What about the Brexit?
The UK & the EU had agreed a Brexit extension "only as long as necessary" and "no longer than 31 October" to allow for the ratification of the withdrawal agreement. Therefor all parties has more time to be prepared for exporting RDF to abroad.
TFS applications
For the Netherlands the Dutch authority has announced that the change in the UK’s status from a member state to a third country will not result in the requirement for a new notification for those shipments where consents have been granted already.
Import tariffs
The Dutch customs declared the value of the product “imported waste” will be negative. Therefore the import tax for waste treatment is being set at 6,5% * € 0 = € 0.
Unfortunately, the Dutch customs defines the import of waste as a product instead as a service. This means there will be an import tax charged for the transportation component of the waste shipment from the RDF transfer location to the Dutch border.
It is still uncertain how the customs and tariff process would work if material entered the EU at a destination outside the Netherlands with the end destination being a Dutch EfW facility. At the moment we are interested and following the developments on how the different customs will act regarding this approach to applying tariffs. Some might consider RDF import as a service leading to zero tariffs, some might consider it as a product with a negative value like the Dutch customs does (leading to a tariff on the transport component only).
Customs procedures
In a No-deal Brexit scenario it is anticipated that Customs will have to check a certain percentage of all shipments. This will likely lead to delays and possibly traffic jams. The British government is anticipating traffic jams and is therefore considering to point out specific parking places such as the closed airport Manston (20 miles from Dover) where 6.000 trucks can be parked.
For Customs also a lot of paperwork is required for clearance. Normally the paperwork for clearance and import tariffs is applied per shipment, but this can be simplified to monthly declarations when agreed by Customs. We advise to consult your shipping agent on their preparations on this additional paperwork and how to implement monthly declarations.