TSA responds to UK’s BREXIT deal  

With EU leaders recently approving the agreement on the UK’s withdrawal from the European Union and future relations, the Tank Storage Association (TSA) has cautiously welcomed this positive progress, but recognises that the agreement still needs to go through the UK Parliamentary process before it is approved.
It is essential for TSA members to ensure access to as frictionless a border with the EU and the Rest of World (RoW) as possible following 29th March 2019. We do not believe this is possible without a deal in place.
If the UK Parliament approves the deal on the 12th December, there will be a significant amount of work required during the transition period to finalise the details of our trading relationship. We have highlighted several areas with UK Government where detailed discussion and analysis is required, these include:

  • Interpretation and implementation of the revised Union Customs Code (UCC)
  • Clarity of processes – it is critical to understand what will be in place once access to the   Excise Movement and Control System (EMCS) has been lost. The Customs Handling Import Export Freight (CHIEF) system is scheduled to be replaced by the Customs Declaration Service (CDS).
  • Ensuring administrative burden is kept to a minimum (and even reduced) relating to the handling of import and export transactions (for example declarations)
  • Ensuring there are no delays at border crossings caused by the need to process declarations
  • Duties and duty collection by HMRC are efficient and transparent
  • Changes that may affect cash flow (for example duty deferments), that may have a significant impact on the cost of business for importers and exporters operating in the UK, are kept to a minimum
  • Clarity on replacement for REACH

We also recognise that freedom to negotiate the UK’s own trade deals following BREXIT may introduce opportunities for business, for example:

  • To end tariffs on bulk liquid imports from outside the EU (where those tariffs are currently in place)
  • The potential to align systems and speed up related processes to account for customs duty like that currently in place for excise, i.e. via a scheduling process with relevant customs duties paid on delivery from warehouse rather than upon receipt
  • Potential to grow Generalised Scheme of tariff Preferences (GSP) partners to assist in country development and encourage tariff free movement of essential goods into the UK

We seek to ensure a frictionless efficient movement of goods and services in and out of the UK, with zero tariffs (where appropriate) and no delays at the point of import / export.
It is critically important to work with industry to understand any unintended consequences of changes to trade arrangements and customs policy. To this end we stand ready to work with Government to ensure the very best outcome.