Brexit’s final nail in the coffin (1)

On April 30 the government will roll out the second phase of its Border Target Operating Model (BTOM). The result is likely to be total chaos on a number of counts. 

There is growing unease about the wall of silence surrounding  the computer system at the heart of the BTOM, called the Single Trade Window (STW). This will be the one and only way of getting data into the system. The final version*^⁠1 of the BTOM guide, published on February 11 states: “ …the Single Trade Window could be fully operational in 2027.” 

There are a number of reasons why this could be awkward, but one will do. The STW calculates the aggregate cost of wear and tear caused by lorry traffic to roadways at ports. This operational detail is  used to set a levy called the Common User Charge (CUC). This is payable to HMRC within four weeks. While the STW sets a figure for Government operated ports, private operators were invited to fix their own charges, as they would do for anything else. There appear to be a number of sticking points.  Dover and Portsmouth,  the two busiest ports in the UK, both happen to be owned and operated privately.

The Common User Charge scheme comes from the European Directive 1999/62/EC, which was passed by the European Parliament and voted by the Council of 17 June 1999.  The EU framed it as a way of charging heavy goods vehicles for the use of infrastructure such as national road networks. It is no more than a rehashed EU pipe dream.

The scheme was never developed into a fully operational model in Europe. However, faced with the challenge of organising a system of robust controls on EU imports, the UK government saved a lot of  time and effort by reviving the Common User Charge. Stakeholders believed that new processes would cost a lot of money, so the UK government took them at their word and came up with a scheme to absorb their cash. Whitehall covered its back by saying that future costs would reflect how businesses are adapting their working practices and supply chains to the new rules.

The architects of the project assume that a budget of £330 million a year would cover roadway wear and tear arising from EU imports. On the basis of that figure, civil servants argue that the new system represents a  cost of 0.13% of all EU imports, then valued at £259 billion pounds. The value of such arguments cannot be guaranteed, but it is definitely an advantage to have two numbers, one of them large and impressive. However, these assumptions were never put to the test.

On Wednesday April 5, DEFRA unveiled a radical restructuring for the Common User Charge. Officials expect the CUC to be set between £20 and £43 per consignment: there are often multiple consignments in a load. The Government predicts that the new system will generate a 0.2% rise in the cost of food over three years.

¹ Feb-11-24-Final_Border_Target_Operating_Model.pdf para 350 page 88