Goods movements involving Irish Ports – Transit and Indirect Exports

[Note: The information contained herein is accurate at the date of this event, however please refer to the written guidance on the Northern Ireland Customs & Trade Academy (NICTA) website for the most up to date guidance.]

Hi everyone, welcome to today’s webinar. This is a Trader Support Service webinar on goods movements involving Irish ports, particularly those for the transit and indirect export routes.

My name is Shenali Joshani and I’ll be hosting a webinar today. I’m sure most of you are already registered but if you haven’t done so already please do visit the Trader Registration Portal and sign up on TSS today.

You can also post any questions that you might have in the questions bar on the GoToWebinar dashboard and we will try to answer as many of them as we can. We’ll have two sets of Q&A, one halfway through and one at the end, so we will try to answer as many as we can.

So let me introduce your panelists today. You have five different experts offering their opinions to you today.

You’ve got Frank Dunsmuir, Shanker Singham, Eleanor Patterson, Celine O’Neill and Noreen Galvin.

Frank Dunsmuir is head of the Customs and International Trade Department at Fujitsu and is a senior member of the TSS.

Shanker Singham is a renowned international trade lawyer, is also a senior member of the TSS. They’ve both been heavily involved in getting the GB to NI movements and policies sort of defined, you know, quite heavily involved in the alternative arrangements. Commission report, if any of you had a chance to read that and now helped to find the consortium that makes up TSS.

Ellie Patterson is part of the Northern Ireland Stakeholder Engagement Team in HMRC and she’s been working closely with the team here to ensure effective delivery of the TSS and should hopefully be available later to answer any of your questions which are more policy focused.

Celine O’Neill is the Principal Officer in Revenue with responsibility for Brexit policy and customs legislation and she has kindly agreed to present on how the pre-boarding notification and the key Irish government systems interact with our TSS journey.

And then we have Noreen Galvin who’s the Veterinary Inspector at the Department of Agriculture, Food and the Marine in Ireland and she has kindly agreed to provide some incredibly useful presentation on SPS goods and their requirements when entering Irish ports.

So now that the introduction’s begun, I’ll hand over to our very capable panellist.

Thanks very much Shenali. So Frank and I will sort of take you through this slide deck.

What we wanted to start with was just a quick explanation of where we are with TSS so far.

We’ll then talk specifically about the various processes that we’re going to discuss and then we’ll have a Q&A session afterwards. If we can go to the next slide.

So just a quick summary of what the TSS actually is and just to go through that left hand portion of the slide. The TSS does provide education and advice to help traders understand the changes that are coming. That is done through our contact centre, which is now up to 750 people. The contact centre has people who can answer your questions on registration, you know, issues you have with your password, that sort of thing.

We also have tier two contact centre agents who have at least two years customs experience, who can answer more specific questions in that area. And then we also have tier three agents who have at least seven years experience of customs. What we are seeking to do, and as you’ll see from the data that will be flashed up in a second, is provide a digital first service. Obviously we have to do all the declarations from GB to NI, at least those that are not being done by existing customs intermediaries, and that is a huge number and therefore you can’t do this on a manual basis. So we have a digital first service. I think what we are seeing actually is that probably 70% of the inquiries that are coming into the contact centre are coming in digitally and declarations are raised digitally as well. So that does appear to be working. What we’re not set up to do is provide a personalised advisory service. So wanted to make it very clear that if you have very specific questions about, I’m moving goods from point A to point B, I don’t really understand how to do it, please advise me on what particular customs facilitation I need to use. That is not something that the TSS is designed to set up. What we are designed to do is once you’ve decided and you’ve taken advice from a customs intermediary or a consultant or an accountant or whoever, once you’ve decided what you’re going to do, then TSS’s job is to make that as easy as possible for you. And to that point, we’re not going to disrupt the existing intermediary market. TSS is a temporary process and we want to make sure that when we leave the market in two years or around thereabouts, that we leave a functioning intermediary market in Northern Ireland. TSS also does not raise what we call non-standard documentation. So TSS is a customs solution. We do not do the export health certificates for SPS goods, for example. We don’t cover other licences and issues for controlled goods.

Those traders will have to do themselves. But there is a, for agriculture and for SPS, there is a movement advisory scheme that is part of DEFRA that you can use. It does lower the cost of raising some of these certificates that are needed and there is a contact centre that you can call as well. We can go to the next slide, please. So these are our metrics for right now.

Useful to see declarations and movements. This is up to the 31st of January. So this is basically the month of January. We have about, we have over 32,000 traders who are registered with TSS.

88% of them are ready to trade. In other words, they’ve submitted their master data, they’ve submitted their information onto the portal and they are, and we’ve checked that actually will work for raising a declaration. You also see the number of goods movements that we’ve created to date, 38,000. And ENS declarations, the entry safety and security declaration, 106,900 of those. And the simplified frontier declaration, we’ve raised 80,000 of those in the month of January. There’s a sinusoidal curve for declarations being raised, tends to go up in the middle of the week, tends to go down towards the weekend and we’re seeing a fairly steady set of those. TSS has had no downtime in the month of January, 100% availability.

As I say, there’s 750 staff, 13,000 outbound calls, 11,000 inbound calls. So we’re not just making, we’re not just receiving inbound calls in the contact centre, we’re also proactively going out to traders. One thing I’ll pick up, 90% of cases related to declarations are handled in that very short timeframe. And 70% of contact centre cases are coming in via the web or electronically. So that really does make it a digital first service.

If we go to the next slide, and then this is just a profile on the ENS transactions.

So this is an example of ENS transactions on the 3rd of February, today’s report.

And we’re seeing these, and this is what I mentioned about the sinusoidal curve in terms of how they’re raised, daily peaks about 1,600 movements. So the bottom line from this is TSS is working, we are doing declarations, we are moving goods into Northern Ireland from GB.

And if we can go to the next slide. So, quick summary of the process from GB to Northern Ireland. I’m going to quickly hand over to Frank to talk about our process, just to recap it, we’re not going to spend a lot of time on this. I wanted to focus on Dublin ports today.

But as you know, we have split the process into a simplified frontier declaration and a supplementary declaration. That is all part of one single customs declaration. But it is designed so that you have, we prioritise flow of trade so that you can get across the frontier, across the boundary between GB and Northern Ireland. So I’ll just ask Frank to take us through this slide. Thank you.

Thank you, Frank. So this slide is an illustration of our core journey from Great Britain directly into Northern Ireland via road. And I’ll just take you through the key phases. On the left-hand side, the transaction is agreed between the supplier and the buyer. And at that point, they’ll typically decide who’s arranging the transport in terms of moving it from Great Britain to Northern Ireland. And of course, who’s going to be responsible for the declarations, the import declarations that are required. And it is a process of an import type process here.

There is no export equivalent. So it’s just the import requirements that are needed to move those goods. On the second block, once that’s been agreed and the carrier has been nominated, then typically the carrier will use the CSS to raise their entry safety and security declaration.

And that tells the inbound port, so it might be Belfast port or Longport, the details of the vehicle, the consignment and the time of arrival. So those are the typical bits of information on the entry declaration. It’s predominantly around border force type declaration in terms of where the vehicle is coming from and what goods it’s carrying and when it’s arriving.

We also use that information on the TSS to generate the simplified frontier declaration.

So for a little bit more data, we’re able to generate two declarations in one go. And that gets typically submitted by the haulier because they’re the ones that have the detail about the actual transport detail. So once that’s been submitted, in the next block, we’re then sending back the movement reference numbers to the haulier and also notifying the supplier and the buyer that the declarations have been raised. So the relevant parties get notified.

Those movement reference numbers are needed by the haulier to create a GVMS entry, so goods vehicle management system, which is a HMRC system that collects the details of the movement reference numbers associated with that vehicle. And that will return back a goods movement reference number to the haulier. So that’s one number or one code that combines all of the consignments within that vehicle for that particular journey. And that number is really important because that’s the one that gets you into the port. So, for example, if we’re going to Liverpool, that will be shown to the ferry operator at the port, and they will cheque the GMR is valid before they’re allowed to board the ferry. So once they’re allowed to board the ferry, they transport, they move across from Great Britain to Northern Ireland on the ferry. And on the next block, they’ll enter the port.

In this example, the port of Belfast, where the goods are either pre-cleared or checked, a document cheque or a physical cheque, depending on what the requirement is for those particular goods. That process is normally done as the, or the selection process will normally be done as the vehicle is crossing the ferry route from Great Britain to Northern Ireland.

