Recommendation 6

Government’s arrangements for goods arriving from the EU is untested and could be exploited, increasing regulatory and fiscal risks. Governments operate import controls for several reasons including: to ensure goods meet relevant standards; to prevent smuggling and illicit activity; and to comply with international obligations. Defra is introducing pre-notification in advance of physical checks and may take a pragmatic approach as people learn the system. HMRC accepted that the sooner import controls are implemented, the better its ability will be to manage fiscal risks and was confident that controls can now be stepped up without disrupting flow. We are less confident, however, and share concerns that many companies are still not fully aware of all the new requirements, for example around rules of origin, and it will take time for them to get up to speed. We also note the potential risks caused by delays putting in place the necessary permanent infrastructure: for example, until the Dover White Cliffs site becomes operational in 2023 trucks arriving in Dover that are carrying goods selected for physical checks will have to travel 60 miles to Ebbsfleet. The further the inland sites are from the ports, the greater the risk that goods could be offloaded on the way. HMRC agreed it would be ideal to have the infrastructure at the port itself and goods controlled at the port but said that it was not possible. It told us it was looking at what surveillance it would need to manage those risks. Recommendation: Alongside its Treasury Minute response, Government should provide the committee with its assessment of the fiscal and regulatory risks for imports from EU-GB and set out how it will minimise any potential gaps in the temporary arrangements it intends to operate until all its planned permanent infrastructure is in place.