Preparing our Ports and Airports for a no deal Brexit
In the case of a no deal scenario, goods entering the EU from the UK will be treated as imports from a third country and goods leaving the EU to the UK will be treated as exports. All relevant EU legislation on imported goods and exported goods will apply, including the levy of certain duties and taxes (such
as customs duties, value added tax and excise on importation), in accordance with EU commitments under the rules of the World Trade Organisation. The need for customs declarations to be presented to customs authorities, and thepossibility to control shipments will also apply sanitary and phytosanitary (SPS)requirements for third countries will also come into effect.
The Government is committed to working with the European Commission and our EU partners to ensure that any potential disruption to connectivity as a result of necessary additional checks and controls is kept to a minimum. At the same time, Ireland is committed to protecting the integrity of the Single Marketand Customs Union, membership of which is a core element of our economic
strategy and has been good for Irish business.
Since the early summer an interdepartmental group has been meeting to prepare the measures required at ports and airports as a result of the UK leaving the EU on 29 March 2019 (may also apply to new exit date on 31 December 2020). This has included the staffing, IT, infrastructural and operational requirements at Dublin Port, Rosslare Europort
and Dublin Airport.
The Government discussed and made decisions relating to Brexit preparedness and contingency planning in July and again in September 2018, including the phased recruitment of the staff required. At the September meeting the Government agreed that OPW should undertake intensified engagement with relevant stakeholders to ensure coordinated planning for the additional infrastructure requirements at the ports and airports, with a view to ensuring that the necessary additional infrastructure became operational in a timely manner. Initially the focus of this work was on the central case scenario, in which a Withdrawal Agreement was concluded between the EU and the UK, but this has been extended to include the scenario in which the UK leaves with no
ICT systems across Revenue, Department of Agriculture, Food and the Marine and the HSE Environmental Health Service will need to be enhanced to deal with the increased volume of documents and requests for clearance. An initial provision of just over €3m is already allocated to address ICT hardware andsoftware requirements. Further phased steps are planned to upgrade and improve relevant ICT systems and infrastructure.
OPW, working with key stakeholders, are progressing arrangements for new customs and sanitary and phytosanitary (SPS) requirements at ports. At Dublin Port, the following requirements are being progressed by the OPWand provision is being made for infrastructure including:
– 33 inspection bays for trucks coming off ships.
– Parking for 270 trucks to ensure that trucks awaiting inspection do nothalt other port traffic.
– A dedicated Border Control Post (BCP) for live animals;
– A public office with 8 counters/hatches and accommodation for staff;
– Office accommodation for an additional 144 staff will be required withinthe port area; and
– A new traffic management system will be developed in conjunction withDublin Port, to manage traffic to/from ferries.
At Rosslare Europort, provision is being made for infrastructure including:
– 13 inspection bays for trucks coming off ships;
– Parking for 35 trucks;
– A dedicated BCP for live animals;
– A public office with 6 counters / hatches and accommodation for staff.
In the case of Dublin Airport, detailed design work has already been carried out on additional facilities at Dublin Airport and discussions are underway with the Dublin Airport Authority (DAA) to develop a suitable location for these facilities. A BCP is required for Veterinary, Forestry, and SPS checks. This will include inspection rooms as well as ambient, chilled and freezer storage areas. In addition, a public reception, office accommodation and ancillary facilities arerequired for 20 staff.
The above outlines the full suite of requirements to meet new customs and SPS controls and checks. As an interim measure detailed scoping work is also underway in respect of options for a temporary approach in a no deal scenario at the above locations. This includes the identification of additional physical capacity at ports and airports for a no deal scenario, for example, at Dublin Port, a temporary site has been identified for urgent adaptation and fit out for a no deal Brexit.
Government has already sanctioned €4m for the commencement of a phased process for the recruitment of additional staff to carry out the greatly increased volumes of import controls and export certification arising from Brexit. After launching a recruitment campaign in September 2018 and receiving over 3000
applications, Revenue has indicated that it will have 200 new staff trained and in place by end-March 2019 and can further speed up the recruitment process to be ready for 29 March 2019 (may also apply to new exit date on 31 December 2020). Revenue is considering the various measures that may need to be deployed should additional staff be required in a no deal scenario. Such measures would include an acceleration of interdepartmentaland open recruitment, and the redeployment, on an interim basis, of existing staff.