And that clearing the port allows them to go to their final destination. So the actual buyer receives the goods on the right-hand side there, and the goods have arrived. So we’re using the simplified process as a way of getting the goods as efficiently across from Great Britain to Northern Ireland as possible, minimising the requirements there. What happens next is the TSS then uses the entry date that’s submitted on the ENS record. So if you’re saying these goods will arrive on Monday, we will then send a request to the declarant, to the importer, to say that you now need to raise a supplementary declaration. It’s SDI for short. That supplementary declaration closes out the customs process because it’s there that the buyer will, or the importer, will confirm all of the details of the goods, such as commodity codes and other items, information that’s required for those items. And if the goods are at risk and if there is a duty liable, it’ll be during the submission of the supplementary declaration that will be calculated. And just as a final point, the supplementary declaration needs to be returned by the 4th of the following working day of the following month. And if there are duties payable, they need to be made by the 15th of that month as well. So that’s an overview of the simplified process we’re using today. Next slide, please.

So now we’re going to talk about transit movements. Obviously, we talked about the core journey there between GB and Northern Ireland, the direct journey. Now, we are very conscious, of course, that there are many hauliers and traders who move goods, not only GB and I directly, but via Ireland, via the Irish ports, and that these are very important journeys for those traders. And so TSS has stood up a transit service, TSS Transit. And what we’re going to do is talk about that route, which we have stood up. And later on in the presentation, we’re going to talk about a sort of product in the pipeline. It’s not there yet, but we are planning to also support the Northern Ireland to GB sort of reverse route via Irish ports as well. And so we’ll talk about that later on in the presentation. But for right now, TSS Transit, how are we going to support GB to Northern Ireland via Ireland? At the moment, there are two legal ways of getting, a legally compliant ways of getting product from GB to NI via Ireland. And there are only two ways of doing this. We’re very conscious that traders in the past have regarded these routes as almost interchangeable. And I know that when there’s weather in the Northern Irish Sea, you have to have the alternative routes. But at the moment, under the Northern Ireland Protocol, and because the UK has left the European Union, the only two ways of doing this are either to use transit, to move goods through Ireland, or a direct export from GB to Ireland, and then the goods enter free circulation on the island of Ireland. Those are the only two ways of doing it. So if we go to the next slide, quick reasons why you should use TSS Transit. Obviously, those are the only two ways of doing it. And TSS Transit does minimise the paperwork that is associated with the declaration process because you’re not doing a direct export from GB to NI, sorry, GB to Ireland, which requires all the ordinary paperwork that you’d have to do for export into a European member state.

This will save you time, it will save you money. And we have put together a transit process that is, we think, as simple as possible, consistent with the law, and consistent with the requirements of the Transit Convention. It’s, and we’ve a quote there from Hans Martin, who’s the former head of the Dutch Customs Brokers Association, one of the world’s leading authorities on transit, you know, very supportive of the process that we have been able with our HMRC colleagues to put into place. So if we go to the next slide, so what is required in the process?

TSS will support the following elements of the process. So we essentially have an end-to-end journey for you with a couple of minor things that, well, one minor thing and one significant thing if you’re trading in SPS goods that TSS would not support. If we can go back to the previous slide, shall I? So the TSS will support with the following requirements. The first is the Entry Summary Declaration into the Irish Import Control System, the Irish ICS system.

TSS will do that Safety and Security Declaration for traders, for hauliers. We will also do the entry into the NCTS system, which is the transit system, and that’s what generates the transit documentation. So TSS will also do that for you. The Simplified Frontier Declaration, and the way the process works is the import declarations that we would have to do relate to GB to NI movements. So that’s separate from the transit process. We will, of course, do those. We do those anyway, always for the GB to NI movement. So the SFD and the Supplementary Declaration, which we would ordinarily be doing for the GB NI direct movement, we will do also for this process after the goods have arrived, after the transit process. Ordinarily, when you’re using transit, you need a transit guarantee. TSS does have a transit guarantee, and we are able to use that transit guarantee, or hauliers and traders who don’t have their own transit guarantee are able to use our transit guarantee in order to do these movements. TSS will also do the communications to UK Border Force, which are necessary. There are communications with UK Border Force at the beginning of the process, when the transit accompanying document is generated. And there is a communication at the end of the process when you arrive in Northern Ireland, and TSS will do both of those notifications on your behalf. The notification that we’re asking you to do is the pre-boarding notification, the PBN, to the Irish Railroad System, the Irish equivalent of GVMS, the UK’s railroad system. This is the notification to the Office of Transit in Ireland.

What we’re doing is we’re asking you to do that, asking hauliers to do that themselves.

We certainly will support if you have problems with that. We’ve been doing that significantly already with hauliers who’ve been using TSS Transit, and we’ll continue to do that. But one of the reasons we’re very pleased to have Celine O’Neill here from the Irish Revenue Commission is that she can explain now the PBN system, because I think what you’ll see from her presentation is that this is a very straightforward system. It’s very easy to use, should not present an obstacle or a problem. And then when Celine has finished her presentation on the PBN, I will carry on talking about the transit process and the other elements. So over to you, Celine.

Thanks, Shanker. And I think Shenali is going to put up the slides for me. I’ve only a handful of slides, and we’ll get through them fairly quickly. And as Shanker was explaining, any goods coming now on a RoRo ferry from GB into Ireland through Dublin or Rossly Airport will need to have a valid pre-boarding notification, and it operates in a very similar manner to the GVMS system. If we just move on to the next slide, Shenali, what the PBN is, it’s a virtual envelope, because in a happy flow scenario, a vehicle would only have one consignment on it, and there’d only be one associated MRN from a customs declaration or a transit declaration.

But the reality is that we know most of the vehicles moving backwards and forwards between Ireland and the UK have multiple consignments from multiple people, which require multiple declarations. So the virtual envelope ties all of those declarations, the underlying declarations, together with the vehicle that’s actually transporting the goods. So what you end up with is one unique identifier, very similar to the GMR in the GVMS system, that gathers together all of the information in relation to the support and documentation in one place. And the value of doing that from your perspective and from our perspective, it makes it much easier to identify what goods are arriving off what ferry. That means we can do all of our risk analysis or the majority of our risk analysis in advance, and it means then that when the goods arrive into the Irish port, the vast majority of them can be green-routed for immediate exit from the port, provided everything has been done correctly. And then obviously the reverse is true. You also need one when exiting from those ports and moving to GB. So if we move on to the next slide, as I say there, the main function is to provide all of the information to us so we can do that risk analysis. But also then it allows us to complete the Office of Transit formalities digitally, so the vehicles won’t need to present to customs at Dublin or Rosslare Port to have those formalities completed. We’ll do it digitally and send messages back through the NCTS system to show that work has been done. And as I say then, it allows us to assign a channel per vehicle rather than the driver needing to understand the individual routings for each individual declaration.

It can give an overall channel per vehicle. So if we go on to the next slide, I’ll just show you how you can create this PBN. So the system, the customs roll-on roll-off service is available on the revenue website. It’s just www.revenue.ie forward slash RORO, and it’ll bring you straight into this screen where you’ll see the option to create a PBN, to edit the PBN details or to cheque the status. So obviously, when you’re starting off, you need to select the create the PBN option, and it’ll open the screen that’s on the following slide. So there’s a few pieces of information.

Shanali, sorry, if we could move on to the next. Yeah, perfect. There’s a few pieces of information that the TSS will be able to provide you with in order to complete your PBN. So when it’s a load leaving the UK and coming through an Irish port, the movement direction there is into Ireland. You’ll have your MRN from both the ENS, the safety and security declaration, and from the transit declaration. So you’ll see there in the box, customs declarations. You simply type in the MRN for the ENS and click on the add button, and then you type in the MRN from the transit accompanying document and click the add button. And you can see in this example, we’ve just used an import declaration, but the exact same would happen with a transit declaration.

And you’ll be able to see the two MRNs on the screen. And once they’re in there, that’s really all that you need to do. You just then select the create the PBN option at the bottom. Obviously, that’s a very straightforward example where there’s only two declarations, but because it’s a virtual envelope, you could have as many declarations in there as you like. So if you’ve more than one customs declaration or more than one transit declaration, you simply keep adding them until you’ve added all of the MRNs for all of the declarations for the goods in your vehicle.

Once you click that create PBN, you’ll see on the next screen then, you’ll get a message back showing that you’ve successfully created your PBN, and it will show you the PBN identifier. So on this example, that’s just above the barcode, and it’s that information really that you’ll use from then on. That’s your unique reference number for that vehicle. And on the next screen then, what it shows you is we have created a channel lookup. So at 30 minutes prior to arrival, this facility becomes active on the website. And again, it’s through that same link, the revenue.ie forward slash RORO.

It’s not an app, just to say that. It’s available on the website, but you can save that link as a favorite so that you don’t need to navigate through the website each time.

When you’re 30 minutes out from arrival at the Irish port, you can go into the customs channel lookup screen, and you enter the PBN identifier in there. And if you click on the get your channel button that you can see on the screen, your channel information for that vehicle will be displayed. And we have an example of that on the next screen as well. And with the transit ones that are destined for Northern Ireland, unless there’s SPS codes involved, you’ll normally always get an exit the port channel information, meaning that you don’t need to interact with customs or with any of the other state agencies when you arrive into the port. And if that’s the case, you can just proceed directly out of the port as you would at the moment. The difficulty that we’re seeing, and I just want to take a moment to stress the importance of doing this correctly. The difficulties that we’re seeing at the moment is where the PBN hasn’t been completed correctly. That then means that the goods will get a red channel to call to customs, and it can take a number of hours to rectify the problem. So, it’s delays for hauliers, delays for drivers that really nobody can afford. So, the importance of getting the PBN completed correctly, I really just can’t overstress it. The last slide there is just some of the terminology that we use, and the slides will be circulated after the fact. So, I’ll just leave that there for you.

