Home Office delivery of Brexit: customs operations Contents

4Infrastructure and capacity challenges

43.This chapter looks at the practical issues that need to be addressed in the event of changes to customs arrangements being required, whether as a result of the transition period, a long-term trade and customs deal, or no deal being in place.

44.When our predecessors took oral evidence on post-Brexit customs arrangements in January 2017, the witnesses representing hauliers, logistics companies and ports described the potential practical problems which were likely to occur if the customs requirements which currently apply to non-EU goods were applied to EU goods after Brexit.46 They were particularly concerned about the impact of delays caused by additional customs checks, especially in relation to supply chains and where perishable goods were involved.

Costs

45.The IfG report states that the introduction of customs declarations on EU trade could cost traders between £4 billion and £9 billion a year, based on an estimate of £20–£45 per declaration and an expected 200 million additional declarations after Brexit. The extra costs go far beyond this because traders are also charged for checks on goods: the cost for a physical examination by port health authorities ranges from £106 to £600 per container, depending on the test requirements. Some goods have to be transported to a specific location to be tested, which adds a further £30 for every two containers.47 Mark Corby has estimated that the additional cost is likely to be between £19 and £26 billion a year as a result of losing the customs and trade facilitation and duty benefits which EU membership offers.48

46.Jon Thompson, the Chief Executive of HMRC, told the Public Accounts Committee in October that the estimated cost to HMRC would be between £300 million and £450 million in the “most extreme” scenario of the UK leaving the EU “with no ongoing special relationship”, and between 3,000 and 5,000 additional staff would need to be recruited.49

Complexity

47.As we have noted, delivery of customs policy is a cross-government process, involving a wide range of public agencies as well as a number of Government Departments. Customs operations also impact on and require the cooperation of a vast array of private companies. In addition to the businesses buying and selling goods, the IfG report lists freight forwarders, hauliers, customs handlers, customs clearance agents, community system providers, port operators and ferry companies as some of the key players.50 The Home Office Permanent Secretary explained the multi-faceted nature of customs in the following terms:

My experience of any work at the border is that questions [on future arrangements] need to be addressed through a partnership, so typically it is a private sector party, the port or airport operator, who has control over the physical infrastructure. You need to see a partnership between the different agencies in Government, of whom HMRC and Border Force are two—there are others. DEFRA, for example, has an interest in movement of animals, food and bio products, and you need to see a partnership between the Government and the port operators.51

Capacity at and around ports

48.A number of key stakeholders have pointed to the challenges the UK may face if post-Brexit arrangements require more checks on goods and vehicles to be carried out at UK border entry points. At some ports, including Dover, as much as 99% of traffic relates to trade with the EU; witnesses told our predecessors that a no deal scenario might therefore result in effectively 100% of trade becoming “non-EU”, leading to a hundredfold increase in the number of customs declarations.52 This would be an unprecedented delivery challenge to UK border operations. The IfG report states that the resulting increased requirement to make declarations would inevitably result in more checks being carried out on vehicles trading between the UK and the EU, with the accompanying risk that this will lead to long delays at points of entry.53 As noted above, these checks can cause delays of up to five hours.

49.James Hookham of the FTA told our predecessors that “we should absolutely and categorically try to avoid physical checks on vehicles at ports” because they “simply don’t have the physical space” and “that is where the pressures are”; this was particularly a problem for Dover. Similar issues also applied to airports.54

50.Infrastructure improvements will be required at ports to deal with the potential increase in the number of vehicles carrying EU goods, which will need to be parked at ports to await clearance, rather than “driving straight through” as is currently the case. In addition to increased parking capacity and more specialist border inspection posts for animals and animal products, improvements to road and rails links in the vicinity of ports are likely to be needed. One of the main constraints on expansion at some ports, including Dover, is that their geographical location prevents this—the position of the port at Dover between the cliffs and the sea-front does not allow for an increase in size. Even at present, clearance for lorries arriving via Dover or the Channel Tunnel which do require customs checks takes place six miles away at a lorry park off the M20 that currently has 82 spaces.55

