Experts voiced their concerns at the Future Relationship with The European Union Committee meeting on 9 September.
Richard Burnett, chief executive of the Road Haulage Association, stressed again that UK customs agents would handle 200 million extra declarations for EU goods after the transition period expires on 1 January.
A substantial increase in personnel would be required to handle that additional work, but Burnett said: "We are a long way off being able to recruit those customs agents. The other thing is it takes a significant amount of time to train and prepare these individuals.
'We've got 81 working days'
"It can take 6-12 months to familiarise yourself, but probably three years to really understand how the process works end-to-end and we’ve got 81 working days between now and the end of the year to be able to recruit the number of agents that are required."
In addition, he claimed there was insufficient funding available to recruit the necessary agents. "If there are insufficient customs agents to process paperwork – you can’t go to a point of exit if you haven’t got the correct paperwork – that means businesses are going to stop trading.
"Businesses might say, ‘we’ll try’ and hauliers end up putting product on without the appropriate paperwork ... in which case what we are going to see is chaos in [Dover] Kent."
Customs and trade consultant Dr Anna Jerzewska said: "It’s years to train [to handle] even something as simple as a commodity code." She also expressed fears about the amount of IT systems that had to be ready for 1 January 2021 to handle the increased bureacracy that would kick in.
Jerzewska later said smaller firms in particular would also struggle to recruit experts and consultants who could help them with customs-related queries. "The problem is the lack of these people – we never had enough customs people in the UK even before the referendum. For smaller companies the issue is the investment required. For larger companies, they have funds to make this investment."
Burnett said staff and bureaucratic requirements were needed regardless of whether or not the UK forged a deal with the EU, because the UK would have to reintroduce the trading infrastructure it had prior to joining the EU.
"You can’t expect 50,000 people to be employed and then just sit there waiting to be trained," he added. "It’s going to take a year to get them into the basics, but even the back end of this year, three months – that’s an enormous cost and we’re expecting business to take that with such uncertainty.
"The cap on state aid is still creating big problems here in terms of businesses being able to draw down the amount of money and the numbers of people that would need to be recruited even as a starting point. There is no easy solution here."
Concerns were also raised about the lack of UK vets to produce export health certificates for exporting live animals or animal products.
'Chaos in Kent'
Asked what they believed the probability was for 'chaos in Kent' from the start of next year, at least in the short term, Jerzewska and Burnett both estimated the likelihood to be 70%-80%.
"In terms of my gut feeling as we stand here today with 81 days to go and the amount of work that we have got to undertake, chaos in Kent? 80/20 for," said Burnett. "If businesses try to dispatch because they haven’t got customs agents to do the paperwork then the chances are they are still going to want to trade and if we’re not ready, then we will have chaos."
Robert Hardy, operations director for the Customs Clearance Consortium, was more optimistic, but still said: "More than 50% chance of delays in Kent. I’m not sure it’s chaotic, but it’s not good. The fear is that snarls up domestic traffic that’s delivering and collecting in Kent, it also snarls up the empty trucks that are going back and it snarls up the prepared."
Hardy's biggest concern was exports. "If there’s a snarl up in Kent, that’s all about exports from the UK. The biggest absolute fear is that a truck is sent to Calais and they send it back. That is a genuine fear.
"If the paperwork is validated whilst the vehicle is crossing the channel and that validation fails because the transit document’s not correctly authenticated or there aren’t any documents or the entry’s not lodged in France, it’s coming back.
"The fear is the Daily Mail headline of ‘We Sent our Goods to Europe and They Sent Them Back' is looming. It’s a matter of time."
Hardy added that if firms were concerned goods could be rejected at their destinations, GB exporters could easily be expected to pay a deposit of 0.5% - 1% of the value of goods, in addition to duties, to cover that eventuality. If delivery was successful, that cash would be repaid, but the process would still create additional cash flow pressures.
Exporters also needed to clear the necessary red tape with authorities in every EU country they were sending goods to, said Hardy. "Now you have a situation where an exporter into the EU from a GB cheddar manufacturer is sending goods into France and it’s on something called 'delivered duty paid' terms.
"Delivery duty paid conditions mean the exporter is responsible for everything, including the import cleared in France, including the VAT in France, which requires them to have a French VAT registration and that’s not a quick fix, so if they haven’t done that already, the market’s going to lock itself out."
That was only a small part of the bureaucracy to consider, he said. "It’s the export health certificate, the phytosanitary certificate, the border control posts and the safety and security declaration, which for Dover-Calais I can’t do. I need access to the French system to do safety and security declaration in France."
There were still considerable problems for imports, said Burnett, much of which were faced by overseas importers, rather than UK-based firms. "The administrative burden to bring product in from Europe is colossal and it’s going to sit with the haulier and I just don’t think that’s a practical solution."
Hardy added: "It is the carrier’s responsibility to do the safety and security declaration. Now the carrier might be a trucker from Hungary. They’re not ready for that for sure.
"85% of trucks servicing the cross-Channel market are foreign. The initial leg is the import leg into the UK. If that’s super fast, super slick and the export leg is like walking through treacle, there will be a perpetual queue – no two ways about it.
"You either solve that by making the export leg as slick as the import – really hard to do – or you somehow slow down the imports, so you’ve got some sort of balance within that circular flow. Or they stop coming because there’s easier money to make. Why bother to go to the UK when you’re not sure when you’re going to get a truck there?"
Burnett said: "The issue is we haven’t got European hauliers with the access rights to go and pick that volume up if we haven’t got a deal. 30% of food comes from Europe." By the time 2021 began, overseas freight services might not have cabotage (leave to operate in the UK).
In turn, the UK may not have the right to operate sea, air or road transport services within at least some EU nations, he said. "If they are not going to deliver it because we have removed cabotage, we may not be able to go and get it."