And then the final slide is just the different contact details for the different services that Irish Revenue will provide. So, if you have any difficulties in relation to your ENS, you can contact that dedicated email address. If you have an IT problem, a problem with the system, which hopefully won’t arise in this instance, because the TSS will be doing the declarations, so there shouldn’t be an IT issue. But if you do have a problem with creating your PBN, you can send queries to that dedicated email address, or you can contact the National Helpline, which operates 24-7. And we did share with Shanker before, there’s a more detailed guide on how to create a PBN, and we’re happy for that to be shared with people as well. So, that’s my presentation over, Shanker, I’ll hand back to yourself, but I’ll stick on the line in case there’s questions. Thanks.

Thanks very much, Celine. That was, I hope everyone will have seen that was very clear and straightforward. So, if we go, so just the bottom, sorry, Shanoi, if we go back to the previous slide. So, you’ve seen the PBN onto the Irish roll-on roll-off system.

In addition, if you are trading in SPS goods, agriculture, goods of animal origin, that sort of thing, there will be a need for additional certificates and licences and notifications for those goods, and that would also apply to excise and controlled goods.

Now, the difference with transit and a straightforward GB10i movement is, from an SPS perspective, this is as if you had entered Ireland, and therefore it is the Irish systems that you need, that traders need to interface with, with respect to their export health certificates and the other licences that they need to provide, in order, as Celine said, to avoid getting into the truck being stuck in the Irish port. I will go to Noreen Galvan, not now, but in a couple of slides, to go through a real explanation of exactly what the Irish requirements are here. So, we go to the next slide. So, I’m going to hand over to Frank to walk you through the very specific processes and when things need to be done. With the PBN, Celine mentioned you need the transit MRN and you need the entry summary declaration into the Irish ICS system.

You’ll have both of those because TSS will have generated both of those for you. So, you will have both those things before you, when you need to have them in order to do the PBN. But with that, Frank, if you want to take us through this slide. Thank you. Thank you. So, this is a five-step process that TSS uses to create the transit procedure and documents for you. So, I’ll take you through each of these steps. Just stepping back in terms of the wider context of transit, for those less familiar with transit, what we’re doing is we are effectively sealing the vehicle with goods inside. So, there’s a seal on the vehicle and we’re transiting that vehicle through another customs region. So, in this case, we’re going from GB through the EU customs region of Republic of Ireland and back into UK customs region within Northern Ireland. That normally takes a guarantee. So, you would normally have to have a guarantee to be able to use transit.

And also, it has the concept of an approved office of departure and an approved office of arrival.

So, that approved office of departure and arrival is approved by HMRC to act as a consignor, an authorised consignor to say the vehicles have been loaded with these goods and it has been sealed properly. And likewise, with the destination, an approved authorised office of destination would confirm the arrival of that transit vehicle with an intact seal.

So, with that in mind, the TSS, there isn’t really been an awful lot of time for organisations to get their authorisations in place to become authorised offices of departure and arrival. So, we’ll talk around how we’ve helped with that. And also, on the guarantor side, the TSS can act as the guarantor on behalf of that movement. So, the first step is you need to raise an entry safety and security declaration, as we mentioned. This is into the Irish system. And in order to do that, you’ll trigger the process by going into the TSS system as normal, raising an entry safety and security declaration as normal. The only difference being, excuse me, when you select the route, you will select a route GB to NI by IE. So, it’s a drop-down menu on the route selection.

There are only two choices, GB to NI or GB to NI by IE. That selection of that particular route kicks off the transit procedure within TSS. And what will happen next is TSS will send you a template, which is essentially an Excel sheet for you to complete your transit details.

So, you do need to complete the ENS as normal, and we will send onto the system, onto what’s called a case on your account. So, you’ll see a message appearing on your account with the transit template for you to complete. There are detailed instructions on the user guides, which will be on the TSS portal this week, which will take you through each of the fields that need to be filled out for that template and what they mean and how to fill them out.

The TSS will then use that template once you’ve completed it and sent it through to raise the necessary movement numbers for you. So, you’ll get a movement reference number for ENS, as Salim mentioned earlier, required for the PBN. You’ll also get what’s called an LRN, a local reference number. That’s not the transit number. That’s slightly different. It predates the transit number, but that allows you to now progress to the office of departure.

So, on item three, the goods have now been loaded. The driver has the MRN and the driver has the LRN.

And we’ll direct you to a suitable office of departure, which will be a location near one of the ports that you’ve chosen to exit. So, maybe near Holyhead, for example.

The TSS will also notify Border Ports that the transit has started. So, we’ll send that on your behalf to say the transit is starting. It’s going from point A and it’s going to arrive in point B with the following details. We’re asking the carriers to make sure that they will remind the carriers that all is to submit the PBN, as Salim has just highlighted for you there. So, submit those details into the PBN. And also, once you’re at the office of departure, that’s where you present your LRN, your local reference number. And the office of departure will confirm that everything’s in order and will release the transit accompanying document.

And it’s the transit accompanying document that has the movement number that Salim mentioned earlier needs to go into the PBN. So, you’ve got the ENS and the TAD movement reference number now to create the PBN. So, you can now cross the sea with the ferry and arrive at the port in Ireland and as Salim mentioned, you either get cleared, pre-cleared or asked to pull over for a cheque, a document or a physical cheque. The item four is how you end the transit. So, let’s assume you’ve exited the port of Dublin and you’re driving up to Northern Ireland to your destination.

So, there’s two options there. Either your haulier, your carrier or your particular depot is already authorised as an office of destination, in which case the vehicle can arrive there and they will have authority to close that transit on the NCTS system in terms of their own capabilities. Or if you’re going to, and this is the bit that TSS has introduced as an added feature, as it were, is if you aren’t going to an authorised consignee, then we have notified earlier the border force of the location that you’re going to and when you’re going to arrive, etc. and border force will respond with a, either respond confirming that’s okay or ask that particular journey goes to an authorised consignee location instead. So, they’ll have the choice there. So, if we don’t hear back from border force, you’re clear to unload at your chosen destination. If we do hear back, then you’ll need to go to the appointed authorised office of destination and that could be Belfast or Warren Point or one of those harbours. Finally, in item five, once the goods have arrived and the declaration has been closed out, the goods need to enter a customs process. So, they’ve arrived in a sealed container. They now need to be declared once they’ve arrived and that can be done with a simplified frontier declaration followed by the supplementary declaration that we talked about earlier on the TSS and that needs to be submitted by the fourth working day. Or they can go into duty suspension in the customs warehouse. So, that’s a quick counter through that process. Next slide, please. And there’s our bright lights of, don’t forget, you’re transporting SPS goods. You do need to make sure you have the accompanying documents, the health certificates, traces submission in advance and I believe that is a 24-hour notice requirement for entering to Ireland. Yeah, thanks Frank. So, essentially, just on that final point about the Border Force closing, if you’re not inside that six-hour window, if you arrive in Northern Ireland sooner than that, then you will have to go to one of those office of destination points. But if you are, sorry, if you arrive outside of the window, if you are beyond the six hours and you haven’t heard from Border Force, you can unload immediately.

But Border Force will indicate to you if you need to go to Warren Point, Lom or Belfast.

TSS is in the process of also applying for authorised consignee locations in Northern Ireland so that you would be able to use those authorised consignee locations in the alternative to an office of destination closing. And on SPS, as Frank said, this is the issue you need to focus on if you are carrying SPS goods.

You will have to make these notifications into Irish systems. And from an Irish perspective, this is as if you had entered those SPS goods in Ireland in the normal way.

So, it will be traces, it will be export health certificates and there’s a potential for an SPS cheque in the Irish ports of entry. But we’re delighted to have Noreen Galvin on the call.

And Noreen is going to take us through what the Irish SPS requirements actually are.

Yeah, hi, I’m just going to show my screen now. Sorry, can you confirm that you can see my slideshow? Yes, yes, we can see that.