Impact of delays in ports across the Channel

51.If new customs checks are required, additional systems and infrastructure will also be needed at the Channel ports in France and Belgium (and in Ireland—see separate section below) where the UK Government has no control over the timetable for change and new investment. The FTA stated in evidence that whatever “frictionless arrangements” the UK put in place would need to be “reciprocated [ … ] by the EU in Ireland, France and Belgium” to avoid long delays.56

52.An example of the potential consequences of delay across the Channel was demonstrated in July 2015 when a strike by French ferry operators resulted in huge delays and traffic jams in Kent and the activation of ‘Operation Stack’ to try to mitigate the worst impacts. Operation Stack is a way of managing traffic during disruption to Eurotunnel or ferry services in Kent; when activated it enables lorries waiting to use Channel services to queue on the M20 and all other traffic is diverted to other routes.57 The IfG report notes that the requirement to implement Operation Stack in 2015 resulted in businesses losing £21 million in stock and the economy in Kent losing £1.5 million a day. It also points out that, although Kent County Council has plans to construct a lorry park on the M20 as an enhancement to the facilities available under Operation Stack, building will take nine months to complete once it begins and construction is currently on hold after a judicial review.58 In the event of significant changes to the UK’s customs arrangements, an operation on a larger scale than Operation Stack would bring huge challenges for the UK Government, UK businesses, Kent Police and the people of Kent.

53.If parallel preparations and investments are not in place in ports across the EU the associated costs and delays will increase substantially after March 2019, in the event of no deal. Andrew Baxter suggested in oral evidence that the key question was what customs “are doing at the local level in countries all over Europe”, with the consequence that “a significant proportion of our exports will get delayed if customs clearance is introduced.59 Jack Semple of the Road Haulage Association (RHA) indicated that there were specific challenges in Belgium and Northern France, where trade with the UK accounts for a large proportion of customs processes.60 The IfG report pointed to the particular potential challenge for ports such as Dublin and Holyhead to expand their customs capacity at short notice.61

54.Another potentially increased risk arising from delays in French and Belgian ports is that of illegal immigration. The French ferry operators strike in 2015 exacerbated the existing problem of people illegally boarding lorries waiting to cross to the UK, with migrants attempting on a number of occasions to block port approach roads and to enter the Channel Tunnel. Our predecessors took evidence in 2015 from the Mayor of Calais, Kent Police, Eurotunnel and haulage companies about the serious problems this was causing on both sides of the Channel, including loss of life of migrants, during that period. Their 2016 report on the Migration Crisis summarised their concerns and the steps being taken by the UK and French Governments to address these issues.62

55.The IfG report notes that an expansion programme has been underway at Dunkirk since 2014, which includes expanding customs and border inspection capacity. Capacity for checks increased from 1,000 to 5,000 consignments per year but this work took 11 months and cost €2 million. In addition, a new car terminal opened in March 2016 which took a year to build at a cost of €14.9 million. The Port of Calais began an expansion programme in 2015 (after a five year development period). It is estimated that this will cost €862.5 million, with works not due to be completed until mid-2021. The IfG report points out that the Port of Dover is “functionally very similar” to Dunkirk and Calais, and so the challenges, costs and timescales faced by those ports in seeking to increase capacity are likely to be mirrored at Dover.63

Potential impact of delays on supply chains

56.The witnesses who gave evidence in January were particularly concerned about the impact of delays and blockages at ports on time-sensitive and perishable goods, and on carefully constructed supply chains. James Hookham of the FTA noted that the economy was based on current assumptions about transit and dwell times for goods and that there would be a “shock to the system” if different customs processes were implemented at short notice. That shock needed to be avoided because it risked bringing “supply chains to a halt” which would result in “serious disruption of the economy”. He said that that is clearly “not what the public expect to happen, as well as costing a lot of money and inconvenience”.64