The Department of Agriculture, Food and the Marine is implementing the steps necessary to facilitate potentially increased SPS controls, which in turn will require staffing, infrastructural and ICT requirements to be addressed at ports and airports. The first phase of this process, the recruitment of staff anticipated for 2019, is currently being put in place. In addition to the sanctioned recruitment, the Department will consider redeployment of existing staff in a no deal scenario, using models such as those put in place for the response to Foot and Mouth Disease. A new Environmental Health Officer Panel is scheduled tobe in place by February 2019 and can be deployed rapidly in a no deal Brexit
Ports Etc. July 2019
Preparing our Ports and Airports
Trade Flows through Irish Ports and Airports
In a no deal scenario, goods entering the EU originating in the UK will be treated as imports from a third country, and goods leaving the EU destined for the UK will be treated as exports to a third country. All relevant EU legislation on imported and exported goods will apply in accordance with EU commitments and under the rules of the World Trade Organisation (WTO). Relevant customs declarations will be needed, and Sanitary and Phytosanitary (SPS) controls will need to be applied.
While preparation at all levels will help, there is no doubt that, at least in the initial period, the additional checks and controls required on UK imports and exports will be disruptive. A crucial element, therefore, will be to effectively manage the new requirements for checks and controls on imports from the UK as a third country for goods coming through our ports and airports. Intensified arrangements are summarised under the following headings.
In the lead up to the end-March and mid-April deadlines, arrangements were finalised to ensure that sufficient infrastructure was in place in Dublin Port, Rosslare Europort and Dublin Airport to provide an emergency response to a no deal Brexit. The focus over the next months of the Article 50 extension will be to refine and improve infrastructure available for a no deal Brexit.
In Dublin Port, plans are progressing to further build on the temporary facilities now in place to provide a full suite of inspection facilities and to bring this additional capacity online over time.
Infrastructure for 29 March 2019 (may also apply to new exit date on 31 December 2020) In the lead up to 29 March, temporary infrastructure for customs, SPS and health checks and controls was put in place at Dublin Port. This infrastructure forms the basis for the incremental development of long-term infrastructure, including the enhanced facilities that will be in place for 31 October, as set out below, pending the completion of permanent infrastructure.
Infrastructure for 31 October 2019 (may also apply to new exit date on 31 December 2020) The provision of inspection facilities in Dublin Port for a no deal Brexit has involved nine separate projects spread across eight sites. The principal facility is a 6,000 square metre warehouse that has been converted to accommodate 13 inspection bays for SPS and food safety checks, as well as a Revenue turnout shed, which is in addition to three existing inspection bays elsewhere. Assessment of inspection capacity is ongoing.
Parking for up to 128 heavy goods vehicles (HGVs) has been provided as well as documentary and identity check facilities, a public office and ancillary staff accommodation.
An additional 100 HGV overflow parking spaces are also available as well as a facility for checking compliance of pet dogs, cats and ferrets entering the EU. A temporary liveanimal Border Control Post (BCP) will shortly be completed. OPW are in the process of securing an additional compound for detained goods and potential overflow parking.
Permanent Infrastructure Plans are in place to construct an additional 18 inspection bays and four turnout sheds, alongside documentary and identity check facilities with further HGV parking spaces. A public office and driver facilities will be provided as well as staff offices and accommodation. A permanent live animal BCP will be in place. Some of the temporary infrastructure, such as a number of inspection bays, will be retained.
OPW and client departments have agreed on the approach for permanent infrastructure, which will replace the temporary infrastructure used for a no deal Brexit.
Preparations undertaken at Rosslare Europort in the lead up to 29 March involved the provision of facilities, which are now being upgraded as set out below for the 31 October scenario.
Infrastructure for 31 October 2019 (may also apply to new exit date on 31 December 2020) Provision has been made for temporary infrastructure within close proximity of the existing port. A large warehouse will accommodate four inspection bays and a Revenue turnout shed, and the site will include the relevant offices, driver facilities, two documentary and identity check facilities, parking for 35 HGVs and a temporary live animal BCP. Staff accommodation and an export office are also being provided.
Permanent Infrastructure The permanent state inspection facilities will be constructed on a site adjacent to the existing port. This facility will accommodate inspection bays for SPS and food safety checks as well as a number of Revenue turnout sheds. The site will also include office accommodation, a documentary and public office, driver welfare facilities, two documentary and identity check facilities, parking for 35 HGVs and a permanent live animal BCP.
