4th November, 2020
No Deal Brexit and International Haulage – Not Enough Permits to go Round
ECMT Permits – Application Window Opens on 2nd November
The preparations for the end of the transition period and the United Kingdom’s (UK) departure from the European Union (EU) continue for the government and the road haulage industry alike.
While the industry awaits confirmation of whether the UK and EU have reached a deal, it remains best practice to prepare for the possibility of a “No Deal Brexit”.
UK operators will be able to continue to use their EU Community Licence until the end of the transition period on 31 December 2020 to trade with EU member states.
In the event of a No Deal Brexit, operators will no longer be able to use these licences. Instead, they will require a European Conference of Ministers of Transport (ECMT) Permit (“the Permit”); more details, including how to apply can be found here.
There is now guidance on the documentation that will need to be carried:
The driver will need to carry these documents for all of the outward and return journey:
- the ECMT permit
- the ECMT permit logbook (plus the issued translation sheets)
- the ECMT certificate of compliance for the vehicle and trailer (plus the issued translation sheets)
- a certificate of roadworthiness for the vehicle and trailer (plus the issued translation sheets)
The driver must show the documents at checkpoints when asked.
Without these documents, vehicles will not be permitted to enter the ports.
Any operator based in the UK (including Northern Ireland) can apply for a Permit if their vehicle(s) meet Euro V or Euro VI standards. The current government advice is that operators should apply for the Permit, in case it is needed from 1 January 2021.
If a deal is agreed between the UK and EU in the meantime, the Permit may not be necessary. However, applying will allow operators to ensure that they are as prepared as possible.
The application window for the 2021 Permits opens on 2 November 2020 and closes on 20 November 2020. The Permits will be allocated once this window has closed and not on a first come first serve basis. There will be a fee of £10 per application and a further fee of £123 for the annual Permit if and when granted.
We advise all our operator clients to ensure that they have made this application to the DVSA within the appropriate timeframe if they wish to take vehicles to mainland Europe next year.
The UK government will only be able to issue Permits as follows;
- 984 annual Permits for Euro VI vehicles;
- 2,592 monthly Permits for Euro VI vehicles;
- 240 monthly Permits for Euro V vehicles;
It is estimated that around 300,000 UK registered vehicles travel to the EU each year (not including those travelling to the Republic of Ireland). According to the FTA when applications were made ahead of the projected March 2019 departure fewer than half the 2,000 applicants received permits.
If no deal is agreed, there will simply not be enough Permits available to meet demand. It is therefore imperative that operators ensure that their Permit application is made in time, to allow their preparations to proceed as smoothly as possible.
Those operators which run their transport undertaking via a number of different companies should note that once issued, the Permit will apply to one company. The Permit cannot be transferred between companies. However, the Permit is not allocated to a specific operator’s licence. This means that operators who have multiple licences can use the Permit across all these licences, provided that each of the operators’ licences is held in the name of the same company.
There is no mention of a registration number on the Permit once issued so the Permit can be used by successive vehicles subject to the Permit being used with the appropriate Euro status vehicle. However, operators should note that the Permit does not authorise cabotage work; vehicles will need to return to the UK after every third journey.
There are some limited exemptions to the need for the Permit; further details can be found here.
Our advice continues to be that operators should ensure that they keep up to date with the latest government and industry bodies’ guidance. Should you require further information regarding any of the points raised in this article, please contact Tim Culpin, Head of Transport
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