57.Andrew Baxter emphasised that “having a secure supply chain is massively important to our customers, as is knowing that goods that are supposed to get to them in 48 hours actually do”. Graeme Charnock of Peel Ports Group said that manufacturers who operate a “just in time” delivery process would probably have to carry additional stock to prevent running out, which would be likely to increase costs. James Hookham of the FTA was clear that perishable and time-sensitive goods “simply cannot tolerate” interventions that would lead to delays at ports. At container ports, where containers selected for inspection can be delayed for between two and four days, the need to carry out such checks on EU imports would pose a significant additional burden.65

58.“Agri-food” products provide a good example. The IfG report points out that UK rules on meat imports from non-EU countries currently result in 20–50% of shipments being checked by food health agencies at the border. Agri-food products cannot generally be taken to inland inspection posts because of the risk of disease, so they have to be checked at ports. Currently, 70% by value of the UK’s food imports come from the EU and are not subject to any checks. In addition, EU trade agreements with third countries can significantly reduce the inspection requirements; for example, the EU-New Zealand trade agreement reduces this to only 2% of shipments being randomly sampled. The UK could decide to continue these arrangements on a bilateral basis in the event of no deal; however, EU rules would require UK exports to be treated in the same way as those from any other third country with which the EU does not have an agreement.66 This would potentially result in serious delays for UK meat and agricultural products at the French and Belgian borders.

59.Decisions are needed as a matter of urgency on improvements to port and transport infrastructure that may be needed as a result of Brexit. The Government should significantly increase its coordination with the privately-owned ports sector to ensure that the necessary preparations for any changes required during the transition period begin immediately. Such preparations must also include anticipating any changes affecting border regimes in EU Member States, particularly France and Belgium.

60.Any new arrangements put in place at UK ports will need to be replicated at the Channel ports in France and Belgium. The French ferry operator strikes in 2015 clearly demonstrated how quickly delays and backlogs can build up when the flow of traffic is interrupted at ports, and the dire knock-on effects this can have in the UK, particularly in Kent on the approach roads to Dover.

The Northern Ireland border

61.The IfG report emphasises that the Northern Ireland border constitutes one of the UK’s major trade routes with the EU, with 200 crossing points and a “continuous daily flow of lorries” which at present encounter no customs controls, and RoRo ferries carrying significant amounts of goods between Dublin and Holyhead.67

62.In August, the Government published a paper which “outlines the UK’s position on addressing the unique circumstances of Northern Ireland and the land border with Ireland”, including the way the customs union issue affects the island of Ireland.68

63.The Brexit Secretary told the Committee on Exiting the EU last month that “one of my aims in this is to try to get an outcome that does not do harm to Ireland”. He confirmed that it remained the Government’s intention to ensure that there is no physical border and no infrastructure at the border. He also pointed out that Ireland is the EU country most dependent on the UK for trade with a value of “about a €1 billion a week” in both directions, and through the UK to the continent.69

64.Witnesses giving evidence in January were clear that the Northern Ireland border presents particular challenges for post-Brexit customs arrangements. Jack Semple of the RHA said that the companies he represented struggled to see how the proposed models for post-Brexit customs arrangements could work on the island of Ireland and that “we cannot see [ … ] an easy solution”. His view was that the problem was exacerbated because “the economic integration of trade” between Northern Ireland and the Republic “is at a far more advanced level than it is between the UK and continental Europe”.70

65.This inquiry has not taken separate evidence on options and arrangements for Northern Ireland. However, it is clear that the impact on border and customs operations at the Northern Ireland border with the Republic of Ireland will be severe in the absence of specific solutions to the very complex Brexit issues affecting the island of Ireland. Decisions on the way forward are needed as a matter of urgency including on infrastructure improvements, systems and capacity.

