Mr. Gerry Harrahill:

On the first issue, anybody trading with the UK or conducting international trade with a third country will need a new EORI number. It is a basic application. It is done online and is quite straightforward. Part of the engagement we have had with trade and business is to outline the overall framework within which customs operates and some of the ways in which businesses can simplify and make things easier. However, they must do an assessment to ensure the strategy they will pursue is right for their businesses. For some, getting authorised economic operator, AEO, status, and I will return to that shortly, is absolutely right for the business. For other businesses, to be brutally honest, it would be a poor investment of time, money and expertise because the potential payback could be extraordinarily limited.

I will give a simple example. If one is involved in moving foodstuffs, due to the regime we referred to earlier regarding safety and SPS checks, having AEO status does not give one any standing when it comes to the potential for SPS checks. That is the reason we have been clear in saying, during engagement with businesses, that there are simplifications and authorisations they can get but that they must make sure they are right for their businesses. Part of what we ask them to do, and it is part of the process, is to carry out a self-assessment evaluation. Sometimes they recognise that they cannot fulfil the criteria so it is clear. For example, a significant investment is required in technology, security, training and record-keeping, and it is an ongoing investment on which we must provide some oversight. It is a Europe-wide system so when one gets AEO status it is recognised across the EU. It is not a case of us being able to say we can dispense with the criteria. The system must be robust.

That said, Mr. Cody mentioned earlier that we are an integrated tax and customs administration. There is a huge benefit we can leverage out of that, which is that it is not like somebody coming to us for the first time. If, for example, the business is already currently trading with the UK and is tax compliant, it is already on our system so we know quite an amount about it. One of the things we take account of and have regard to is its compliance record, so there are clearly advantages. We have provided on our website clear indications as to what the different simplifications are and what, broadly, the type of business is. If people go through that and then wish to talk to us about it, we are more than happy to engage with them and to suggest that this might not be where they need to go and ask them if they have thought about other things. Ultimately, it is a matter for the business to make its own decision, but AEO is useful for the right business.