Further to the various meetings that Stephen Denning has been attending on our behalf with reference to the changes from Authorised Depositories to ETSF’s, we need to ask Members if there are any requirements for an ETSF that they believe they will have to comply with that they didn’t as a Depository? To try to establish this, Stephen
has processed an application for ETSF and reports that it is straightforward with respect to most aspects of the requirements because they refer to the premises and its security, integrity, facilities etc which seems to be the same as has been required for an approved depository.
The significant changes are that there needs to be inventory linked to a port, i.e. there must be an electronic interface with the port via one of the Community Service Providers, CNS or Destin8 and that the mover also has to have a “Badge” for one of the ports supplied by them. There are two port systems that cover the main ports that are most commonly used, and neither provider covers all the ports. However, an agent known to Stephen has said that apparently DESTIN8 charge £1,000.00 for the badge, and that it can be used for arrivals at ports that are on either system. We are unsure as to just how accurate this is and are still trying to get absolute confirmation on that point.
So, the mover has to have this inventory linking, which is an added inconvenience and cost, and also the mover must have a Comprehensive Customs Guarantee, which will need to be separately applied for. This will inevitably mean that there will be a cost for a bond of a given value, depending upon the duty liability that the Member will have. In all likelihood, we do not believe that this will be overly expensive for most companies because of the notional value of HHG, the small numbers of shipments normally stored and consequently the low liability.
So from what we know currently, these seem to be the major stumbling blocks and added burdens, both of which have cost attached to them. In summary therefore, we believe that any applicants for ETSF will find that it is the inventory linking and Customs Guarantee that will generate additional cost and administrational requirement.
If anyone has a different view on these changes to the requirement, it would be greatly appreciated if you would share those thoughts with us.