EU Customs - Impact on EU Security filing requirements in case of “No-Deal Brexit”

We would like to inform you about the security filing requirements in a Short Sea environment if the UK leaves the EU without a “Brexit” deal on March 29, 2019.
The European Commission (EC) has confirmed that immediately as from that date the UK will be treated exactly like any third country for security filing purposes. EU export cargo that will be loaded on a service currently not affected by any 24 Hour Rule can become filing relevant depending on the vessel rotation.

Example: Rotterdam – London Gateway – Hamburg – Antwerp – Le Havre – Cartagena

All cargo loaded at London Gateway as well as cargo loaded at prior EU ports (e.g. Rotterdam as per a.m. example) and remaining on board the vessel while calling at London Gateway, requires to have an Entry Summary Declaration (ENS) filed for it in advance of entry into the EU. This is not limited to cargo discharged in an EU port later on, but also includes FROB cargo (Foreign cargo Remaining On Board) transiting the EU and destined for subsequent non EU ports (e.g. Cartagena as per a.m. example).

To comply with these filing provisions as Hapag-Lloyd, we will not only require complete and correct Shipping Instructions, but also in many instances need same earlier than today.

Therefore, we deem it important to remind you of the relevance of always adhering to the documentation closing times as stipulated in our Booking Confirmation.

We shall keep you advised about further developments on this topic. For any further information, please contact your local Hapag-Lloyd office.