An internal report by the Revenue Commissioners had been leaked to RTÉ news and outlines the huge financial and economic impacts Brexit will have on Ireland’s current customs infrastructure.
The report was seen by RTÉ News over the weekend and also lists the potential impacts for the many companies who continue to trade within the UK. The report states there will be a huge increase in human resources needed, paperwork and space requirements at Ireland’s ports and airports.
The report also states that having an open border between the Republic and Northern Ireland would be impossible with regards customs. This leaves over 90,000 Irish companies, trading within the UK, in serious danger. It will mean their custom declarations post Brexit will be increased by almost 800%
This would of course mean extra investment would be needed, special permits, an increase in paperwork and delays. Ports and airports across the country would require extensive investment, to ensure they are equipped to deal with new customs rules. Even smaller regional airports would need increased investment, as they will need customs infrastructure of their own.
This would also mean more staff would be needed for Revenue and An Post, to help them manage custom checks on incoming packages. The report estimates that over 13,000 commercial vehicles travel cross border everyday.
The open border proposal has been more than dismissed by the report, with it saying it is impossible.
"Once negotiations are completed ... the UK will become a third country for customs purposes and the associated formalities will become unavoidable...While this will affect all member states, the effect will be more profound on Ireland as the only EU country to have a land border with the UK.", the report states.
The report does state that an arrangement similar to CETA and those seen in Norway and Switzerland, could be an option in the future. It does though admit that this would be very difficult.
"At some point a similar arrangement between the EU and UK is conceivable," the report says. However, negotiating and implementing a similar deal in the Article 50 timetable [ie, the two year divorce talks] would be "extremely challenging", it says.
The report also states that if negotiations with the UK fail, then any trade between it and the EU would have to be carried out under World Trade Organisation rules.
"all UK goods entering the EU would be subject to a default range of tariffs ... It has to be assumed that broadly similar tariffs would apply to EU goods entering the UK.", it continues.
"As all of these goods will be subject to the Customs Import Procedure in the post-Brexit era, the administrative and fiscal burden on the traders involved cannot be underestimated,", it says.
Goods imported from the UK will also require an ENS. This will contain information on the company sending any goods, information on the company receiving it as well as the carrier. It will also list all transport document references, information on the unloading and loading of any goods and finally a description of the goods.
All goods imported in will then require immediate presentation to the customs office/temporary storage. This will be then processed and the goods held until all formalities have been completed by customs.
"Presentation in a land frontier scenario [ie, the border] is likely to require both a form of electronic notification as well as physical arrival of goods at a designated customs station…In order to end Temporary Storage the goods must be placed under a customs procedure or re-exported."
There will be a 90 day limit on goods remaining in temporary storage. If still there after 90 days they will incur a customs debt.
The report also lists the National Ploughing Championships as one to take a hit in future. This is due to the large volume of machinery and equipment imported from the UK and NI prior to the ploughing. All of these goods could require declaration under the Temporary Importation Procedure. They would also require guarantees of ATA carnets required for the duration of the importation period.
"In addition to the routine processing of the associated declarations, EU customs procedures would require a significant level of checking to ensure the re-export of these goods at the conclusion of the Temporary Importation period.", the report stated.
The report also lists the construction industry as one to be affected, highlighting the frequent movement of construction equipment and tools.
"Given that these temporary movements would now be across the border of the EU customs territory, controls would be unavoidable," the report also states.
Exporters and shipping:
The report also predicts future difficulties for Irish exporters, saying the burden on traders “will be significant”.
“This extra layer of formalities for movements that are currently intra-union movements will not only place a considerable administrative burden on traders, it will also have a negative impact on trade flows and delay the release of goods," it says.
The report says any duties that will be imposed on UK goods in future, will be calculated as a percentage of the value of said goods. This rate will depend on the goods type and will be set by the EU. They will depend on the type of trade agreement agreed between the UK and EU.
Also highlighted in the report, is further difficulties in shipping goods. They say any shipping between the UK and Ireland will lead to extra compliance costs for operators, while paperwork will also increase significantly.
"The actual scale of the increased activity is unknowable," the report states.
"A far greater number of small consignments, each requiring an individual customs transaction, may be involved in our UK imports than would be the case with current third country supply chains," the report adds.
"While some form of common travel area may exist post-Brexit, a completely open border is not possible from a customs perspective….It is probably somewhat naive to believe that a new and entirely unique arrangement can be negotiated and applied to the EI/UK land frontier.", it continues.
"The staffing and infrastructure costs..., along with the physical infrastructure required to facilitate efficient processing at these sites, will make this a significant project.", the report concludes.