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EU Security Filings in case of "No Deal BREXIT"

In light of the currently still prevailing uncertain situation, we would like to remind you about the security filing requirements in a Short Sea environment, if the UK leaves the EU without a “Brexit” deal on October 31, 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 to be submitted earlier than as per current practice.

The current position suggests a “No Deal” Brexit could potentially occur on October 31, 2019 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 Thursday October 31, 2019:

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

We can confirm that at this stage cargo would still continue to be shipped without Shipping Instructions and subsequent ENS filing on these additional services which currently are not affected by the 24 Hour Rule. 

However, due to the uncertain position and inability to predict how the relevant EU customs authorities will proceed in the event of a “No-Deal” situation, we need to advise you that any customs fines, additional costs incurred due to missing ENS filing as a result of non-provision of shipping instructions will be for the account of the cargo.

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

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