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European union common border crossings management project


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European union common border crossings management project

  1. 1. F;ù EUROPEAID/129783/C/SER/multi Lot 1: Studies and Technical assistance in all sectors “A Study on Common Border Crossings Points Management between Schengen Area and Russia / Belarus” Contract No. 2011/282801 STUDY REPORT This project is funded by the European Union A project implemented by B&S Europe Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 1
  2. 2. Common Border Crossings Management Project – Draft Final Report May 2012 Table of contents Executive Summary Glossary Map showing major BCPs between Schengen Area and Russia and Belarus 1. INTRODUCTION .................................................................................................................. 2 2. METHODOLOGY ................................................................................................................. 2 3. CONSTRAINTS AND OPPORTUNITIES .............................................................................. 3 4. SCHEDULE OF FIELD VISITS ............................................................................................. 4 5. INTERNATIONAL CONVENTIONS RELATING TO BORDER CROSSING FACILITATION 5 6. DOMESTIC LEGISLATION IMPACTING ON BORDER CONTROL PROCESSES.............. 7 6.1 OVERVIEW OF RUSSIAN FEDERAL CUSTOMS SERVICE’S OPERATIONS AND FUTURE STRATEGIES ................................................................................................................................................. 8 6.2 OVERVIEW OF BELARUS STATE CUSTOMS COMMITTEE’S OPERATIONS AND FUTURE STRATEGIES ............................................................................................................................................... 10 7. BORDER CONTROL PROCESSES AS ACTUALLY PRACTICED .................................... 11 7.1. CURRENT SEQUENTIAL PROCESSES IN RUSSIA AND BELARUS.............................................. 14 8. DEFICIENCIES AND DISCREPANCIES IN ACTUAL BORDER CONTROL MANAGEMENT PRACTICES.............................................................................................................................. 20 9. CROSS BORDER COOPERATION BETWEEN BORDER CROSSING POINTS MANAGEMENT AGENCIES ..................................................................................................... 23 9.1 AUTOMATED EXCHANGES OF INFORMATION ON CUSTOMS MOVEMENTS WITHIN THE CONTEXT OF OPERATIONAL LEVEL COORDINATION BETWEEN CUSTOMS SERVICES .......................................... 25 10. THE LOGISTICS OF MOVEMENTS OF PASSENGERS AND GOODS AT BORDER CROSSING POINTS ................................................................................................................. 26 11. THE IMPACT OF PHYSICAL INFRASTRUCTURES ON THE OPERATIONS OF BORDER CROSSING POINTS................................................................................................. 30 12. THE VIEWS OF BORDER MANAGEMENT AGENCIES ................................................. 33 13. THE VIEWS OF TRANSPORT OPERATORS AND THEIR REPRESENTATIVE BODIES 34 13.1 SUMMARY OF THE VIEWS OF EU BASED TRANSPORT OPERATORS. ....................................... 35 Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 2
  3. 3. 13.2 SUMMARY OF VIEWS OF A RUSSIAN BASED TRANSPORT OPERATOR .................................... 36 14. THE VIEWS OF DRIVERS. ............................................................................................. 39 14.1 SUMMARY OF DRIVERS’ QUESTIONNAIRES .......................................................................... 41 15. THE RAIL FREIGHT SITUATION. ................................................................................... 43 16. THE RAIL PASSENGER SITUATION. ............................................................................ 45 17. CONCLUSIONS REACHED ............................................................................................ 46 17.1 ROAD FREIGHT ................................................................................................................. 47 17.2 ROAD PASSENGERS ......................................................................................................... 49 17.3 RAIL FREIGHT................................................................................................................... 51 17.4 RAIL PASSENGERS ........................................................................................................... 52 18. RECOMMENDATIONS ................................................................................................... 52 18.1 HIGH PRIORITY ISSUES...................................................................................................... 52 18.2 GENERIC BORDER MANAGEMENT PROCEDURES ................................................................ 54 18.3 TECHNICAL ROAD FREIGHT PROCEDURES .......................................................................... 56 18.4 GENERIC ROAD FREIGHT PROCEDURES ............................................................................ 56 18.5 GENERIC AND TECHNICAL ROAD PASSENGER PROCEDURES ............................................... 57 18.6 GENERIC AND TECHNICAL RAIL FREIGHT PROCEDURES........................................................ 57 18.7 GENERIC AND TECHNICAL RAIL PASSENGER PROCEDURES ................................................. 58 19. RECOMMENDATIONS ON BORDER CROSSING POINTS REQUIRING PRIORITISATION OF MODERNISATION AND INTRODUCTION OF NEW PROCEDURES ... 58 TABLE 1 BORDER CROSSING POINTS VISITED BY THE PROJECT TEAM DURING THE STUDY ............ 62 TABLE 2 ALTERNATIVE BORDER CROSSING POINTS NOT VISITED DURING THE STUDY BUT INCLUDING BCPS RECOMMENDED FOR MODERNISATION PROGRAMMES ........................................................ 63 MAP 1 LOCATION OF BCPS VISITED IN THE FIELD VISITS............................................................. 64 20. BCP BASED TESTING OF RECOMMENDED MEASURES ........................................... 71 APPENDIX A – IDENTIFICATION OF CORE ROAD AND RAIL TRANSPORT CORRIDORS ...................... 74 APPENDIX B - BORDER MANAGEMENT AGENCY QUESTIONNAIRE RESPONSES ............................ 76 APPENDIX C - PUBLICATIONS CONSULTED ............................................................................. 150 APPENDIX E - ACKNOWLEDGMENTS ........................................................................................ 164 APPENDIX F – TERMS OF REFERENCE .................................................................................... 167 Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 3
