37 Days and Counting...
As the new Brexit deadline of 31 October 2019 nears, the UK government and EU leaders are still negotiating and discussing a mutual agreement for Brexit. The EU maintains its standpoint to not allow a Brexit deal which may break the Good Friday peace deal between Northern Ireland and the Republic of Ireland. The UK on the other hand, has vowed to remove the backstop, and has not yet provided a clear solution on how potential issues at the above mentioned border would be solved.
If the negotiations for a new Brexit deal or another postponement on the 31 October 2019 departure deadline would all fail, a no-deal exit [hard Brexit] may be worse case scenario, although the UK House of Parliament voted for a bill to prohibit a hard Brexit.
Eurofins Central Laboratory conducted an Operational Risk Assessment focused on the introduction of Brexit on 31 October 2019 to address potential risks to our operations, applicable regulations and standards, and potential impact on study subjects and or investigator sites.
Regardless of the outcome of ongoing negotiations, in order to mitigate the worst case scenario, we continue to prepare for a hard Brexit:
Outbound Shipments [Kits and Supplies Shipped from Eurofins EU to UK Sites]
- Sites ought to be prepared for possible delays in kits and supplies shipments from the Eurofins Central Laboratory kit packing location in EU to Sites in the UK. Delays are expected as a result from the introduction of customs clearance proceedings for the shipments between the EU and UK and common concerns if the UK border authorities’ capacity will suffice. We anticipate that not all companies in the EU and UK will be fully prepared for an expected jamming in the customs processes, so Eurofins Central Laboratory will ensure that all necessary customs documentation is in place for successful customs clearance.
- To minimize the impact to UK Sites we propose the following:
- Upgrade the current shipment method from ground service to air service for the outbound kit/supplies shipments, as a temporary solution. We anticipate that we can return to ground service 6 to 8 weeks after hard Brexit date permitted stabilization of the customs process. Please note that this upgrade from ground to air will have an impact on current study budget and must be approved by the Sponsor prior to implementation. In case an objection to using air service exists, we will obviously respect this and will continue utilizing ground services.
- If the layout of a Site allows, we encourage Sites to keep additional stock at hand and avoid ordering supplies in the first few weeks after Brexit.
- UK customs authorities will invoice customs duties and taxes to Eurofins Central Laboratory as a result of the customs clearance procedure. Based on our pass-through invoicing procedure, these charges will be invoiced to our Sponsors [with no further additional fees].
Inbound Shipments [Samples Returned from UK Sites to EU Eurofins Laboratory]
- Inbound shipments of samples will continue to be shipped via air services. In addition, these samples are being shipped using a Medical Express service and therefore have the highest boarding status for the flight.
- Because of the change in customs regulations the couriers will change the Air Way Bill [AWB] details. Sites will receive new AWBs with resupply orders that are shipped after 31 October 2019. The AWBs currently on site that were created prior to Brexit can still be used after 31 October 2019. There is no need to discard these.
- For shipments that will be returned to the EU Eurofins Laboratory, Sites will need to include a customs invoice. A customs invoice is a statement towards the customs authorities (both in the UK and EU) that confirms the shipper and consignee, the commodity of the goods and the value. Sites will receive a template for a customs invoice along with instructions for the completion of the document. PLEASE NOTE: Shipments without a customs invoice will be returned to the Site and can’t be exported to the EU. Samples returned to laboratories within the UK do not require inclusion of a customs invoice.
- Additional customs invoices will be shared with the Sites through the resupply orders.
- Our preferred courier DHL will increase the number of flights between the EU and UK and will also use larger aircrafts. If necessary we have the ability to offer addition courier options through specialized couriers (Marken, QuickStat, Ocasa, MNX and others).
As a standard, the dedicated Eurofins Central Laboratory Global Transport Team monitors all shipments. In the weeks following Brexit, there will be a special focus on the shipments to and from the UK. As per our Standard Operations Procedures, this team will work with the couriers to prevent delays or when delays occur keep them to a minimum.
We will continue to closely monitor the events related to Brexit and share additional information when available.