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A Guide to Ro/Ro Exports from the UK to the European Union in a No Deal / Hard Brexit Scenario

Following requests and after numerous questions from our clients as to how Customs clearance will work post Brexit and following the removal of Non-Disclosure Agreements I have now formulated the following guide to assist you in deciding how you might be able to Export your goods form the UK to the European Union post Brexit when using a Ro/Ro method.  My guide to importing will follow once I able to give clear clarification of the processes. Unfortunately the Import processes Customs are advocating companies consider utilising aren’t as clear as they might seem. TSP for example cannot be used for goods exported from the EU under the cover of a transit T-from , which is clearly missing from the HMRC guidance.
Before you read please bear in mind the following.
1) This process is for EU27 traffic only – Existing third country traffic travelling by road will follow the same procedures as it does today
2) All documents (excluding ATA Carnets) will need a corresponding import declaration raised in the EU and it is our belief there is a huge shortage of Customs agents on the continent to meet the demand
3) Stopping to raise Customs document and have them processed electronically or manually causes friction so delays will be inevitable
4) There has been little external investment to train UK Customs intermediaries so there is currently not enough capacity across the industry
5) Customs agents and forwarders will struggle to meet the demands of obtaining and managing transit guarantees , some may not even want to accept the liability so there will be an increasing demand for UK exporters to obtain their own guarantees for agents and forwarders to use.
6) These process are the only conceivable solutions to export at the time of issue in our opinion, things could change in the coming days , weeks and months.
7) This paper is issued for guidance only and you should fully research which method of export which is best for your company and make a commercial decision based on your companies and clients requirements. 
Exports to the European Union
Methods of Export 

NCTS T-form – To move goods from UK to an approved office/point of destination in any EU Country.
TIR Carnet – To move goods from UK to approved office/point of destination in any EU Country.
ATA Carnet – Temporarily exported goods returning in an unaltered state, examples are exhibitions, horse racing and motor sports events.
Export declaration only with pre-lodged EU Import entry at the port of arrival – Only applicable for goods which will be cleared in the EU Port of arrival,  proof that a pre-lodged European Import entry is lodged at 
the port of arrival is held by the carrier before the goods leave the UK.
NCTS T-form 
Firstly, all Exporters of commercial goods will need to be EORI Registered so please do not hesitate and apply today.
For those that are not involved in Customs processes today, it is important to understand there are two parts to the export process when goods are exported under the cover of a NCTS T-form (Transit- T-form).
The first part is the export accompanying declaration which is also known as the EAD, EX1, EX or even a pre-entry. This is the Customs declaration that includes all the statistical and licencing information that is electronically transmitted to CHIEF and allows Customs intelligence to determine if the goods can have the permission to progress and leave the UK. 
In a change to how things operate today, UK Customs have advised that the export declaration will be able to be submitted for the export clearance checks as soon as they are available for export. This ideally will be at the exporter’s premises. Once an export invoice and packing list have been produced clearly classifying the goods for Customs purposes, an export declaration can be produced by the exporter, forwarder or the appointed Customs agent. This should be transmitted to CHIEF and once a P2P (Permission To Progress) is received from CHIEF, the goods can be loaded for shipment. If the goods are required for physical examination they must be taken to an approved Customs location to fulfil the examination.
If the goods were to attempt to ship to the Continent at this point (without a T-form) they would not be able to move beyond the port of arrival. The goods have to be under Customs control and the Customs taxes secured by a guarantee. The UK has been granted accession to the Common Transit Convention and these are some of the constraints of that system.
So, post-Brexit we envisage the most common method of moving the goods to their final destination will be under cover of a NCTS T-form (Transit T-form). A T-form will move the goods from the UK across European borders to the final point of discharge. At the point of discharge the T-form will need to be presented to an authorised Customs agent or Customs Office within 8 days of being issued.
The NCTS T-form can only be completed by someone with access to the Customs NCTS system. Documents are issued/released to transit at an authorised location within the UK such as Dover Western Docks or Folkestone Stop24 Services. Exporters or forwarders could choose to have their premises authorised but we have been informed the process could take up to 120 days.
