00:05 OK, welcome back for the third episode of the TSS Podcast. I’m Shanker Singham. I’m the Customs and Trade Policy Lead for the Trader Support Service Consortium. I’m joined today by Hena Elsayed, who is the Trade and Customs Specialist with the TSS Consortium and by David Vallely, who is the Northern Ireland Stakeholder Engagement Lead and Danya Sarayreh, who is the Northern Ireland Safety and Security Policy Lead.
00:36 In today’s conversation, we’re going to build on recent messaging, the recent webinars that we’ve done on the Import Control System 2, which is the Safety and Security system known as ICS2 for Ro-Ro movements and that comes fully on stream on the 1st of September. We have, as I say, covered this in a number of webinars and two previous podcasts, but we have had a lot of engagement on this issue.
01:07 So we’ve had a lot of questions coming through. So we’re going to pick up some of those questions and we’re going to do some other things in this podcast that will make it, we hope, easier for you to comply with and fully engage with the ICS2 system. Before we do that, I’m just going to ask Hena, Danya and David to reflect on, and give us a quick overview of the changes.
01:33 So we put some of these questions in, you know, in their proper context. So, and maybe I’ll kick off with Hena. Do you want to give us a quick, you did a fantastic job in the webinar of sort of outlining all the, the requirements. How about a quick overview from your perspective?
01:52 Sure. Thanks, Shanker. So what we covered in the previous webinar was the main changes that are coming into effect for ICS2, particularly for our railroad movements. I think we highlighted in the TSS portal all the various changes to the form. So they were, the inclusion of the name and addresses for the parties. So this is the importer, exporter, consignor, consignee and then also distinguishing whether the buyer is different from the importer and whether the seller is different from the exporter.
02:23 We also covered things like the requirement for confirming if the goods are moving in a container, in a registered shipping container, that’s one of the requirements as well for ICS2 as well as looking at the places of delivery and places of acceptance. Again, another requirement for ICS2 and I think we also looked at the requirement for a commodity code, a 6 digit commodity code which will be new to a lot of traders or hauliers who are doing the ENS or the Entry Summary Declaration and a detailed goods description. So we covered stop words as well.
03:04 So it’s worth adding that this is the final stage of ICS2 release 3. It’s been an ongoing project that’s been implemented over the years. The first releases brought on board movements and maritime movements. So we’ve now got all of those movements into Northern Ireland using ICS2 and then business to business parcels and into Northern Ireland on boarded in May.
03:24 So this is kind of the final phase of that system change. And that final phase, that deployment window closes on the 1st of September, right? So traders have got to do it from the 1st of September. That’s right. Yes, it’s been a window open on the 3rd of June, I believe, and it runs until the 1st of September. Great.
03:44 Anything David, you want to add to that? No, I think Danya took the words right out of my mouth, but worth highlighting that, you know, obviously we’re doing this podcast, but there’s a range of other resources available, both hosted by the TSS, but also on gov.uk. So as, as Danya mentioned, though, this is the third phase.
04:03 If you need any more of that background, there’s, there’s many places you can go to find that. So obviously we can’t cover everything today, but if you are looking for more of that context and background there are sources out there to find more of that detail. Great. And so, I mean, one of the things that came through in the webinars and in the podcast we’ve done in the past was I think there’s quite a lot of confusion, understandably in the trader mind between the safety and security process and the customs process.
04:32 And they tend to get blurred and they tend to get confused. So maybe I’ll come to Danya as the Safety and Security Policy Lead to sort of, you know, really clarify the difference between and why the safety and security process is different from the customs process. And, and maybe that will help people understand it in their minds.
04:51 Sure. The customs declaration process and the safety and security declaration process are kind of two entirely separate processes. The customs process as I like to describe it as the kind of the fiscal process and that is all about declaring the value of the goods and paying, ensuring that you pay the correct amount of duty.
05:10 The safety and security declaration process is all about providing Border Force with the physical information about the goods, so when they’re arriving, where they’re arriving, what the goods are, so that board of wars can risk assess that information and ensure that we aren’t having any illicit or illegal goods entering the territory.