Possible mitigations and solutions

66.Andrew Baxter suggested in evidence to our predecessors that the use of “approved warehouses” could help to provide a solution. These currently allow clearance checks to be carried out away from borders and points of entry and therefore help avoid bottle-necks and delays at ports. The option for businesses to apply for authorisation to operate these facilities is open to “modestly sized organisations” as well as big operators, as long as they meet the required standards. Specifically in relation to the Northern Ireland border, Andrew Baxter suggested that it would be possible for a company based in Belfast to carry out its trade with the Republic via Dublin by doing all the necessary clearance using authorised warehouses, rather than actually at the border.71

67.As referred to above, the Government’s recent White Paper suggested that the use of the “trusted trader” Authorised Economic Operator (AEO) system could be expanded to reduce the need for documentary requirements at the border, as a mitigation of the impact on ports. James Hookham of the FTA advocated greater use of this system as having the potential to “lighten the load considerably”.72 The Brexit Secretary confirmed that use of AEOs was certainly being considered in relation to solutions in Northern Ireland.73 However, the IfG report pointed out that the current EU process to accredit AEOs can take up to six months for businesses to complete. The 180,000 traders who will potentially be required to make customs declarations for the first time would need to be able to apply; and early guidance for traders would therefore be needed on the application process and using the AEO system for EU imports.74 No such guidance is yet available and there is no sign that the Government has made the decisions needed for this system to work.

68.Andrew Baxter noted that the customs office in Tilbury closed daily at 4pm, and therefore only goods arriving before 3pm can be distributed the following day. If such arrangements were preserved, he believed this would result in “a very substantial proportion of goods having an extra day’s transit time”, with the associated costs and burdens on storage facilities.75 More flexible and timely customs and border operations would therefore be of considerable benefit to future procedures at the border.

69.The Government’s plans for expanding the use of the “trusted trader” Approved Economic Operator and approved warehouses schemes seem sensible and are welcome. They could also help address some of the specific challenges at the Northern Ireland border. However, the Government needs do much more immediately to inform traders about what this might mean for them in practice and to develop the registration and accreditation processes so that businesses can start the process now. The Government should also ensure that it has the capacity in place to register a high volume of traders in a short period of time.

IT systems

70.The IfG report notes that “information sharing is the key enabler of modern customs”. The UK is currently able to access over 20 EU systems, which provide a variety of functions, including tracking goods and vehicles, and storing details about goods and suppliers. EU systems are supplemented by member states’ internal IT systems.76 In the UK, HMRC is replacing the current customs system used to administer customs declarations (known as CHIEF) with a new Customs Declaration Service (CDS). The CDS programme began before the EU Referendum took place and therefore before the Government was aware that it would need to put new customs arrangements in place from March 2019.

71.CHIEF is designed to process about 60 million customs declarations a year; the pre-Referendum planning for CDS had a capacity aim of 150 million declarations. However, HMRC itself has estimated that Brexit will result in an additional 200 million declarations, meaning that the new system will need to be capable of handling at least another million declarations a year beyond the planned capacity.77

72.The NAO published a report on the progress of the Customs Declaration Service programme in July 2017.78 It points out that the planned completion date for the programme is only two months before the March 2019 EU exit date and that government IT projects routinely overrun. It emphasised that there is still a significant amount of work to complete, and concluded that there is a risk that HMRC will not have the full functionality and scope of the CDS in place by March 2019.

73.It also points to the uncertainty for the programme which arises from “the unknown outcome of the UK/EU negotiations”, which had resulted in no changes yet being made to the scope of the CDS programme to reflect the UK’s decision to leave the EU. The NAO concluded that any future changes which need to be made to accommodate the outcome of negotiations with the EU “would increase the risk of additional cost or delay to the programme”.