A NCTS T-form has a financial guarantee placed upon it by a guarantee holder. The guarantee covers the VAT and Duty liability for the goods declared on it. The VAT and Duty element on some consignments will be as much as 30%-40% of the invoice value.NCTS T-form guarantee holders are required to financially manage their transit guarantees against a reference amount agreed between the guarantee holder, HMRC and the guarantee holder’s bank. Once the reference amount of the guarantee is exhausted, no more goods can be released to transit until outstanding/undischarged T-forms are discharged. Harbour Shipping has a NCTS T-form guarantee but it will not be sufficient to meet the demands of all of our clients post-Brexit so if you are moving goods from the UK to the EU today and want to continue doing so you should be considering obtaining your own guarantee which you can authorise Harbour Shipping to utilise.
The issue of a NCTS T-form has to be, in our opinion, the easiest way of exporting your goods to the EU once you are able to satisfy who is providing the financial transit guarantee liability. Agents or forwarders might accept this liability in some circumstances but there is a large commercial risk that many companies may not wish to accept, so you should consider having your own transit guarantee to ensure the movement of your consignments.
TIR Carnet - Updated 14/03/19
A TIR carnet like a NCTS T-form allows you to move your goods across borders to their end destination. Carnets in the UK can be purchased through the Road Haulage Association or Freight Transport Association who act as the principal and accept the liability of the goods in transit. A TIR carnet does limit you to be able to move goods to three Customs clearance locations and the vehicle must be sealed by UK Customs at the point of export and the seal has to be intact when reaching the first Customs point and the vehicle then re-sealed if moving to subsequent clearance points.
When using a TIR Carnet you still have to follow the export process, So, again you will complete the export declaration as early as the exporter’s premises and obtain the permission to progress.
Once the permission has been granted you can report to the designated Customs location of export and have the TIR Carnet raised. 
A TIR Carnet is a 14 Page Customs document which can be raised using a specialised printer or manually with a typewriter and carbon paper. They are fairly simple to raise as there are not many boxes to complete but they are extremely time consuming.
TIR Carnets have to be presented to a Customs office and be physically stamped which adds further burden/friction to those who will choose to utilise them.
On arrival in the European Union an electronic NCTS TIR has to be completed by a continental Customs broker, this is essentially an accompanying T-form with no guarantee, and will accompany the TIR Carnet to its destination. The necessity to have the NCTS TIR raised in the European Union is a change to current arrangements and is a direct result of our leaving of the European Union. The changes were indicated in Customs Information Paper 07 (2019).
ATA Carnet
If you are shipping exhibition goods, horses for racing or motorised vehicles for racing, then ATA Carnets will be beneficial to you.
ATA Carnets are provided and completed by UK Chambers of Commerce in advance of the goods being dispatched. 
Once a UK Chamber has returned the ATA Carnet to the holder, the shipment can be loaded for export. Once loaded the ATA Carnet accompanies the goods to the approved Customs location for export and it is presented to a UK Customs official. The ATA Carnet is endorsed (stamped) by UK Customs and returned to the driver of the accompanying vehicle.
Once the driver has the stamped document in his possession he can proceed to the port of export. He can freely cross Europe to his end destination where he presents the ATA carnet to the Customs at destination for endorsement. 
When the consignment is ready to return in an un-altered state the process in reverse is followed.
Export Accompanying Document with Pre-clearance in the Port of Arrival 
There will be situations where the consignee in France, Belgium, Holland, Germany , Denmark , Ireland or Sweden has arranged for the EU Customs clearance to be undertaken at the Port of arrival within the controlled port confines. Please note this will be only available for Port to Port shipments. For example, goods shipping from Portmouth to Caen where a UK Export declaration has been raised and a French agent pre-lodges an Import entry in Caen to meet the vehicles arrival. 
If this is to be the case for your shipments it is possible just to ship from the UK with an Export accompanying document. This document as we have already informed you can be raised as early as the UK Exporter’s premises and permission to progress granted.
Using this method is not as simple as you might think. If you use this method the consignee in the member state will have to arrange the pre-lodgement of a Customs entry and a copy of the import declaration must be produced to UK Shipping line along with the UK export accompanying documents by the driver at the UK port of exit.
This might seem advantageous as it removes the necessity for a transit guarantee however you need to consider that agents in the likes of Calais, Dunkirk and Caen to name but three are few and far between. You should only consider this option if you have the relevant import agents in place who have the capacity to lodge pre-arrival Customs documents. 
We would not advocate the use of this procedure , we believe it will lead to large delays in the EU port of arrival or in the worst case scenarios vehicles being shipped back to the UK for not holding the correct documentation.
I hope this will help you with your planning your export shipments when the UK does leave the European Union.
Kind regards
Steve Applebee