05:28 So it’s there to help kind of keep the country safe and ensure that drugs, guns and other illicit goods aren’t entering the customs territory. So two separate declarations with kind of quite different purposes there. Yeah. And it’s understandable that confusion arises because in the TSS system, you know, you get the ENS first, the Entry Summary Declaration. And that’s what generates the customers process, at least initially. But yeah, please understand that it’s, these are two separate things and, and we need to make sure you don’t sort of blur them in your in your minds.
06:04 We got a number of questions in the webinar. We didn’t get to all of them. We got to most of them, but we didn’t get to all of them. So I’m going to pick up a couple of questions now. And the first question is to David. So, trader says we send goods to Northern Ireland via Royal Mail and DPD. How do we know if they need an ENS?
06:26 Yeah. So this is one we, we heard a few times, I think. And we, we get separately through our, our mailbox and very understandably because there are kind of separate ways of dealing with this. So for goods moving to or from consumers, which by which we mean private individuals in Northern Ireland, ENS declarations, so safety and security declarations aren’t required. And this is kind of in line with the, the new arrangements that also came into effect from the 1st of May. But if it’s business to business parcel, then you will need to do an ENS declaration as with other kind of business-to-business parcels.
7:02 And for those moving by air or express operator, you know they’ll already be completing this in ICS2, as Danya mentioned, you know this this is the third stage and they can continue to do that as part of their door to door set service. So the key difference there is whether or not it’s going to a consumer or to a business. Great.
7:22 Next question for Danya. The question about commodity codes, we got a lot of questions about commodity codes, the 6 digit commodity code, the question is, is vague on what the what the goods being moved are. Does this cause any issues?
7:42 So the ICS2 commodity code requirement is only 6 digits with an optional 2 digit for the HS code if you want to provide that. But the 6-digit code is the minimum requirement and that can be quite high level in some cases.
7:53 It’s smaller than the 10-digit code sometimes required in supply chains. So it’d be a case of taking the 1st 6 digits of that number and it is a change for the entry declarations. So we strongly encourage supply chain conversations and to ensure that that data is flowing through to the haulier. Who’ll be making the declaration and there are tools available online to help. There’s the Trader Goods Profile, there’s the Online Tariff Tool in Northern Ireland, and there’ll be continued support and comms engagement from HMRC to help you with that. And if you are unsure you can always contact HMRC for support with the commodity code.
8:26 Yeah, it’s worth pointing out, I think that the TGP, you know, the trader will put information on their TGP, which is an HMRC thing. And that will produce a 6-digit commodity code, ordinate digit commodity code for the goods that need that. And if you give as a trader, your haulier access to the TGP, you give them access to that process. That should help.
8:52 And then finally, Hena, feel free to add to that if you want to talk about the TSS. It was just about the TGP actually, because it’s not just going to give the commodity code, it’s going to give you that goods description as well, which again is a requirement. So by using the TGP, you’ll get, you get the extra as well with a goods description.
9:09 Yeah. And with the TGP goods description, the trader can put in however they describe the goods, right? Not just a specific type of description. Yep. OK, so question for you, Hena.
So how will this work with bulk loads with hundreds of different commodity codes?
9:29 Yeah, of course. I think that’s a really good question. It is probably something high on the list for hauliers have to sort of consider is having the bulk, the sort of bulk loads and the hundreds of different commodity codes. So I think the first thing to talk about here is probably the API, so the application programming interface. So if you’re a haulier and you’re able to have a system that you can set up an API with, you know, the TSS does support API submissions. So you know, that would also alleviate some of the admin burden on doing an Entry Summary Declaration. So that’s probably one of the first things to consider.
10:06 If you’re a sort of smaller haulier and you don’t have the options to use API, then there are other things that you could use. And I think we, we, we talked about and touched upon Danya and Shanker about the TGP. So you know, on the TSS portal, if you’re doing an Entry Summary Declaration, you could do, you could be doing the Internal Market Movement Information upfront at the same time. And that’s where you’d have the ability to access the TGP.