74.When the report was published, the head of the NAO (the Comptroller & Auditor General), Sir Amyas Morse, was reported as saying that the new system threatened to become “a horror show” and that it may not be flexible enough to cope with new rules after Brexit. He was quoted as going on to say:

What’s unique about these circumstances is there can’t be a drift in timescale. Normally if you have this project and it took another six months to be a working project you’d say this is a pretty successful project. But this is not like that.79

75.The Public Accounts Committee took oral evidence from the Chief Executive of HMRC, Jon Thompson, on 25 October during which the risks to the delivery of the CDS were explored. He acknowledged that it would be “catastrophic” if the system was not operational on Brexit day. Mr Thompson confirmed that the programme was currently meeting its milestones, and he stated that he was “reasonably confident” that it would be delivered by January 2019. However, he was clear that there were four major risks, which he identified as:

76.Updated IT systems will be fundamental to the effectiveness of any new customs arrangements. By far the most important of these is the HMRC Customs Declaration Service (CDS) which is due to be in place by January 2019, to replace the existing CHIEF system. It is deeply worrying that any slight slippage in the CDS programme risks it not being available by the time the UK leaves the EU at the end of March 2019. The Chief Executive of HMRC has acknowledged that it would be “catastrophic” if the new system is not operational on Brexit day. We endorse the NAO’s recommendations on the actions the Government needs to take to ensure this scenario is avoided. We expect the Government to prioritise contingency planning for the eventuality that the CDS system is delayed or lacks full functionality. We also look forward to the further recommendations which our colleagues on the Public Accounts Committee plan to make on this issue, following their recent hearing with HMRC officials.

Home Office capacity

Staffing

77.The Home Office Permanent Secretary, Philip Rutnam, was not able to tell us how many of the current total of approximately 7,600 Border Force staff work specifically on customs operations. He explained that this was in part because: “the way that the Border Force operates is essentially increasingly multi-skilled. You will have somebody who may be capable of doing customs work or immigration work”.81

78.Mr Rutnam was able to tell us that he was recruiting 300 additional Border Force officers who would be in place by September 2018 and trained by March 2019, “to ensure that we can deal with the consequences of leaving the European Union with a deal or without a deal”. This would amount to an increase of approximately 4% in Home Office staff working at the border. Contingency planning would be kept under review, including the total number of additional staff who might eventually be required to deliver the agreed arrangements or a no deal outcome.82

79.However, in a 2013 report, the NAO noted that Border Force has previously struggled to forecast its overall staffing needs accurately which resulted in “substantial reductions in staffing in one year being followed by very significant increases in the years immediately following”. Border Force had subsequently developed a detailed model for forecasting resources through to 2016, but had itself identified limitations in this model, including failing to take account of changes in aircraft and port capacity and future port openings or closures. This meant that Border Force did not regard the model as sufficiently accurate to inform operational planning.83

Operational challenges

80.The NAO points to the challenges which Border Force faces in its customs operations: “Although HMRC and Border Force have a partnership agreement, it is not always straightforward for government as a whole to prioritise the various activities involved in managing a safe and effective flow of people and goods, and the collection of revenue”. The NAO also suggests that, given that Border Force is also responsible for immigration at the border, it could “struggle to deal with the training, workforce, financial and prioritisation challenges” arising from so many changes to operations arising from Brexit in a short space of time.84

81.As we have noted, physical inspections are carried out on a very low percentage of goods, due to the use of IT systems and the intelligence-led approach, which enables Border Force and HMRC to focus on the most high-risk goods and traders. However, checks and inspections are an essential part of the customs clearance process and seizures of illicit and illegal goods are a key element in preventing such items as guns, drugs and fake goods coming into the UK. If the capacity of Border Force staff is stretched by a post-Brexit requirement for an increased number of checks and inspections to be carried out on previously exempt EU traffic, there is likely to be a higher risk of illegal goods penetrating the border and in excise, customs and duties not being collected. The multi-skilled aspect to Border Force roles may also contribute to this: if staff are required to fill operational gaps related to customs, for example if there is no deal or if customs planning proves inadequate, this might leave fewer staff available to work on border security.

82.In addition, if the new border regime results in longer waiting times and holding arrangements for lorries in Calais seeking to enter the UK, this will carry a consequential risk of increased clandestine and irregular arrivals and increase the need for more checks for illegal immigration.