Okay, so, yeah, so as you’ve both very correctly alluded to, regardless of whether you’re doing the transit or the direct import, your goods that require SPS checks will have to have those import controls done at the border control post of entry. So, either Dublin Port or Ross Lair Port. So, what are the SPS requirements? Now, I suppose I’m going to focus mainly on products of animal origin, because I believe my colleague from Plant Health will be here next week. But live animals, products of animal origin for human consumption, products of animal origin not for human consumption. Germinal products, so we’re talking about semen, embryos, ova for animal reproduction purposes, they’re all subject to import controls. And all of the material that is in products that are subject to these controls can be found in the regulation 219-2007. Now, there are some exemptions on some composite products, and these exemptions are used frequently on the trade that we’re currently seeing come through the port. So, you will require a health certificate for all of these products, so referred to as an export health certificate from GB. And this is where hopefully you’ll have engaged with your supplier in GB ahead of time to make sure that the product that you want to export to the EU can be certified for export to the EU. We, the border control post of entry, i.e. Dublin or Ross require pre-notification and document submission 24 hours in advance of the load arriving in Dublin port. Once we get that, we can carry out our documentary cheque, which is the first phase of the import controls inspection. And we do that on the copies of the documents that you’re going to submit, and we’ll talk a little bit about that. And then all products of animal origin, all live animals are subject to identity checks. Physical checks are carried out on products of animal origin at variable rates, depending on what they are. So, anything between about 15% or 30% of consignments would be subject to a physical inspection. Now, after having, I suppose, being a month in now, or we’re at the 3rd of February, I can’t overemphasize the importance of this person in the import controls process. And they are the operator responsible for the consignment. And if you’ve already done SPS checks directly into Larne or Belfast, you’ll know who this person is, you’ll know the importance of their role.

They may be the same person who’s doing your, well, maybe not in this case, but in our case, where we don’t have the luxury of a company to do customs declarations. Sometimes the customs clearance agents or the customs agents are doing traces. But the one thing I want to stress here is that if you’re using somebody to do your traces work for you, entering through Larne or Belfast, and you want them now to do some traces work for you entering through Rosslare or Dublin, it’s important that person registers with the Department of Agriculture, Food and the Marine in Ireland, so that we can validate them to create CHED for entry through the border control posts in Southern Ireland. And I’ll just mention one thing here, we’ve already seen it, we’ve seen some mix up. So CHED Ps, XIs for Northern Ireland being submitted to our imports portal. It’s very important that you create your CHED for the border control post of entry that you’re entering. So for us, they’re always CHED Ps.ies, that’s what they are. CHED Ps or CHED As for live animals or ShedPP.ies for plant and plant products. So if you are going to be importing SPS products through Dublin or Rosslare port, ensure that you have someone, i.e. an operator responsible for the consignment is the term used on traces ready and set up, able to create CHED.ies for products entering through Rosslare and Dublin. So their role, as we said, is just so important. They need to have access to all the paperwork. They’ll either get it from the GB supplier or the EU importer.

They have two things to do. They’re going to pre notify the border control post of entry 24 hours in advance. They’re going to generate the CHED, as we said.

And we’re also asking them to submit their documents to our import portal 24 hours in advance. Okay, we’re going to talk about that a little bit more later. So as we said, the first step, generate a ShedP.ie for your consignment. And you will be generating that based on the copy of the health cert, the scan copy of the health cert that the agent receives from the UK supplier or the EU importer. Once they have their CHED completed, then the next step is for them to get an MRN number for this consignment. So once they have their CHED and an MRN, they can proceed to our import portal. It’s a very simple step-by-step process. It doesn’t take that long to upload the details of the consignment. And the portal is so important to us because it’s where we can put everything together, I suppose. It’s our virtual envelope. Everything is here. And it also feeds into our internal system, which then customs feed into to route the vehicle accordingly for its required SPS cheque once it rolls off the ferry. So once we have 24 hours in advance, once we have everything, we start our documentary checks. So we’re looking at the health cert, the common health entry document and the supporting documents. The supporting documents could be commercial invoices, packing lists. For some of the trade that we’re seeing, the retail trade, the health certificates are extremely long. They have long schedules attached to them because there’s numerous products coming across. And sometimes we need to ask for supporting documents, i.e.

Excel files to support this information. Important to remember, if you’re moving fish, so wild fish, so anything that has the commodity code 03 or 1604 or 1605 is subject to ensuring that the catch is legal and is regulated under the fishing regulations.

And what we need is a catch certificate for that. And then that is uploaded also to our import portal.

The SFPA, the Sea Fisheries Protection Authority, are tasked with looking at, with ensuring that these catches are legal. And they will, they have access to our portal and they can cheque the catch certificate, the processing details, etc. to make sure that it is IUU compliant. So that’s another really important reason for the portal and for 24 hours notification, so that this can be done before the lorry, the load, rolls off the ferry in Dublin or Rosslare Port. Again, the operator responsible for the consignment is the person who we contact if we have issues with the paperwork.

And I suppose, again, having now, being into it now, whatever, nearly five weeks, we’re looking at the fact that there are issues. There are small, you know, there are issues with the health cert that we appreciate the agent can’t, cannot correct there and then. These have to go back to the OV or go back to the supplier. There may be issues with the creation of the CHED, with the weights, with the establishments of origin, etc. that have been entered. So there’s ongoing communication between the BCP staff in Dublin or Rosslare Port and the operator responsible for the consignments.

But once we’re satisfied that the documents are correct and we complete our documentary cheque, we then, we then take it as being signed off on our system and we route it accordingly. So, if there is a seal on the load, so a competent authority seal, and this will be done at the point of certifying, at the place of certifying when the OV is there doing the health certificate, then we can route this for a seal cheque. And this is a relatively, we’ll talk about it in a minute, it’s a relatively benign and efficient way of checking it. If there’s no seal cheque, then it must be routed for a full identity cheque. Important point to remember, the original health certificate must travel with the consignments. So the haulier must bring it or if it’s an unaccompanied load, we ask that it’s put into an external capsule or weatherproof envelope on the exterior of the trailer. And I suppose I’m saying this from experience, ensure that the health certs are not put in the back of the trailer because we’ve no way of extracting them.

If there’s a seal on the trailer, do not put the health cert in the back of the trailer because then it has to be opened, the seal has to be void in order to get the health certificate.

And that cannot be done in T7, the lane that is Terminal 7, the drive-through scenario, the load would have to go to Terminal 10. And that negates the efficiency that was hoped for with having a seal load. So ensure the health certificate is not in the back of the load.

So the identity cheque, as we said, for the products of animal origin, 100% of loads of products of animal origin. So if a haulier knows that he has a load, an MRN that has a CHED or a CHED and a health certificate submitted for it, 100% of those loads will require further DAPM inspection.

If they’re sealed, we can do a seal cheque. This is a very efficient way of cross-checking the health certs on the load with the seal on the exterior of the load.

Again, we cheque the number, we cross-reference the number.

And again, the seal must be intact, it cannot be tampered with.

If there’s no seal cheque or if we have discrepancies on the paperwork or we’re missing some paperwork, then the load is routed for a full identity cheque.

And here, again, it’s reversed onto a loading bay and the load is partially turned out proportionally to the number of consignments or the products that are on it that require identification to cross-reference the information on the health cert with the actual product on the load. The physical checks, as I said, the rate varies with the type of product of animal origin.

So the products that would be deemed at higher risk would be the likes of raw poultry would have a 30% physical cheque rate, whereas pet food packed for retail sale would have a 5% physical inspection rate. So if we route you from our system, we’ve done our documentary checks and we route you for a physical cheque, then you will be routed, well, you’ll be routed initially to T7 and then eventually onto, not eventually, then rather efficiently onto T10 where you’ll have your physical cheque.

Just an important point to remember that if you are moving goods, that all wood packaging, pallets, donnage, etc, needs to comply with the ISPM-15 in order to avoid bringing in any negative diseases and insects that would affect the trees, plants and ecosystems in the country or in the EU. It’s an EU-wide requirement. Okay, once we’ve done all our checks and the consignment is compliant and we can accept it, it’s free for movement within the EU, we validate the common health entry document on traces. We also sign off our internal system.

This is how customs will know that DAFM have finished their inspection and then customs will route the load or we’ll give it a green routing to say it’s free to go if indeed it is free to go from their point of view. If we have an issue with the consignment, then it may be refused, rejected and rejections can occur at any stage of the process. So, the documentary phase where the incorrect model of health search is used and if it cannot be rectified.

So, we can see here most of the rejections are coming because of documentary errors and certainly we’re seeing some loads still coming without documents.

Okay, so lack of documents. Now, hopefully that will reduce massively.

But the important point for this is to say the 24 hours pre-notification and document submission is so important for us. It just gives us that time to get the documents checked, get a routing for your load in time for customs to then give you the routing for the PBN that you have.

Otherwise, you’ll be sent to a terminal 10 or terminal 11 while the routing is being reconfigured to assess for the DAFM routing. So, it’s so important to get it into us in time.

If your load is rejected, you have the option of returning it to the country of origin or destroying it. Now, there are fees for the import controls process, even for smooth easygoing fees and it’s on average €55 per consignment up to 6 tonnes and it does increase by €9 per tonne thereafter. The operator responsible for the consignment, so the person who generates the CHED and signs the CHED, albeit the electronic signature, is the person who we charge and they will subsequently pass it on to the importer or whatever DDP or arrangement you have with whatever it is, but the fees are charged to the operator responsible for the consignment.