10:35 You know, so long as your customer has given you the access permissions to gain access to that TGP. But that can populate some information onto the ENS as well. So that’s probably another good one. You know, that could help with the, you know, lots of hundreds of commodity codes that you’d need to enter.
10:54 I think the TSS portal itself as well has been designed to do a lot of automation where it can, you know, if you are a registered trader and you have chosen not to keep the details private in your company profile, you know, the TSS will start auto populating things like the names and addresses, you know, if they’re registered on the TSS and have that. So that’s quite a good one as well.
11:18 And the portal does ask you questions rather than sort of force you to put the information in. So for example, if you’re, if you need to put the buyer’s details in and they’re the same, for example, as the importer, the TSS portal just asks you, you know, is the buyer the same as the importer.
11:34 And by selecting yes, it will just populate that information directly to ICS2, rather than saying, well, here’s all the fields for the buyer, you need to put the name and address. So, you know, there is some, some functionality that’s been designed to hopefully ease some of that burden as well. And I probably would say the last thing that that could also help is templates. So the TSS portal has got the availability for a goods records template.
12:02 So if you’re a haulier moving the same products for the same customer week in week out, you know, you could create a goods records template and then you can just use that template directly onto your ENS consignment. So that’s another option and something that I think I’ve just come across as well is that some hauliers and traders are already using or are used to using consignment first.
12:25 So again, you know, if you’ve got those goods a couple of days before they’re due to move as a haulier, you could start setting up the consignment information early. The same works for the trader. The trader is going to say, well, I can do the consignment because I know what I’m going to be moving with you in the next couple of days. You know, they can start using consignment first.
12:42 So that’s going to be something I believe that the TSS is working on functionality so that it can extend over to the ICS2 movements as well. But that’s something to look forward to as well in the future. That could also help with completing the ENS. And that’s a good segway into the into the next section here, I think. We’ve talked to you a lot about supply chain conversations, and I think we’re very conscious that that may not be clear what we mean by having those supply chain conversations.
13:11 So we’re going to try and do a little bit of a simulation of what that might look like. Obviously, there are various roles of, of people in this. There’s a haulier, there’s the trader, there’s the carrier, there’s intermediaries. And what we want to do is sort of help you understand and how to have these conversations in your supply chain so that the right person who has the right data can provide it to whoever is responsible for uploading that data into TSS.
13:40 So I’m going to ask Hena to sort of assume the role of the of the trader.
13:46 And I’m going to ask David to assume the role of the of the of the haulier.
13:51 And I’m going to ask Hena first of all, to talk to us about what the trader should be thinking, what the trader should be asking or what kind of, you know, conversation should the trader be having with the haulier?
14:04 What should be in your mind, you know, what’s your side of this, this supply chain conversation?
14:09 Yeah.
14:10 So I think as a trader, I’m probably thinking and looking at ICS2 thinking, well, it’s, it’s the haulier’s responsibility.
14:17 So how much do I need?
14:18 What information do I actually need to provide them?
14:21 Because they’re the ones who are moving, moving the goods.
14:23 However, because of the requirements for the ICS2, I’ll be obviously looking at what information am I already providing to them because there is also the sort of customs element of this as well.
14:33 So just because I when I move my goods with to Northern Ireland, I may have to do a supplementary declaration, or I may be doing an internal market movement information beforehand.
14:41 So I would be providing things like the commodity code, or the goods description of my products and I would know and I should have that information to hand because I know I’ve got something else that I may have to do either before the goods move or after the goods move.
14:55 So I think that’s not something that I’d be thinking too much about, but more about where my goods are going, who the buyer of the goods are, you know, what’s the end destination of my goods so that I’m able to give the information about where the goods are being delivered.
15:10 And that’s probably the things I’ll be thinking about.
15:12 From what I’ve heard so far about ICS2, I know there’s a names and address requirement.
15:16 So I’ll be looking back and thinking maybe I need to update the, the documentation that I give to the haulier to ensure that they have got all the information for the various parties that I’m going to be either selling to or are delivering to.
15:31 So that’s probably one of the things I’d probably be looking at.