Queen’s Warehouses

83.The Home Office is responsible for the storage of goods which are seized or detained by Border Force, HMRC and the National Crime Agency. Queen’s Warehouses are used as secure storage locations for this material, which includes such items as excise goods (cigarettes, tobacco and alcohol), firearms and prohibited drugs. Queen’s Warehouses are geographically spread across the UK and some have responsibility for the storage of specific goods.85 Clearly, if more goods are subject to customs checks after Brexit, and there are more seizures or delays as a result, then increased capacity will be needed in these secure storage facilities.

84.The Permanent Secretary told us that the Home Office was in the process of reviewing Queen’s Warehouses, including “the stock of property that we have”.86 However, we were not given a timetable for this review work to be completed or any indication that the Home Office has plans in place to increase warehouse capacity before the end of March 2019.

85.The Home Office is not the lead department for customs but Border Force staff provide an essential function in carrying out checks of vehicles and goods at border entry points. The NAO has raised concerns that Border Force may struggle to cope with the combined demands of a greatly increased number of checks being required for both people and goods entering the UK after Brexit. These risks include fewer seizures of illicit and illegal goods at the border. The Government needs to provide reassurance that there will be a sufficient number of Border Force officials in place and that they will be properly trained in any new customs processes required for the transition period or the UK’s future partnership with the EU. Border Force may well require more locations to hold goods or conduct searches and assessments, yet the Home Office could not provide specific details about any post-Brexit planning that is under way. We request that these details are set out in response to this Report.

86.Urgent coordinated staff planning is required between HMRC and Border Force. HMRC has stated that it will need up to 5,000 additional staff in place by March 2019 as a consequence of Brexit. The Home Office has stated that an extra 300 border staff will be in place by March 2019, a 4% increase. We find these plans for such a small increase in border staff completely unconvincing, particularly given the current uncertainty and the need for contingency planning. If new customs arrangements require a substantial increase in customs capacity which cannot be delivered in time, then there is a significant risk that Border Force staff will be diverted from crucial security functions, including preventing smuggling, the seizing of dangerous goods and immigration processes. The Home Office needs to plan for a significant further increase in border staffing and to ensure that arrangements are in place to prevent large numbers of staff being diverted away from other critical areas. The Government must not allow failures in operational planning, HMRC recruitment, or the implementation of new customs arrangements to jeopardise UK border security. We will return to consider further the relationship between the immigration and customs functions which Border Force and HMRC staff carry out, and whether any changes need to be made.

Co-ordination and leadership within Government

87.The complexity of the customs landscape, in addition to the volumes of goods involved, exacerbates the difficulties in identifying and implementing a new customs system which will work in the best interests of all, or at least not damage or impede their business. The approach the Government is taking in relation to leading the process to construct post-Brexit customs policy, and to co-ordination of the multitude of interested parties, are clearly intrinsic to its success.

88.As we have noted, lead responsibility for customs within Government lies with the Treasury, which has oversight of HMRC. The Minister responsible for HMRC is the Financial Secretary to the Treasury, currently Mel Stride MP.87 The Home Office Permanent Secretary explained that, although the Treasury has primary responsibility for policy, Border Force’s operational role meant that the Home Office is “very closely tied into the work that is being led by HMRC”. He said that the department is part of a special working group where the Home Office Second Permanent Secretary and the head of HMRC “consider these issues”.88 The Home Secretary is a member of the Cabinet Committee on EU Exit and Trade.89

89.We were not satisfied with the answers we received to a vitally important question about planning for post-Brexit customs arrangements: who is in charge? The Government’s approach seems to us to lack focus, urgency and above all leadership. Any progress seems to rely on working groups of government officials, with no meaningful ministerial leadership. This is particularly worrying given that the costs involved would appear to be significantly higher than the existing Brexit contingency funding requested by the Home Office and even higher than the total envisaged by the Prime Minister for the whole Government. Moreover, the fact that multiple government departments and agencies are involved in delivering customs means that a fully joined-up approach from the Government is urgently needed, as well as proper coordination with the private sector. The impetus to achieve this is only likely to come from a named senior Government Minister taking responsibility, who can then provide regular reports to Parliament on the Government’s plans. In addition to the ongoing cooperation between the Treasury, the Home Office and other departments with a direct interest, we recommend that a Minister of State should be named as the lead Government Minister responsible for delivery of post-Brexit customs arrangements.