If there is a rejection fee or storage fees or destruction fee, that is subsequently added on to the fee. I would also say to you to have a plan in place to deal with the rejected consignments and this is important because IPAFs have to be notified of returning of the goods into GB and you’ll find detailed guidance on return on the gov.co.uk website regarding rejected consignments, but the thing that we’re saying is just make sure that you have someone that has access to IPAFs who can do the notification for you so that the rejected goods can be sent back to GB if that’s what you choose to do with them. So, just a summary, make sure you can get a health certificate for the goods that you want to export, make sure you’ve talked to the supplier in time, the supplier has access to an official veterinarian or your consolidation warehouse has access to an official veterinarian. The importance of the operator responsible for the consignment cannot be overstretched at this time, they are so important.

They’re responsible for the CHED, the imports portal, they have to be so careful and accurate with their data entry and their uploads and they have to be available for follow-up queries so that we can get the doc checks done as soon as possible and ensure that the original health certificate travels with the load. And then once you have passed your SPS checks and your CHED is validated, that load is free to enter the island of Ireland from the point of view of SPS checks and conforming to EU requirements for products of animal origin, live animals, germinal products, etc. Again, I’ve sent a copy of the slides so they’ll be shared. So, the email address Brexit Call, however general your query is, just email it there and then it’ll be divvied out to the correct department. There’s some very good information on the website, gov.ie agriculture Brexit is pretty good, it’s very good. There’s lots of information there on importing a varying degree of products. So, I think that’s it from me now. I’ll stop sharing my screen and hand back.

Thanks very much, Noreen. That was very useful. So, Shenali, if we can go back to the slide deck and go to the next slide. Yeah, just give me a sec.

And just while we do that, just to confirm that for these purposes that Noreen is talking about, the Northern Ireland importer is effectively the EU importer but they do have to register on the Irish systems, of course. So, this is just to show the alternative, the only alternative to using the transit process is a direct export to Ireland and that follows exactly the same procedure as a standard export to the EU. Once the products are in Ireland, then under the Northern Ireland protocol, they can be freely moved into Northern Ireland using free circulation on the island of Ireland. But it is important to note that this is effectively the same as exporting to any EU member state and you will need to do the UK export, the exit summary declaration out of the UK into chief. You need to do the entry summary declaration, safety and security declaration into the Irish ICS. You’ll need to do Irish import declarations into the Irish AIS system and you’ll also need to do the PBN as we discussed previously. But TSS won’t do that.

We won’t, just as we wouldn’t support a process, you know, going to another EU member state.

And you would need to have, if you want to do this, you’d need to have a separate customs agent to help you do that. But overall, you know, TSS transit is available, it’s ready now for you to use and we would strongly encourage you, if these movements are important to you, these journeys are important to you, we’d strongly encourage you to sign up with TSS transit.

If we can go to the next slide, that’s just another sort of summary of how these two routes compare. A major point I would say also on this is, if you are able to declare your goods not at risk, so your movements are GB to NI, not at risk and they’re staying in Northern Ireland and they’re going into retail and they satisfy the other requirements for not at risk, then you can use, if you’re using transit, you can still benefit from those not at risk movements with respect to not having to pay any applicable duty.

Whereas if your goods were at risk, you might have to pay a duty depending on a range of factors, including whether your products satisfy rules of origin in the UK-EU Trade and Cooperation Agreement, the TCA. So this is another advantage of using TSS transit is that you would be able to preserve your not at risk status.

And obviously there’s a limited number of declarations that would be required because you’re relying for the movement on your transit accompanying document.

If we go to the next slide, so I think we’re going to have a break here to go to questions, questions and answers. And also I think, Shalini, you’re going to do a poll now for the audience.

So our first one is just to ask you what type of business the majority of our attendees are. So while that’s going, please feel free just to click. And we have some questions that have been coming through. So we have one question, I’ve heard about the UK trader scheme and I think my goods are not at risk.

If I use transit to do this route via Ireland, will my goods now be at risk?

Right. So this is related to the issue I raised last time around, which is one of the advantages of transit is that you can preserve your UK trader scheme authorisation and you can still use it to declare. So essentially the customs part of the process is the generation of the SFD and then the supplementary declaration, which has to be done by the fourth day of the month after the month of the movement. And it’s at that point with the supplementary declaration that you would be declaring your goods not at risk. So you would use your UK trader scheme authorisation to do that. So absolutely you can use transit and still retain that not at risk UKTS authorisation. Great. Thank you. So just to be clear, will I need to do all of the extra transit requirements or does TSS do it all for me?

So I’m assuming this question is coming from a haulier because that is where the transit process is relevant. And from a haulier perspective, TSS will do all of the process.

The only thing the haulier will have to do is the PBN notification. I think we’ve seen from the presentation from Celine that the PBN is very straightforward. We will generate, we will have generated the LRN and from the LRN, the MRN will be generated. The transit MRN will be generated. We will have done the entry summary declaration into the Irish systems, into the Irish ICS. And the haulier will have all of that. So you can very easily fill in the PBN screens that you just saw. Great. Thank you.

And the health certificates and the traces and all of the SPS related issues that the trader would have to do. And that’s where the importer, the Northern Ireland importer has to do those processes, has to register into the Irish systems and complete those processes.

And we have one question probably for Noreen. If I am trading under Incoterms and my importer is therefore definitely saying that it lies with me, the GB supplier, to do all of the import requirements, how am I supposed to raise the ched if I’m UK based?

Yes. We have several traders working on that and they have used agents in the EU or agents in Ireland to do this for them. So ideally what happens is that you are registered, your company is registered in the EU if you’re registered as responsible for the load. So they’re the people that do the cheds. They can have users, they can have authorised users on their company to generate cheds. Those authorised users can have IP addresses or email addresses in other countries. But we have several people that are doing this, but they’re using an EU registered company that is validated for responsible for the load to generate cheds into Ireland. And that would include a Northern Ireland agent also could do that. Yes. Yeah. Yeah. So I think you’ve covered that off, but a similar question.

I’m a little confused. Last week I tried to log onto Traces to apply for an organic licence, but because the UK is no longer part of the EU, I was not able to get access.

So again, is this just they need to become one of the honorary members like you said here, Noreen?

So for that, it would be the import. Well, certainly the EU importer needs to apply for an organic licence to import organic products. And there is information on our website. Again, I’ll send you that. As an exporter of organic products, I think you would need to get onto Defra about that to have you registered as an exporter. So a GB supplier will need to be on Traces to be as an exporter, again, as an establishment, etc. So if there’s a requirement for them to be on it as an organic exporter, then it’s up to the APHA or Defra to validate them to do that. Great. Thank you. We have a question about empties. The question is if I’m running things back from Northern Ireland via Dublin, do hauliers need a transit document for empty vehicles? And I guess we can extend this, you know, how does it work if you are transporting empties via any of these routes? I know this question has come up quite a lot. I could probably answer this one if you wanted. I’m just wondering, sorry, it’s Celine here from Revenue, but I’m just wondering who you were directing the question as, because there’ll be a PBN requirement aspect. So I wasn’t sure, do you want me to take it? Yeah, if you could answer the PBN part, that would be great, Celine. Yeah. So for an empty vehicle, you don’t require any PBNs, there’s no declarations required, or you don’t require any MRNs, sorry, you do still require a PBN and you can create a PBN and tick the option to say that your vehicle is empty.

And that’s all you need to do for an outbound movement. On an inbound movement, if that box is ticked to say that the vehicle is empty, we do cross-reference that information with the information supplied to us on the manifest by the ferry operator. And if there’s a discrepancy, those vehicles would be red routed to see what has caused a discrepancy. But on an outbound one, you’d simply be selecting the outbound direction out of Ireland and indicating that the vehicle is empty. And then you follow the process as previously, you just click on the create button and it will generate your PBN ID for you. Great, thank you. And I know for the GVMS routes, it’s the same, it’s the same principle, please just select on the route and then it does give you the option for empty and then contract by carriage. So you’re given essentially a GMR, but it’s an empty one. So that, I think, pretty much mirrors the process for the PBN.

So the idea is you don’t need declarations, you just need to list that it’s empty so that you can board the ferry because the ferry operators, of course, won’t be able to necessarily distinguish whether your trailer is empty or not. So please just make sure you have the correct references.

And we’re getting loads of questions in about rules of origin and at risk. We do have the webinar on this topic tomorrow and both of these webinars repeat again next week. So hopefully we’ll cover off those questions then. We’ve also got a few questions coming in about supplementary declarations. And again, these will be covered in different webinars. So please just look out.

And there’s been loads and loads of updates in the weekly bulletins. So we can make sure they’re all out. They’re also all on NICTA. So I think we’ll pause it there with the Q&A. There’s also lots of questions on the reverse route, which we are about to cover in the second half of this presentation with another Q&A at the end. So I promise we will cover it all. And thanks to everyone who’s answered the polls. It looks like 47% of our attendees are micro SME businesses, i.e. those with less than 250 employees. We’ve got about 25% of large traders, 9% are hauliers, 7% are customs intermediaries or freight forwarders, and 13% have voted as other. So that’s really useful.