15:35 But I’m wondering if David can, can shed any light on, you know, what he would be asking me and the information that I’d have to give him.
15:43 Yeah, very much in agreement with that, Hena.
15:47 Obviously as the whole year, I’m probably more concerned about the physical movement of the goods.
15:52 When am I moving, what route am I taking, which ferry am I on the timings?
15:58 And I’d probably have quite good sight of all of that, you know, but some of that can easily change depending on scenarios, you know, changing of ferries, which is also then really important around making sure ENS’s are accurate and up to date.
16:12 But what I’m probably looking to the trader much for is details about those goods.
16:17 If I’m going to a depot to pick up goods, I might not know the details of what they are until I get there.
16:25 My experience of commodity codes and, and the description of, of what’s in a box won’t be as, as close to the, the trader.
16:32 So that is where when we’re talking about the supply chain conversations, the, the responsibility, the legal responsibility for this, as Shanker mentioned, sits with the, the active mode of transport, in this case, the haulier, though it’s my responsibility, it’s incredibly important that those closest to those pieces of information are passing that to me.
16:53 And you know, the, the trader is looking to, to me in this situation to provide a service and provide a good service.
17:00 However, to do that, there is a degree of collaboration required to allow me to be able to fill out and, and complete that that obligation in a timely and efficient manner to keep your goods flowing and for your business to keep doing what it wants to do.
17:17 So that’s, that’s a key bit.
17:19 Depending on the nature of the supply chain, sometimes pallet network might be involved.
17:23 I might be looking to multiple traders.
17:25 So if I’m looking to multiple traders, again, incredibly important that those traders are making my life as easy as possible.
17:35 But again, there’s an element on me to be communicating with that supply chain to be really clear what it is I’m needing.
17:44 I know we’ve mentioned the TGP already.
17:45 I can be discussing with them if they have the TGP to give me the relevant access to be able to, to draw that information in an efficient way.
17:54 And you know, we’ve talked about some of the bulk side of things.
17:57 If I’m able to pre-populate or auto populate as much information as I can gain, a little bit of that is on me to make sure I understand what I’m what I’m doing.
18:09 But yeah, I think that’s the area that I’d most be looking to a trader for is what don’t I know?
18:16 What am I not closest to or have least experience of?
18:19 And that is probably going to be the details of what the goods are that that I’m moving.
18:24 And also while the whole time while looking at the other side of it, of how am I, where am I going with these goods?
18:32 So again, that that smooth flow of information I think achieves what will be the key to achieving everybody’s goal in all of this, of a trader wanting their goods to move smoothly and for me as a haulier to be to be able to move those goods on their behalf.
18:49 Yeah, it’s almost like a split role, isn’t it?
18:51 It’s almost like a split job.
18:52 It’s like you would know everything about the movement of the goods and the transportation of the goods.
18:56 Whereas in me as a trader, I know about the goods itself.
18:59 So it’s almost like it’s a split role here, sort of.
19:03 And that’s why we need to collaborate and pass that information across.
19:07 I sometimes see it as a kind of a way to contextualise that relationship between the trader and the holier.
19:13 It’s a little bit like if you book a holiday through an agent, the agent will take care of the logistics side of things, but you have to provide them with your details, your passport details, so that they’re able to book those and take care of that for you.
19:26 So it’s different, but it’s a little bit like that type of relationship.
19:30 Yeah, that’s a good analogy.
19:31 So, so when, when Hena calls up David and says, I’ve got these things to move, can you move them?
19:37 And he’s worrying about the logistics and how he, how he does that.
19:41 He’s got to remember that, you know, I need this extra information.
19:44 And Hena’s got to remember that she’s got to provide this information.
19:48 But of course, you know, that’s for a truck with us, you know one trader, you know one set of things, if as David, you mentioned, pallet networks, if you have, you know, lots of traders, if you’ve got groupage, if you’ve got pallet networks and so and so forth.
20:05 It, it does get even more complicated.
20:08 And so what I think we’d say is don’t have this conversation on your call with the haulier when you are trying to move the goods.
20:17 Have this, have this conversation long before that.
