End of the UK Brexit Transition Period - Changes to EU Security Filings

On December 31, 2020 the BREXIT transition period will expire, Great Britain, apart from Northern Ireland, will leave the EU’s Safety and Security Zone. Even if the EU and Great Britain still settle on a free trade agreement, it would require a waiver from the EU in order to continue treating the UK concerning security declarations as today.

Therefore, we deem it important to remind you about the security filing requirements in a Short Sea environment, which will come into effect when the UK will be treated 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 – Caucedo

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. Caucedo 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 to be submitted earlier than as per current practice.

The current position suggests that at the expiry of the transition period the UK will be treated as any other third country for filing purposes and therefore, in the absence of this position changing, the following UK documentation cut off times need to be applied with immediate effect on all services currently not affected by the 24 Hour Rule and sailing from UK on or after December 31, 2020.

Vessel sailing date / Documentation cut-off day

Tuesday before 1700hrs / Friday 1700hrs
Tuesday after 1700hrs / Monday 1700hrs
Wednesday before 1700hrs / Monday 1700hrs
Wednesday after 1700hrs / Tuesday 1700hrs
Thursday before 1700hrs / Tuesday 1700hrs
Thursday after 1700hrs / Wednesday 1700hrs
Friday before 1700hrs / Wednesday 1700hrs
Friday after 1700hrs / Thursday 1700hrs
Saturday or Sunday sailing / Thursday 1700hrs
Monday before 1700hrs / Thursday 1700hrs
Monday after 1700hrs / Friday 1700hrs

Furthermore, please note that UK Customs will continue to expect ENS for cargo on vessels arriving from round the world countries 24 hours prior to loading. Cargo on vessels arriving from EU ports will only need an ENS filing as of July 1, 2021.

We shall keep you advised about further developments on this topic.