The CIOT has received the following update from HMRC on transit issues.
Presentation of LRNs: HMRC has heard from industry and French customs officers that hauliers are arriving without the correct transit or import documentation. What seems to be happening is that hauliers are presenting one Local Reference Number (LRN) when starting transit movements at GB Offices of Departure. This is fine if a vehicle is travelling with all of its consignments captured under one Transit declaration. However, if a vehicle is carrying multiple consignments under different transit declarations but does not present all of their LRNs, the goods will be held on arrival in in the EU.
HMRC has amended their guidance to frontline HMG staff at OODs so they will now prompt every driver to present all of their LRNs, and is publishing leaflets with updated guidance in several languages for drivers. HMRC is monitoring the effects of these changes, but remind freight providers that every LRN must be presented at the Office of Departure or it likely the goods will be held on arrival in the EU.
Box 51: French authorities have notified HMRC that several vehicles have arrived in France either without an Office of Transit (OoT) listed in Box 51 or with an incorrect OoT. If a trader arrives in France without the correct Office of Transit listed, it is understood that ‘SI Brexit’ – their new digital border system – will hold the goods. This is because the local NCTS will not have a record of the transit movement or be able to complete Office of Transit digitally, unless this location is declared at the Office of Departure. The French system will need to manually request this data from the original Office of Departure and then process the movement. To avoid this issue, HMRC ask traders to ensure that they are declaring every Office of Transit en route – this means listing the port of entry into every new customs territory.
Export Accompanying Documents: across both the French (SI Brexit) and UK systems (GVMS) HMRC note that traders have been inputting Movement Reference Numbers (MRNs) from Export Accompanying Documents, rather than from Transit Accompanying Documents. This means that the Office of Transit cannot be completed on arrival into the new customs territory and is creating systems errors which may result in goods being held. The French have published high level guidance on this – HMRC has taken away an action to provide more detail on the error and provide clearer guidance to traders.
For now, HMRC ask that for transit arrivals in GB, GVMS requires that traders moving goods under transit must submit a Goods Movement Reference at the EU port of departure – this must contain all transit accompanying document MRNs and should not contain EU EAD MRNs. As per the French leaflet, goods arriving in France or the EU must submit an import declaration, transit declaration or logistics envelope, and must not submit UK EADs.