20:21 And the more complicated your movement is, the earlier you have to have that conversation.
20:27 So I don’t know Hena, is there anything else that you think you should as a trader be mindful of? If I’m moving good in the UK internal market, I may be using TGP.
20:40 So if I am using TGP, I’d be looking at, especially using the TSS, I’d be having a look at my company profile and thinking right, have I given my haulier access to this? Because if I’ve already taken the time and the effort to create my TGP and everything’s, you know, I need to be giving that information to my haulier so that the haulier can, it’ll make their life easier for them. I could give them a product reference and say these are the goods I’m moving.
21:05 Here’s my product reference from my TGP and that should hopefully start filling out some information on the ENS as well. So I think I’d be, I’d be considering something like this as well. If I am moving goods in the UK internal market and I’ve got a UKIMS authorisation, that’s something else I’d look at. I mean, the TGP sort of acts almost like Trader Mosta data, doesn’t it?
21:26 I mean that the haulier can pull all this information off the traders TGP, and David as a haulier in terms of route changes. I think this is quite an important thing for hauliers. How do you interact with the carrier and what’s the information you need to provide regarding the specifics of your route, and when do you need to provide that?
21:49 Yes, I think this ties in and actually a little bit with, you know what you were saying there Hena earlier about the difference between safety and security and customs, where for this the safety and security side of things, the timing is incredibly important because as Danya had touched on, the purpose of a safety and security declaration is, is different to customs.
22:08 So the importance of having this information available before the movement is key, which again ties into being able to provide within the ENS. We need to be providing the vessel number and information around that, that crossing and timings. So again, it almost puts the haulier in the middle of everything of needing to be drawing information up from the trader with regards to what is moving.
22:38 But also there there’s a requirement a little bit on the carriers, on the ferry operators to be making the information such as what we call the IMO around the vessel number to be able to put that in the ENS. So there is this kind of flow of information both up to the haulier, but also down from the carrier to be able to complete this.
23:00 And again, this all has to be done beforehand. I know Hena mentioned some of the stuff about pre movement IMMIs. With ENS. It is core that it is before the movement, as Danya said, otherwise the relevant risking and checks can’t be done. It’s you know, too late if the goods are already in a country.
23:19 So that is a bit that I’d really focus on and having those conversations about ensuring that information is there before the movement and as a haulier, you know, needing to be really aware of where I need to be drawing this information from in both directions, not just kind of assuming everything will be OK.
23:42 There may well be instances where the route you’re taking changes. So again, you need to be really aware of that and making the relevant changes, or updates to that, as any of those changes occur.
23:57 So it’s, it is quite a change, but the, the sooner this is engaged with and again, from a trader’s perspective, the sooner you are more familiar with the goods you’re moving and the commodity codes that relate to them and the routes and the relationships.
24:14 You know, if you’re regularly moving the same thing through the same haulier, you can build up that relationship quite quickly to make that as smooth as possible. I think the, the sort of key takeaway here is that the trader, because as you said, David, the haulier’s sort of in the middle of things.
24:31 It’s really important, even though the haulier is the one who has the obligation to do the safety and security declaration, that the trader doesn’t sort of put their hands in the air and say, well, you’ve got to do it. So it’s all up to you. If you want your goods to move and you’re a trader, you need to help, you need to participate in this process.
24:52 It’s worth adding as well that David mentioned that the ENS declaration has to be submitted pre movement and there are some set time limits within the legislation that mean the ENS has to be submitted a certain time ahead.
25:04 Now that changes by the type of transport that you’re moving goods into Northern Ireland with, but for road movement, so whether it’s accompanied or unaccompanied ferry movement, that’s two hours ahead of arrival in Northern Ireland.
25:16 So it’s definitely, definitely worth having those conversations well in advance so that your haulier can submit that your entry summary declaration at least two hours before arrival. You can submit it more than two hours before arrival, but no later than two hours before arrival.
25:31 And I think that’s actually a really good point because from the conversations we, we have been having with a range of stakeholders, some businesses operate 24/7, other businesses much more kind of nine to five.
