Tuesday, 21 December 2021

The all new Brexit v reality battle

So, to recap, Brexit has seen every Minister for Brext and negotiator. The compromises that are requred between the dogma and reality are impossible to reconcile. The latest to step up to the plate is cheese, jam and pork champion, Liz Truss, fresh from there underwhelming tenure as trade secretary.

She now has relations with the EU as well as the rest of the world, and Equalities Minister duties to look after.

She posted a statement yesterday echoing the line that Frost had about the role of the ECJ in NI and that the NIP needed to be revisited.

What about it being wrong or not operating as planned, she didn't say.

That Brexit is now under the control of the FCo means that there will be experience and diplomacy at the heart of UK-EU relations for the first time, and there was enough wiggle room in her statement to see a path to an agreed landing spot for both sides.

That Truss is Johnson's main problem if ever there is a leadership challenge, placing her in charge of the impossible task of delivering Brexit that satifies everyone could tarnish her undeserved high rating among party members.

Brexit battles are for the New Year, but in 9 days, new import regulations come into force, here is a summary from a wine importer, Daniel Lambert, whose business, and other like his, have had to use this process for the last 12 months.

Spoiler alert: its not good news.

"We are now twelve months in with Brexit and some media outlets have been in contact to see if everything is as bad I said it would be. Here is my final thread on the reality of Brexit after 12 months and what’s coming in 2022.

Since Brexit started excise goods (Alcohol, Cigarettes, other taxed goods) have been subject to the full Brexit regulations and checks that 95% of all other goods have not had to worry about in 2021.

Therefore the wine industry is very aware of the problems that everyone else will face in just 8 days from now. Moreover it’s why we are nearly fully stocked going into January but had to start that process back in October.

It’s about to get a lot harder because HMRC requires all goods to be pre advised from January 1st. But what does that actually mean? It means that every import must have a U.K. entry number, this is where it gets complicated.

CHIEF (U.K. importation computer system (built in the 80s)) creates an ‘entry number’ for every declaration. Each declaration requires up to 56 pieces of information to validate.

To validate you need to know the senders address, Rex number, EORI number, Excise number, your EORI number, the cost of transportation, the weight, type of packaging, commodity code, type of declaration (CPC) and of course any tax payable.

Once you have all that information you then need to ensure your suppliers understand the rules, have done the right declarations to exit the EU, the goods get a MRN number & know the port of exit BEFORE the goods leave the country of origin.

If your suppliers and you have got all of that done correctly then both set of documents must be stuck to the actual pallet/consignment so that both EU and U.K. customs can check the documents are correct.

Finally if the goods are excise suspended and going to a bonded warehouse (as much wine does) you also need a U.K. ARC number which is created on a different system via HMRC Gateway under EMCS U.K. Another two registrations required right there.

So folks there you have it, from just one document (pre Brexit) the supplier would create, to several barriers to trade which many will have no idea about on both side of the channel despite this coming into force in 8 days.

So one year on with us doing all of the above where are the issues? The fact is the system is so complicated that we seldom have everything done correctly by the suppliers first time round, it normally takes two or three versions to get it right.

Transportation companies are now in the habit (rightly so) of not even collecting stock until all documents are correct. The average lead times have gone from 1 week to 8 and the worst we see from the EU is 12 weeks.

Now I run a wine company which is not perishable goods and if it gets delayed the product is still fine when it arrives. But for fruit and veg and all the other perishable goods I dread to think how companies will cope.

With any business who are not up to speed they simply will not cope and even when you do get it right your suppliers must also be on their A game too. A supply chain is only as strong as its weakest link.

We have seen over 2021 the paperwork we send is often removed by drivers (who don’t know its importance) and this can’t happen in 8 days.

To conclude I simply don’t see how such a steep learning curve for both suppliers and importers will go well, the wine industry as you will see from retailers shelves is barely coping after 12 months of Brexit. Gaps are plentiful.

The wine industry now works on three month lead times and more often than not this is not long enough. It’s even worse with American wines. Stock that collected in July still hasn’t arrived in my warehouse. So the issues are global.

Brexit simply isn’t working and those that have been dealing with the full version on excise goods can see the impending plane crash. I dearly hope I am wrong but thus far I have been correct on my factual analysis.

Despite the bleak situation I would like to finish on a positive. Even with all the barriers to trade this week 4 pallets from Spain did turn around from collection to delivery in just 7 days. This is the only delivery in 2021 to achieve this.

https://twitter.com/DanielLambert29/status/1473542887346475010

I suppose the interesting this will be to see how Truss balances the reality of Brexit, when it become obvious and how that plays with the headbangers in the ERG.

This could go the way of an all out trade war, with the aim to remove all tariffs, NTBs, taxes and regulations. Or they could go and sit in their Brexit-mancaves and complain about they would have done Brexit right it it hadn't have been for the EU/Remoaners/reality/The US. I mean, who knows?

A year ago I sat in on a wibinar from the ISO organisation, where they explained how harmonisation enabled better, more efficinet and economical trade between two countries, and they hoped the UK remain in current harmonisations standards/regulations. As we have seen, REACH was far too complicated and costly and so has been kicked into the long grass for at least two years. The other stuff, we shall see.

THe other point is that, currently, the UK has gifted the EU the best trading conditions it could possibly want: implementing checks and inspections on goods entering the Eu for complaince, while goods into the Britain have had no checks at all, outside those for excise purposes. There is no incentive for the EU to negotiate when they have the best deal possible already, so checks on inbound goods have to come in.

But if there is a lead time of 3 months on goods from the EU, that would mean no fresh fruit or vegetables from the EU, and with the labour shortage in farming ongoing, this seems like perfect conditions for food shortages in the new year. Unless checks and paperwork are suspended. With nine days to go, no sign of that, but estimates are that 75% of businesses are unprepared for the changes, and Brexit, far from reducing red tape, will have increased it. As well as costs and delays.

Put that on top of further probable COVID restrictions, then 2022 could start out even worse than March to April 2020.

Now there's a cheery thought.

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