Arrangements were in place on 29 March to allow SPS controls at the airport.
Development of an enlarged BCP is ongoing This will include separated inspection areas for SPS controls on live animals, products of animal origin, plants and products of plant origin, as well as staff accommodation, freezer storage and inspection facilities.
Emergency orders were made under the Planning Acts by the Minister for Public Expenditure and Reform, acting on behalf of the OPW as the developer, to ensure the timely completion of the temporary infrastructure required at Dublin Port and Rosslare Europort.
The next phase of work requires further emergency orders for Dublin Airport and Dublin Port, which have been made on the same basis. Secondary legislation to facilitate the permanent infrastructure required is being progressed in full consideration of any environmental considerations involved.
Ensuring Optimal Goods Trade Traffic Flows
At Dublin and Rosslare Ports an interagency approach has been agreed between Revenue, the Department of Agriculture, Food and the Marine (DAFM), the Department of Health, HSE Environmental Health Service (EHS) and the Food Safety Authority of Ireland (FSAI) to ensure optimal goods trade traffic flows. A coordinated approach will be in place so that the necessary customs and SPS controls take place on imports from the UK. Revenue is leading on the necessary IT changes for October 2019 readiness. This approach will allow Revenue to signal to trucks whether they have been greenrouted out of the Port area or red-routed for further checks, including inspection where required.
Prohibited goods will be refused entry.
Revenue staff will manage and resource a control centre that will have sight of: parking spaces and exam bays; the number of consignments requiring a documentary or physical inspection; when the next ferry will be arriving; and the number of consignments that will need documentary or physical inspection on arrival.
The robustness of the proposed inter-agency arrangements to carry out any necessary customs controls, SPS checks at ports and airports will be tested prior to 31 October 2019 (may also apply to new exit date on 31 December 2020).
In order to avoid unnecessary delays, it will also be vital that industry prepare as fully as possible. Businesses will need to familiarise themselves fully with all relevant customs procedures; ensure that all necessary documentation is completed in advance and that any logistic companies being engaged are aware of new responsibilities; and consider the implications, for example, of having mixed loads, where some products are likely to green-routed but may be delayed if in a consignment with SPS products. For more details on how traders should prepare for Brexit, see the Chapter on Trader Customs Requirements, Education and Supports.
A Traffic Management Group for Dublin Port is continuing to consider the potential knock-on impacts on the wider area and city traffic management of any potential disruption in a no deal scenario.
The Group will have traffic management and communication contingency plans in place for a no deal Brexit on 31 October 2019 (may also apply to new exit date on 31 December 2020). This includes using a number of sites as holding areas for HGVs should they be required.
Minimising Disruption – Rosslare and Dublin Airport
When required, the Department of Health will designate Rosslare Europort as a Designated Point of Entry (DPOE) for certain food products controlled by the HSE’s Environmental Health Service, thus ensuring that, post Brexit, it can be used for the importation of such goods from the UK.
While the potential for disruption at Rosslare Europort is significantly less than at Dublin Port, due to the lower volume of trade on Rosslare/UK routes, interagency routing arrangements can be applied at short notice if required.
The challenges at airports are not as acute as those at ports due to the volumes involved, and existing procedures will be used in a no deal Brexit.
All goods arriving by air from a non-EU country are brought immediately to a transit shed within the confines of the airport or to a temporary storage facility authorised by Revenue outside the airport. Goods are held at these locations while awaiting the submission of documentation (customs declarations or supporting documents) or to undergo additional intervention by Revenue. Goods that require intervention by DAFM or the HSE’s EHS are facilitated within the confines of the airport. Goods can only leave those locations once these checks have been conducted.
Passenger Flows through Irish Ports and Airports
In a no deal Brexit scenario, UK nationals can continue to avail of the Common Travel Area arrangement as they currently do. There will also not be any change to the procedures for UK citizens travelling to Ireland from outside the Common Travel Area. Appropriate way-finding signage will be put in place should it be required.
When the UK leaves the EU there will be a number of specific issues relating to tax and duty on personal imports of goods. Part 6 of the Brexit Omnibus Act makes provisions for these issues. For more details on Duty Free sales and the application of the VAT Retail Export Scheme see the Chapter on Taxation.