25:45 So it is really worth building that understanding between the different actors within your specific supply chain because equally we appreciate, you know, different supply chains, different sectors operate in very different ways.
25:58 But setting out those kind of expectations and routes to help with any issues, any missing information, again, for a trader, incredibly important because if haulier doesn’t have the information he needs to be able to provide that information within an ENS, they may well not move your goods or kind of delay moving your goods until that information is forthcoming, which again, is not or may not be ideal for your business model or your, your other wider business relationships.
26:32 So again, the ramifications are worth considering and what mitigations you can put in place to ensure that, you know, as Danya says, if that information is available well beforehand, fantastic, get that sorted.
26:46 So again, if there are any issues, they can be resolved. But yeah, I think timing is incredibly important around all of this. Great. Thanks very much. And as always, if you are still in doubt on your questions, please raise the case with the TSS and we can help with the process.
27:05 So in terms of getting ready for this, we mentioned that the window closes on the 1st of September and from the 1st of September. You have to do this; you have to do ICS2. It’s obviously round the corner. What would your advice be in terms of getting ready, what you need to do to get ready? And I’ll go to Danya first.
27:27 My advice would be take action today to ensure that you’re ready. Make sure you have those conversations as early as possible with the people in your supply chain so that come 1st of September, you are well prepped, well ready and can move your goods as smoothly as possible.
27:41 And Hena, what about from a TSS standpoint? Yeah. So yeah, I’m going to echo what Danya said, like start looking at these things now. The TSS portal already has and is submitting to ICS2 for RoRo movements now since the 13th of July, which was about 8 days ago. So that’s already up and running.
28:02 So you know, all hauliers can start using the accompanied option or the unaccompanied option depending on how they’re moving the goods. And then they can see for themselves what information they are missing and what information that they need to go back and talk to their talk to their customers about if they’re missing any of them.
28:19 I think just to add here that since we have, since we have launched this on the TSS since the 13th of July, it’s been 8 days. And we’ve had about 100 / 150 traders who have now submitted an ENS to the ICS2 through the TSS. And about just over 800 submissions have gone over to ICS2. So it’s a really positive number that we’ve only sort of been active with it for 8 days, but we’ve had a large number of ENS submissions already. So it’s, it’s a positive sign that you’ve got hauliers looking and trying to do this now so that they can be ready for the 1st of September. Great.
29:03 So as we come to the of the podcast, I’m just going to ask David, you know, the really key takeaways and we’ve given you the sort of conversation that you could have between haulier and trader and so on. But what are the sort of takeaways in your mind and, and how should people be, you know, preparing for this? So a key one for me, I think is just to be proactive. Don’t wait for someone else within the supply chain, whoever you are within it, to be taking the lead on this. September is not far away.
29:34 So be proactive, familiarise yourself with the resources available. If what we’re talking about here is new to you, then, you know, go and find out more. There are resources available, both HMRC, TSS and wider to familiarise yourself with all of these things, you know, not just ICS2, but if commodity codes are new to you, maybe go and have a little look at that goods description, all these kinds of things that kind of integrate for this process and start having those conversations.
30:08 And then the final big takeaway, as I mentioned before, is the importance of timing across all of this and the potential, well, if you haven’t got everything done in the right time in the right space, that this will potentially have an impact to your, your goods moving.
30:25 But if you’re ready, if you have everything prepared that you need to, you should see no real change. But you do just need to be proactive and prepared and helping others in your supply chain to fulfil their role on your behalf and make sure all your goods carry on moving smoothly and as easily as they should. Excellent.
30:48 So I think we’ve got a lot of material on the NICTA website. So we’d encourage everybody to look at the NICTA website, look at the webinars, look at the podcast that we’ve already done. If you’ve got questions, you know, we’re here. TSS is here to answer them. Reach out to TSS, reach out to HMRC. I’m sure HMRC will be happy to help you as well. So that concludes this TSS podcast episode. And I just want to thank Hena, Danya, and David for participating and for this very interesting discussion.
31:25 Thanks. Thanks, everyone. Thank you. Thanks.