Thank you. Thank you very much. And we’ll continue with the presentation.

Great. Thanks very much, Shenali. If we can go to the next slide.

So we are going to talk now about the process NI to GB, where, well, we’re going to focus on where you’re going through an Irish port. Now, there are various options, NI to GB.

One is moving goods directly from NI to GB. And TSS does support that NI to GB route. And as we’ve said in previous presentations, under the terms of the Northern Ireland Protocol, there are no requirements, NI to GB. You have unfettered access, NI to GB, except for the 14 very specific treaty areas. These are things like CITES, endangered species, Kimberley diamond mining process, this sort of thing. Or if you’ve got goods moving in duty suspension, and that’s actually quite an important point as we come to explaining to you the products we have in the pipeline to support you here. And coming to that second point, this is not a service that we currently support. This is a service that we are planning. And we do recognise that there is a huge demand for NI to GB via Irish ports. And that we do recognise that there is some urgency here.

And that’s why we’re developing this at pace. And that’s why I want to talk to you about it today, even though we don’t have it fully in place right now. We expect to have it in place very, very shortly. And we will continue to keep you updated on progress in that regard. But essentially, what we are doing, what we’re using here is a Northern Ireland to GB via Ireland as an indirect export that has a very specific meaning that I will come to when we get to this portion of the slide deck. And we think that is the most simplified, the most facilitated way of getting products from NI to GB via Irish ports. We don’t, you could move them under transit to GB via Ireland. That would be a transit movement, just like the transit movement the other way. Essentially, you’re going from one customs territory, Northern Ireland, to the same customs territory, GB via a different customs territory, Ireland, part of the EU customs territory.

So you’ve got the same transit potential there. The complication with transit is that under the terms of the Northern Ireland Protocol, if you were using transit to do this, and if you are going to use transit to do this, or you’re using it now, this is a complication of transit.

Goods moving in duty suspension are subject to the export declaration requirement. So you would have to do export declarations anyway. And because the purpose of transit is to create a slightly more administratively or slightly less administratively burdensome journey by using the transit accompanying document as opposed to the full export process, you can’t do that in the case of the Northern Ireland Protocol. So it doesn’t make as much sense to use transit in this direction. Whereas under the Northern Ireland Protocol, you do have free circulation on the island of Ireland. So the better process is to use the advantages of the Northern Ireland Protocol and not the sort of disadvantages and build the journey accordingly. So TSS, we’re very focused on the trader experience. We’re very focused on ensuring things are as simplified as they possibly can be consistent with legal requirements. And that’s why we’re landing on this indirect export as the best way to move goods NI to GB via Ireland. But we wanted to explain to you why it is the way it is and therefore how we’re developing it. So if we go to the next slide.

So again, moving goods directly from NI to GB, they won’t be subject to new checks, requirements or declarations. That’s part of the unfettered access requirements in the protocol.

And for most traders who are not trading in those 14 treaty areas and not moving goods in duty suspension, you can move goods directly from NI to GB in the same way as you did before the 1st of Jan. There is an issue about what is a Northern Ireland qualifying good. And at the moment, until July, the definition of what is a Northern Ireland qualifying good is anything in free circulation in Northern Ireland. And because of the protocol’s requirements for no checks and controls between Northern Ireland and Ireland, that essentially means anything on the island of Ireland. And so that’s what you do now. If you want to know exactly what these 14 treaty areas are, they are very specific. There is information on the NICTA website that has the list of all of those different cases.

So, if we go to the next slide. So, moving goods NI to GB as an indirect export. And we will, in the future, support this option. We are in the final stages of planning it and building it.

And if we just use the example of Dublin, Holyhead, although this would apply, of course, to any Irish port going to any GB port, so would apply also to the Rosslare, to Fishguard, Rosslare to Pembroke routes as well. TSS will submit an indirect export declaration into CDS with NI as the place of export and the Irish port as the place of exit.

TSS will provide the export declaration movement references in the usual way. And just as with the transit route in the other direction, the Holyhead would create the PBN on the Irish system, which is the only additional requirement that you’d have in addition to the export declaration, the full export declaration. Now, because there is a phased UK border and because there are staged controls that will apply from July, it is important to note that for controlled goods specifically, and this goes back to the NI to GB export declarations requirements and controlled goods, that there will be a requirement for import declarations on chief. And that would apply now. But in terms of a tariff that might be applied, even if you are trading in controlled goods, subject to goods being qualified Northern Ireland goods, you can use the tariff override so that you wouldn’t have to be subject to any tariff.

The rules for GB on import controls are on that gov.uk link that is on the presentation.

And we would ask that traders who think they might be trading in goods that are covered by GB import controls, they would need to look at that link to verify whether they are covered. If we go to the next slide, please. And the final route, which TSS does not support this, won’t support this process, which is goods moving in transit, for reasons that I mentioned before to do with the Northern Ireland protocol and the requirement for export declarations for goods moving in duty suspension, which transit is. Sorry, can you go back to the previous slide?

So, in this particular case, there would be a requirement for the export declaration as well as the transit document. And that applies, you know, regardless of who is doing it for you. It applies whether you’re using a customs broker or intermediary or anybody else.

And it’s because of this complexity that we’re going to recommend when we have the product ready to go, the indirect export route. So, I wanted to give you a little bit of a sense and a preview of what’s in the pipeline. And so, you can plan accordingly. We go to the next slide.

So, I think that’s the quick preview on NI to GB via Irish ports. I’m conscious, Shenali, that you had a lot of questions on this particular route in the previous Q&A session. So, we’re now going to have another Q&A session. I don’t know if there’s another poll that you want to do, but if there is, we can do that as well. Yeah, I’m just going to make the next poll open. So, I’ll just launch it for you. Please answer it while we do the Q&A. So, I’ve just been flicking through the questions and we’ve got lots just sort of on clarifying the actual transit route itself. So, we’ve got questions about at the office of dispatch, aka the office of departure, how do you actually get to the physical printed TAD? So, just want to confirm that this will be done by border force at the office of departure, which will happen near whichever port you end up using and they will print it for you. And at that point, you’re given your transit MRN and your TAD and you, the driver, will need to communicate it with your haulier to figure out who then obtains the PBN as described by Celine earlier. And there were also a few questions around, do you need the PBN? If you’re doing the route from GB to Ireland, you will need a PBN, just like if you’re doing GB to Northern Ireland, you’ll need to use GVMS if you are moving freight on those routes. And that’s a legal requirement on the ferry operators. So, just to highlight, you will need one of those. Yeah, that’s correct. So, just to look at that route in particular and sort of bring this, make this a bit more real for people. Essentially, what happens on the, if you look at Holyhead, Dublin, for example, you will drive, the truck will drive to the Road King facility, which is the office of destination, sorry, the office of departure in close to Holyhead. It is at that point that the transit accompanying document will be raised by TSS.

We will provide the LRN, border force will provide the, to us, the convert that into the MRN.

And that will be available for printing at the Road King facility so that you’ll be able to print the TAD and other necessary documents at the Road King facility itself, which for the purposes of Holyhead is the office of destination, sorry, the office of departure that you’d be using.

At that point, you will have the transit MRNs and you will have the TAD. And you will also have, because TSS will do this for you, based on your entry into the ServiceNow portal, as Frank said, the NI, the GB to NI via Ireland route. That will generate the entry summary declaration into the Irish ICS system. So, you will have that as well. And it will also, by the way, generate the SFD, the simplified frontier declaration, which will be held in the system until the appropriate time at which the SFD would be entered into CDS in the normal way at the point at which the transit is closed. So, you’re sitting in Road King, you have those documents, they’ve been printed out for you. The haulier can then take those documents and do the PBN process that Celine outlined. Once that’s cleared, you then move on in your journey. And similar practices for Pembroke and Fishgold.

Great. Thank you, Shankit. We’ve gotten loads of questions coming through about what if I have split loads? So, if I’m using the transit route and in my trailer or my truck, I have some that need to be dropped off in Ireland and some that will continue to Northern Ireland, how does this work? So, we’re conscious that groupage is a big issue for these. And I’m going to ask Frank to sort of address some of the groupage related things that we’re doing because this also relates to groupage in other areas as well. I know there are lots of questions about that. But the bottom line with transit is that you need a transit accompanying document and transit documentation for each transit. So, you might have on the truck two or three transit or transits where you may have more than that. But you will need a separate transit for each of these different transit consignments. Do you want to say something, Frank, about the groupage?

Might be worth letting people know what we’re doing in that regard.

Yeah. Shankit, Shanali, do you have the groupage slides as well?

