Mr. Eoin Gavin:

I thank the Chairman and the committee for giving me this opportunity to make a presentation in my capacity as vice president of Shannon Chamber of Commerce, representing our more than 300 member companies in the mid-west region, and in my capacity as an international road haulier. I am the owner of Eoin Gavin Transport, which operates across the 26 EU countries and into the Eastern bloc for the past 25 years. I am delighted to get this opportunity to further expand on the contents of letters submitted by Shannon Chamber to Ministers and to our local elected representatives on 11 January in which we outlined issues being experienced in the movement of goods to and from the United Kingdom from businesses in the mid-west region.

Hauliers and freight forwarders, exporters and importers, expected that Brexit would result in some teething problems, as with any major change in our economy. We accept that some exporters and importers must take some of the blame for the current delays being experienced by hauliers in transporting goods from Ireland to the United Kingdom and from the United Kingdom back to Ireland. Some of the systems in place for trading also have procedural flaws, which need to be addressed.

We understand the requirement to complete an import and export declaration when trading with a third country and that a three-step process is now required on import for hauliers trading with the UK. First, they must prepare a customs declaration and get a movement reference number, MRN, or pre-clearance to ship. They then need to complete an entry summary declaration, which is a safety and security declaration and which duplicates most of the customs entry detail in the previous declaration. Third, they need to prepare a pre-boarding notification. PBN, which is permission to board a ship with the load. This must incorporate all the MRNs. Here lies the problem. As these three layers are being completed, Revenue's systems try to tally and match them up in the background but this does not seem to be working. In many cases this is resulting in one stage wiping out the other stage. Also, the more entries one has to make the more likely there will be human error.

Why are the customs declarations and the security declarations not being combined for imports from the UK as is currently happening with Irish export declarations and as happens for exports from the UK to mainland Europe, which are also combined into one declaration?

I also question why the obligations under steps two and three have shifted to the operator and the haulier, and not to the carrier, which is the vessel and the ship, which is the requirement under the UCC that was brought in after 9/11.

There are other reasons for delays. These relate to drivers getting notifications of the status of their goods - green, orange or red - before disembarkation from ferries at Irish ports. The only way they can check this is by logging on to the Revenue website on their phones, or with a transport office doing it for them, and trying to create a routing. There is an immediate need for routing status display screens on ferries to expedite the disembarkation process at our ports.

I will provide the committee with a practical example. A truck going from London to Pariswith a load requires an export declaration. This creates an MRN and a barcode. The driver arrives at ferry in Dover and presents his papers with the MRN in order to check in. The ferry company uploads the details and he can board. On the ferry, the driver checks the display screen in the restaurant area to see which lane - green or orange - he needs to follow on disembarkation at Calais. That is the process for exporting a load from London to Paris.

The same load going from London to Dublinrequires an export declaration. This creates an MRN number and a barcode. The driver’s transport office needs to create a separate entry security declaration which has the same details as the export declaration. This creates another MRN number and barcode. The driver’s transport office then needs to enter both MRN numbers on the Revenue website to get a PBN. The office then needs to upload this to the ferry company's website in order to confirm the booking. The driver can then drive to the port to check in on the ferry. Thirty minutes out from Dublin Port, the driver’s transport office needs to enter the PBN number on the Revenue website to check which lane the driver needs to follow on disembarkation from the ferry at Dublin Port. Members will agree that there is quite a contrast.

I am here today to request that these issues be followed up on and prioritised by Revenue as a matter of urgency because they are having a significant impact on the economy. They will result in trade being stifled and in our export-led economy slowing down. This matter requires urgent attention. The solution must be executed as a priority. We would ask that a timeline for action be provided as a matter of urgency.