The Department of Agriculture, Food and the Marine, which is responsible for personal consignments (i.e., the introduction of foodstuff, plants, seeds, etc. in personal luggage), has a presence in both terminals in Dublin Airport. There is currently no presence or plans for presence in Rosslare Europort or other airports. DAFM is involved in an active EU campaign called “Don’t risk it”, which is raising awareness of the risk arising from personal consignments.
Movement of Pets and Horses through Irish Ports and Airports
DAFM has developed plans that can be put in place to ensure that the obligations involved in moving pet dogs, cats or ferrets from other third countries will be applied to UK in a no deal scenario. These obligations will make the movement of such pets significantly more cumbersome.
Many airlines servicing Irish airports do not carry pet dogs, cats or ferrets and those that do carry them generally insist that pets travel in the hold of the aircraft. Dublin Airport is the only airport in the State that has been designated a Travellers’ Point of Entry (TPOE) for the arrival of pets in Ireland from third countries. Advance notification to DAFM of the pet’s arrival in the State is required.2 On arrival, pets from third countries must be presented to the Department at the airport to check compliance with pet travel legislation. There are no plans to change the existing arrangements at Dublin Airport.
Rosslare Port and Ringaskiddy Port are designated TPOEs for pets from third countries. The Department intends to designate Dublin Port as a TPOE for pets from third countries in advance of Brexit. Current facilities will be used in Rosslare Europort and a facility has also been identified in Dublin Port.
Movement of Horses
In a no deal scenario the Tripartite Agreement between Ireland, France and the UK on the movement of horses will no longer apply to the UK. Equines from Great Britain will only be allowed to enter Ireland if the UK is listed in the relevant EU legislation as a third country, and if listed, requirements will depend on the UK’s sanitary classification. The European Commission has indicated that the UK should be listed “swiftly”.
The UK Government has indicated that, in a no deal scenario, there will be no immediate change for equines currently permitted to move from Ireland to the UK on a valid passport as is current practice under the Tripartite Agreement.
OPW will continue to develop and enhance infrastructure at Dublin and Rosslare Ports, and Dublin Airport, in readiness for 31 October 2019 (may also apply to new exit date on 31 December 2020).
Traffic management plans for Dublin Port will be further refined for 31 October 2019 (may also apply to new exit date on 31 December 2020).
Work will continue with traders and with the logistics and haulage sector, to prepare them for new customs and regulatory requirements. Further detail is provided in the Chapter on Trader Customs Requirements, Education and Supports.
The Department of Agriculture, Food and the Marine will continue to monitor development over the coming months and update guidance already available on the DAFM and gov.ie/brexit websites in relation to the movement of pets.
The Department of Agriculture, Food and the Marine will continue to engage with the equine industry on the movement of horses.
Staff July 2019
Staffing and ICT for checks and controls Staffing
Revenue accelerated and expanded recruitment and training schedules to meet the 12 April 2019 deadline for Brexit, with an additional 400 staff trained and ready. Revenue will continue to build on this and will have 450 additional staff in place by 31 October. Additional staff recruited in preparation for Brexit are deployed across a number of functions, with approximately half on import and export trade facilitation activities. Revenue will continue to monitor the need for further recruitment, deployment and training.
The Department of Agriculture, Food and the Marine (DAFM) had around 190 staff ready to carry out import controls and export certification as of 12 April 2019. Further staff will be ready to carry out controls in the additional inspection facilities that will be available by 31 October. These numbers represent a combination of permanent and temporary recruits, and redeployment and temporary flexible solutions. Additional permanent staff will be needed to apply these controls on a permanent basis and to activate additional inspection facilities as they become available.
The HSE had 59 staff trained and available to conduct no deal Brexit (import and export) activities for the 12 April 2019 deadline. The HSE is progressing recruitment for a further tranche of staff before the end of October.
A 24-hour service will be provided at Dublin Port, and extended hours to match arrival times will be provided at Rosslare Port with on-call service provision outside these hours.
All Revenue IT preparations are currently on schedule. Based on the progress to date and the robustness of testing programmes, Revenue are confident that their IT systems will handle the increased transaction levels in a no deal scenario. DAFM’s necessary IT systems were in place by March 2019. Changes to improve connectivity with Revenue systems, and to improve export certification systems, will be complete by October 2019.
Revenue, the Department of Agriculture, Food and the Marine, the HSE and Environmental Health Service will continue to monitor and respond to recruitment, deployment and training requirements for 31 October.
Additional Revenue staff will assist with Revenue’s direct trader engagement campaign.