Um, yeah. I’ll just talk to those because my video on. So, it’s part of the initial and these slides. I think it’s these ones, yes. Yes, it is these two. So, in the original version of the TSS platform, it’s very much created in a structure that’s based around the actual vehicle itself. I think the next slide is the one that I want. There you go. So, we’ve got this structure on the TSS at the moment, which is a, I’ll call it a header vehicle, which is the first record that’s entered into TSS when you’re creating a declaration. And that’s very much the vehicle and the journey details go in. And then attaching to that header, you’re allowed to start setting up consignments, which typically are the supplier and either the supplier or the buyer type records.

So, depending on the structure there, you’re setting up a consignment that says these goods are going from this supplier to this buyer. And for each of the consignments, you can set up items, which is a description of the goods that are in that consignment. So, that’s a hierarchy in the structure that’s in the TSS at the moment. And the feedback from a lot of hauliers and carriers has been that for a groupage model, they don’t typically start with the header. They’ll start with the consignment. So, on the next slide, we’re about to release a new version, a new option on TSS that works like this, which will allow organizations to create a consignment independent of a header.

So, you could be a trader, trader one and trader two could create their own consignments in terms of the shipments that they’re planning to move from Great Britain to Northern Ireland for that particular, you know, for the next few days or weeks, whatever forecast they have. And they can start to build up that consignment with the items that they want to put together for a particular consignment. So, these will exist as standalone records in the TSS portal underneath that trader’s account. So, they can quite happily build their plan in terms of the products they’re wanting to move to Northern Ireland. And you can’t submit those. You won’t be able to submit a consignment on its own. But what will happen there is, once you’ve arranged, if you’re the trader, once you’ve arranged for the shipments to be moved, you can enter the details of the, or the EORA detail of the carrier or haulier that’s going to pick up your consignment. And that record will move over and be visible to the carrier. And the carrier can pick that record up.

So, they’ll have a growing list of consignments that have been allocated to them. And they’ll be able to determine how to group those consignments for a particular vehicle movement. So, they’ll make the choices. And once they’ve done that, under that particular header, they can then submit the record and create the necessary declaration. So, the ENS, the entry, safety and security declaration, becomes the last thing that’s completed, as opposed to the first thing in this particular model. So, this version should be out in the next few days, just going through final testing. And I think there’ll be a significant improvement for groupage and also allowing traders to work in a slightly different way as well.

Great, thank you.

And just on this point, the reason why this is so important and why we wanted to raise it in response to that question now is, of course, transit is only part of this process of getting goods from GB to NI via Ireland. There is also the customs process. So, in addition to the transit documents that you’d need for different transit movements on the same truck, you also have to do the SFD and you also have to do the, ultimately, the supplementary declaration. And we wanted to create a system that was easier for groupage hauliers to use. And that is what TSS release 2 is all about for the consignment first model. Okay, are there other questions, Shanker?

Great, thank you. Yep, let me just change over the polls so you can see them. So, out of our responders, we had about just over half have used TSS to make movements.

So, now I’m just going to open up the next poll. Do you intend to?

So, now we’ve got a question. Hopefully, we’ve still got Noreen on the line.

Can the Department for Agriculture please confirm what the process is if the original health certificate is lost after leaving premises in GB before reaching Dublin Port?

So, Noreen, if you’re speaking, you’re on mute. So, I just wanted to make sure you knew.

Oh, sorry, Shanker, I just had to run out. Could you repeat the question? I am sorry.

No, no, absolutely fine. Can Daphne please confirm what is the process if the original health certificate is lost after leaving premises in GB before reaching Dublin Port?

Okay, there is a, as long as we have a colour scanned legible copy of that, of it as part of the document submission, we can work with that. We are required to see the original health cert. Now, there was, there probably, it is probably still in place. There has been some COVID derogations about the handling of original health certs. It is up to the BCP whether they want to use that derogation. We haven’t been using it because of the importance of the original health cert. And actually, the presentation of the original health cert, at some times, because the paperwork submission has not been great, the health cert is the only thing that has saved the load. But I suppose to specifically address the question, if it is lost, well, then a replacement certificate can be reissued if your OV is okay to that. So, there’s very strict guidelines about when a replacement certificate can be issued.

And being lost or damaged is one of those areas when a replacement certificate can be reissued.

But as I say, for the interim, we are trying to, we understand that everyone’s getting used to this process and transferring them, especially on unaccompanied loads, can be difficult at times.

So, if we have a good quality scan copy, a colour one that shows us that the OV signature and stamp are present on each page in a different colour, etc., then we can work with that. But we would ask you to try your best to get the original to us. Great. Thank you, Noreen. We have a question, I think, that’s probably for Celine. I’ve had quite a few questions come in. How will the transit process work for people moving goods from the island of Ireland, transiting through GB onto mainland EU? And are any of the requirements the same here?

Yes. So, we refer to that as a land bridge movement. And whether it’s coming from Ireland or Northern Ireland, the process will be the same. You will need to use a transit declaration, much very similar to what was already described here. The office of destination would need to be somewhere, or the office of departure, apologies, would need to be somewhere on the island of Ireland.

The office of transit formalities would be completed on entry into the UK. But I understand that you need to put the transit MRN into GVMS as well as into the PBN. And then GVMS will digitally complete the office of transit formalities much as the PBN would do it if it was going through Ireland. On re-entry then in France or whichever other member state you’re going back into, office of transit formalities will be completed digitally again. And then the goods need to, the transit itself needs to be closed, much as Shanker described earlier, at an office of destination. Now, in France, Calais or any of the ports, they don’t operate as offices of destination. The preferred model in France would be to use an authorised consignee and closed movement at their premises. If you can’t do that, then there’s a whole list of offices of destination away from the port that can be used. But I suppose just a word of caution on that, those offices don’t operate 24-7, their business hours Monday to Saturday. So, now if the goods aren’t destined for France, if they’re moving on to another member state, you can close the transit at any location. That’s convenient for yourself. So, if they’re going on to a different member state, you might prefer to close it there, whichever suits you, but there’s a good few options around it. Yeah. And if I can just add a TSS sort of perspective, obviously TSS does not support movements that end in EU, other EU member states, so not Ireland, but the EU26. And the reason for that is, as Celine pointed out, the preferred method in the EU26 is really authorised consignee locations. And obviously we can’t, we’re not authorised to have authorised consignee locations in EU26 members. But there are, I mean, you should, if you are doing that, you should look at what the authorised consignee rules are in that particular member state, because there are simplifications that are allowed under the transit convention that some member states use slightly differently to others. So, I would make sure that you cheque that as well. Great. That’s what I was going to ask you to come on to. And just, Shanker, if you could help highlight as well, if you do have traders who are moving stuff, you know, across the land bridge, if they do wish to use TSS, they just need to terminate.

Yeah, you could certainly terminate in GB. And we’ll have, TSS will have both authorised consignee and authorised consignee locations in both Northern Ireland and in GB. So, yeah, you could do that. But if you’re going to do that, and you’re going to enter free circulation in GB, we strongly urge you to use, once we have it up and running, the indirect export route to do that. Excellent. Thank you. We’re getting, again, still lots of questions coming in around at-risk and what counts as a Northern Ireland qualifying good. So, maybe it’s worth just giving a really, like, high-level view just to help the attendees. But I suggest we don’t delve into too much detail, because we will cover this tomorrow. Yeah. So, we are going to cover tomorrow in detail the whole issue of rules of origin and the UK trader scheme, and not at-risk and at-risk, and all of that. So, if you do have questions, please come to the session tomorrow, because, you know, we will cover that in enormous detail. The one thing I would say is, do not assume, simply because there’s a UK-EU TCA, Trade and Cooperation Agreement, do not assume that means that you don’t have to worry about duties. The rules of origin in any trade agreement, you only can claim the preferential rate, which is zero in the case of the EU-UK TCA.

If you satisfy those rules of origin, and particularly in the UK-EU TCA, there are very specific rules of origin, and you may well find that even though you think that your goods are in free circulation in GB and they’re moving to Northern Ireland, you may well find that actually they don’t satisfy those rules of origin and a tariff would be applicable.