46 Oral evidence taken on 25 January 2017, HC 494 (2016–17)

47 Institute for Government, Implementing Brexit: customs, pp 4 and 39

48 BBC Radio 4, Today, 20 October 2017

49 Public Accounts Committee, Oral evidence taken on 25 October 2017 on Brexit and the Future of Customs, HC 401, Qs 14–18

50 Institute for Government, Implementing Brexit: customs, pp 15

51 Oral evidence taken on 17 October 2017, HC 434, Q14

52 Oral evidence taken on 25 January 2017, Q144

53 Institute for Government, Implementing Brexit: customs, p 20; Oral evidence taken on 25 January 2017, HC 494, Q144

54 Oral evidence taken on 25 January 2017, Qs 137, 187

55 Institute for Government, Implementing Brexit: customs, p 14

56 Oral evidence taken on 25 January 2017, Q137

57 Kent Police website, Operation Stack [accessed 31 October 2017]

58 Institute for Government, Implementing Brexit: customs, pp 22, 30, 40–41

59 Oral evidence taken on 25 January 2017, Q140

60 Oral evidence taken on 25 January 2017, Q137

61 Institute for Government, Implementing Brexit: customs, p 14

62 Home Affairs Committee, Seventh Report of Session 2016–17, Migration Crisis, HC 24, paras 13–16

63 Institute for Government, Implementing Brexit: customs, p 30

64 Oral evidence taken on 25 January 2017, Q187

65 Oral evidence taken on 25 January 2017, Qs 132, 137 and 143

66 Institute for Government, Implementing Brexit: customs, pp 19–22

67 Institute for Government, Implementing Brexit: customs, p 14

68 HMG, Northern Ireland and Ireland—position paper, August 2017. See also HMG announcement, 16 August 2017, Pledge to protect Belfast Agreement and Common Travel Area in new position paper.

69 Select Committee on Exiting the EU, Oral evidence taken on The Progress of the UK’s negotiations on EU withdrawal, 25 October 2017, HC 372, Qs 105, 147–148

70 Oral evidence taken on 25 January 2017, Qs 155 and 178

71 Oral evidence taken on 25 January 2017, Qs 179–180

72 Oral evidence taken on 25 January 2017, HC 494, Q153

73 Select Committee on Exiting the EU, Oral evidence taken on The Progress of the UK’s negotiations on EU withdrawal, 25 October 2017, HC 372, Q148

74 Institute for Government, Implementing Brexit: customs, pp 32 and 38

75 Oral evidence taken on 25 January 2017, Qs 137, 150 and 156–167

76 Institute for Government, Implementing Brexit: customs, p 19

77 Institute for Government, Implementing Brexit: customs, p 26

79 The Independent, 13 July 2017, Brexit: Government’s new customs IT system heading for £34bn ‘horror show’, watchdog warns

80 Public Accounts Committee, Oral evidence taken on Brexit and the Future of Customs, 25 October 2017, HC 401, Qs 38, 46, 48, 54

81 Oral evidence taken on 17 October 2017, HC 434, Q125

82 Oral evidence taken on 17 October 2017, HC 434, Q125

83 NAO, The UK border, p 23; and NAO, The Border Force: securing the border, September 2013, HC 540 (Session 2013–14)

84 NAO, The UK border, pp 11, 18 and 30

85 Independent Chief Inspector of Borders and Immigration, An inspection of how Border Force deals with seized drugs, tobacco, alcohol and other materials, June 2014, paras 1.1–1.2. These storage locations are known as Queen’s Warehouses because when goods are seized they become ‘forfeit to the Crown’.

86 Oral evidence taken on 17 October 2017, HC 434, Q18

87 Gov.uk website [accessed 26 October 2017]

88 Oral evidence taken on 17 October 2017, HC 434, Q14

89 Institute of Government blog, 27 July 2017




13 November 2017