of the three nominated inland locations first.
  3. The driver has no documents.  The driver will be diverted to Manston Airport (near Ramsgate) or to a new holding site in Ashford.  A ‘limited period’ will be allowed for documents to be arranged.  It is unclear how long this period will be or what will happen if it expires before documents have been raised.

The release suggests that it will be possible for the export documents to be set live at the new sites.  This means when the driver is released to proceed to Dover or Eurotunnel, he would be able to board in the normal manner.

In theory, this system may work.  However, it ignores the fact that drivers will probably just go straight to Dover or Eurotunnel, given the chance.  It is also unclear how trailers will be marshalled when in queues on motorways to identify where they will be sent – or even how it will be possible to physically separate them so they can be sent to the appropriate waypoint.

Having a facility north of London in Epping seems particularly problematic – many drivers would not be travelling anywhere near this on the way to Kent, depending on their route around the M25, or would simply bypass it.  Furthermore, no information has been issued for exports via other Ro-Ro locations.

David

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