If you can qualify for the UK trader scheme and you can have a not-at-risk movement, it is very important that you fully examine whether you do qualify for that, because the point about the not-at-risk movement and the UK trader scheme is that is a movement between GB and NI, it doesn’t go on, it’s no risk, obviously, of going on to Ireland, and therefore it’s a movement entirely within the UK customs territory, and therefore you don’t need to worry about rules of origin, you don’t need to worry about the UK-EU TCA, you’re simply not going to have to pay a tariff. Now if you can’t qualify for the UK trader scheme, and we’ll go over tomorrow the very specific requirements that are needed, and probably there isn’t time now to sort of start going into them, but there are specific requirements for the UK trader scheme. If you don’t qualify for it, for whatever reason, if you don’t qualify for the zero tariff of the TCA because you don’t satisfy rules of origin, then if you are particularly, and this is particularly true for the smaller traders, there is a subsidy mechanism where you can claim a subsidy up to the level of your EU state aids de minimis rule, the EU state aids de minimis rule, and you can claim the waiver, which is effectively a subsidy, and then you don’t need to worry about that. So I would make sure that you’ve covered off all of those different areas. There are various things that you need to do, and I would say the other point I would stress here is that this is a decision you need to make now, because this is a decision that feeds into the information you put in when it comes time to do the supplementary declaration, and the supplementary declaration, we’re now, what, the 3rd of February. You don’t have to do it by the 4th of February, thankfully, but we will be producing a series, a release on the supplementary declaration. We’re doing a lot of training on the 4th of March, but that doesn’t mean you wait until the end of February to think about it. You need to think about it now, because you need to make these decisions about what tariff rate is applicable to you, and what mechanism you’re going to use, and these are complex questions, particularly if you are going to be relying on the rules of origin to qualify for the preferential rate. You must really do the work now to identify whether they apply to you. The rules of origin are the most, in many ways, the most complex area of trade agreements. It’s where the hundreds of pages of trade agreements tend to come from. There are rules about local content requirements that are specific to sectors. There are rules about what qualifies, depending on how much you process the product, in this case in GB, to see whether you lose potentially UK origin if you don’t process the product enough when it gets into GB. This was the Percy Pig’s type issue. It is complex, and it’s really important that you review it now, but there’s no better way to start that process than going to our seminar tomorrow on rules of origin and the UK trader scheme. Of course, all of these presentations are immediately available on the Northern Ireland Customs and Trade Academy, and I’d also say that the Irish Government’s presentations that you heard today will also be on the Northern Ireland Customs and Trade Academy as well.

Great, thank you, Shanker. There were lots of people asking the questions for links to the webinars and stuff, so if you haven’t received it via email, I’ve just put the email that went out with the link to register in the chat function, so hopefully that’s available to you all. Please do register, and like I said, we will be running these identical sessions again next week, and there’ll be an email going out for you to register for those shortly. We’ve got two more questions I think we’ll answer, and then we’ll probably close off. From a haulier’s point of view, what if you have your own transport guarantee? Is there any way to facilitate using your own guarantee instead of TSS’s? No, absolutely. If you are a haulier and you have your own transit guarantee, and you have your own authorised consign or consignee locations, let’s focus on the GB to NI via Ireland route, then absolutely you can use those.

That’s certainly an advantage that you can provide to your customers, and that’s fine.

There’s no requirement. Just as there’s no legal requirement on people to use TSS, if you’ve got a customs intermediary you like and you don’t want to change, and the customs intermediary is able to do this for you, then you should continue to use them.

The same is true of hauliers and the transit process. If you’ve got a haulier who’s already able to do this, it’s perfectly fine to be able to do it. There are certain things that are specific to TSS in the presentation that I just gave that relate to TSS processes that obviously would be slightly different if you were using a haulier and their own authorised consign or consignee locations and transit guarantees. You would need to make sure that you understood what the haulier was offering, but subject to that, absolutely, it’s perfectly fine to use the haulier’s transit guarantees and use the haulier to do this. Great, thank you. There’s a question I could probably just answer a bit quickly, just to clarify. Somebody asking about a haulier is insisting that the haulier will do the ENS, but is asking them to do the SFD. To be able to use the TSS process, how it works is the haulier will raise the ENS, we auto-generate the SFD for you, and then we contact you, the trader, later on to complete the SDI. We can’t separate those processes out, so you have to do it all with TSS or all yourself. We’ve got loads of material out on NICTA, so please just double-cheque the information to get a more detailed view of that.

Sorry, if I can just comment on that question, just so people understand why we’re doing it that way. Obviously, we have to process lots and lots of declarations. It’s a digital first service.

It doesn’t lend itself to being broken into component parts. In fact, we really can’t break it into component parts. As Shenali said, that’s the reason why. In order to be able to do the bill, to be able to carry the load of all these declarations, this is the way the system works.

It’s not a personalized service. If you need a personalized service, then it’s certainly appropriate for you to talk to a customs intermediary or broker. Great, thank you.

A question I know has come up quite a lot in the past as well. If I am an Irish importer, but I use the GB to NI channels, so the ferries say Liverpool to Belfast, how does TSS work for me, and can it support? What we’re saying in TSS on that front is that we understand that’s a route. We understand, obviously, that there are certain ports in Northern Ireland that are very reliant on this sort of thing, particularly that would be true of the port of Warren Point, for example. What we’re doing there is you would enter the port of Warren Point as a normal, basically, it’s our core journey, which is the GB to NI core journey, which is an at-risk movement, GB to NI. You would basically fulfill all of the requirements in exactly the same way. You’d raise the ENS. You’d raise the SFD. I mean, TSS would raise all this for you. The only issue is in order to take advantage of the TSS system, there has to be a Northern Ireland entity that’s registered on it. Now, that could be an Irish importer who has set up a facility or a subsidiary in Northern Ireland to do this. It could be a Northern Ireland haulier who’s acting for an Irish importer. It could be an agent of the Irish importer. It could be any number of people that could be registered, but the one thing it can’t be is you can’t as an Irish importer be on the TSS system, but there’s no real need for you to do that anyway. Provided you can cover that off, then yes, the way to do it, the simplest way to do it is GB and I at-risk movement, and then once you’ve read Northern Ireland, you benefit from the free circulation provisions of the protocol. Great. Thank you very much, Shanker. I just want to thank our panellists today for joining us, but in particular, Celine and Noreen, for joining us from the different government departments. Just before we sort of wrap up, is there any sort of parting bits of wisdom you would like to offer the audience here while we have the attendees’ attention? Well, the only thing I would say is, first of all, thanks very much for making the time to come to this. We noted that, and we set up the transit, the TSS transit, at pace because we were aware that there was a huge latent demand for it. To be honest, we haven’t seen the massive take-up of it that we thought we would see, and that may be because people are not fully aware of it. So, please do, not only for yourselves on the discussion here, but to let your immediate contacts and networks know that it exists, because we’ve worked through, there were a few initial kinks, we’ve worked through all of those. We’ve had wonderful collaboration with the Irish government, so thanks very much to Celine and to Noreen and their colleagues on making this work. It does work now, so please do use it. So, that’s one thing I would say. The other thing I would say is the supplementary declaration process is more complicated than the SFD to get over the frontier. It’s not the sort of thing that you want to, you know, wake up on March the 1st and decide, you know, now I’ve got to do a supplementary declaration by March the 4th.

You need to be preparing for it now. There is a wealth of material on the NICTOR website. There are lots of webinars on it that we are doing at TSS. Please avail yourself of all of that, and it is really critical, particularly for people who haven’t really traded, you know, who haven’t really used customs processes before, that even though your goods have crossed the frontier and have entered Northern Ireland, it is not, in order to be legally compliant, you have to do the customs declaration. The customs declaration is not just the SFD, it is also the supplementary declaration. If you don’t do the supplementary declaration, you are not complying with the law. So, it is incredibly important. We, in TSS, we sort of set up a system that was very, made it as easy as possible for traders to cross the frontier, to get their goods into Northern Ireland without major impediments and so forth, but we would really ask you to work with us on making sure that the supplementary declarations are fully completed so that you actually legally comply with the rules and you finish the process.

So, that would be my parting comment. I don’t know if Frank has a parting comment as well.

I totally agree. I think the next phase is really about getting used to the supplementary declaration where there is a level of detail beyond the current process. Please keep an eye on the user guide site on the TSS portal. There is a wealth of information there around, from the very basics of introduction to customs through to the supplementary declaration information. And also, I know you are probably getting lots of emails like all of us at the moment.

Every week, the TSS does produce a bulletin and we use that as one of the main sources of announcements of the functionality and features that are being launched by the TSS. So, please keep an eye on those as they come out each week and they’ll give you the latest information about the release for the supplementary declaration process and also the necessary trainings and guidance material. Thank you. Thank you, Frank. And just to add, I know there’s lots of nervousness around supplementary declaration and lots of questions coming through. There will be a really detailed demo coming out via this same portal, via IOE’s email from the TSS shortly, so please just keep an eye out. That will all be recorded, uploaded onto NICTA, and there will be step-by-step guides being released. So, we are here to help support you through the entire process. So, thank you very much to our panellists. I hope that everyone has found this course valuable. I’m sorry that we couldn’t get around to all the questions that were put forward, but please know that we will examine every single one and get to them in future sessions and add them to our growing knowledge base. It really does help us to improve the future content that we can provide. If you are looking to find out more information on any of the topics covered today, please visit NICTA, which is the NI Customs Trading Academy website, which is nicunicustomstradeacademy, all as one word, at .co.uk. Here, you can sign up for more webinars, courses, and guides to help answer your questions. We’ll also be uploading a recording of this webinar and the session tomorrow up onto NICTA, along with a copy of all of the slides you’ve seen today.

So, please do go and register on the TSS if you haven’t already. Please post any questions that you would like continuing to be answered. Thank you all to our panellists for sharing your knowledge, and thank you everyone for attending. Have a great day. Thanks all. Thank you. Thank you.