  4. 4. Executive Summary The Project Team (PT), composed of the Team Leader, the Logistics Expert and the Trade Facilitation Expert, together with an interpreter and translator, has completed its interviews with Border Management Agencies, Freight Forwarders Associations and Road Transport operators, and with individual drivers. The meetings with Border Management agencies, including those responsible for infrastructure development, have all been on the Schengen side of the border, with the exception of a meeting in Poland with Belarusian Customs staff. Russian Agencies have been kept informed of Project progress and contacts made. The results of these interviews and other research have been used in producing Conclusions and Recommendations for development and modernisation of border management infrastructures and technologies and particularly of intra state and interstate information sharing and cooperation procedures. These Conclusions and Recommendations are summarised at the end of this Executive Summary and the appropriate sections of the Main Body of the Report with background information being included in the relevant Appendices, especially Appendix B which reproduces the Questionnaires used for Field Visits to BCPs on the EU side of the border. The required outputs of the Study were in relation to using assessments of the current status of management of road and rail BCPs as outlined in Section 2.1 (a) to (e) of the Terms of Reference as reproduced at Appendix F, in order to produce recommendations in relation to improving physical infrastructures and movement capacities, developing agency cooperation within countries and between countries and to coordinate the development of technologies and operational planning to achieve these aims. Specifically, a list was to be produced of BCPs requiring modernisation. All these issues were taken into account in the Study, but with a particular emphasis on organisational, managerial and technological (IT) issues. This approach was taken on the advice of the NDP TL Secretariat, which advised the Project Team that previous studies had tended to relate to infrastructure issues. Because the non-infrastructure modernisation issues are closely related to each other, the Conclusions and Recommendations have been collated and presented on functional lines in relation to particular modes of transport, particularly road freight. This approach has been taken because specific capabilities and procedures have differing levels of impact on specific modes of transport. This means that specific recommendations in one transport mode ay relate to several separate output deliverables. It also means that “modernisation” has several meanings depending on the context of the recommendation. It does not simply mean expansion of rail lines or road lanes, or of parking space and shelter facilities. The Project believes that the opportunities for improving integrated BCP management within the Schengen Area and between the Schengen Area and both Russia and Belarus as Customs Union members are both technical and organizational. It is felt that Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 4
  5. 5. there is no single solution to the challenge of reducing delays in the movement of people and goods while maintaining the security of physical and fiscal borders. The interviews and written submissions by all parties interviewed have, however, enabled the PT to reach a number of conclusions for which there is a wide and strong consensus among the interviewees regarding what is needed to improve border crossing procedures in the four separate but also related categories of road freight traffic, road passenger traffic, rail freight traffic and rail passenger traffic. In reaching this consensus, the PT has been able to identify the major transnational transport connections between the Schengen Area and Russia and Belarus and has accordingly produced a list of those road and rail BCPs which would require particular improvements in management of border crossings. These were identified after taking into account current and expected traffic volumes and possible procedural changes such as liberalization of visa regimes. However, the Project Team noted particularly that the non-infrastructure bottlenecks apply to all BCPs to some extent, and that infrastructure issues impact on other issues and vice versa. This thinking has to be considered throughout the Report. While physical infrastructure issues are highlighted, such as the need for more bridges at river crossings, the modernization of procedural issues are seen as being of significantly greater importance, both in the short and long term. The most important issue is felt to be an organizational one. There needs to be a significant reduction in the number of processes involved in the movement of freight, where the delays are greatest. Such reductions would be consistent with the letter and spirit of the Conventions to which some or all of the Northern Dimension Partnership states are signatories. The report therefore highlights the provisions of these Conventions, together with the encouragement of moving to free flow systems for the passage of goods and commercial and passenger vehicles. Such systems are defined in detail in the Report and the PT’s calculations are that they can reduce crossing times by up to 40%. In relation to technical issues, key identity verification equipment and the operation of the Schengen Information system can be slow or unreliable or both, leading to severe entry delays. Communication networks speeds need to be increased considerably, with significant excess capacity built in. Reliability and robustness of passport readers and fingerprint readers needs to be improved significantly, especially for use in bad weather. Reflecting the desirability of saving time, fingerprint checks might be limited to the checking of just one finger. Serious consideration needs to be given to much more detailed systematic use of Advance Passenger Information (API) for both coach and rail transport. Tests between Poland, Belarus and Russian during the Euro 2012 football championships will provide experience. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 5
  6. 6. There needs to be much greater systematic cross border exchanges of Customs data regarding common and separate assessments of risk in order to move to genuine implementation of the aims of the TIR Convention which aims for generally unimpeded movement. There are opportunities for improving border security and revenue protection by developing the use of Automatic Number Plate Recognition (ANPR) systems on national and transnational bases, which would support tackling cigarette, alcohol and road fuel smuggling into the EU and support the effective collection of Customs duties and VAT on private cars imported into the Customs Union (CU). Reaching agreement on such mutual exchanges will be challenging as there are currently very different trading patterns with imports into the Customs Union being generally of higher value with correspondingly greater risks for frauds such as misdescription and undervaluation. However, the task should be made easier given Russian’s accession to the WTO with resulting reductions in duty rates. These measures should be accompanied by reductions in the number of sequential Customs procedures required by Russian Customs and Belarus Customs on behalf of Russian Customs, an aim recently highlighted by President Putin. The most effective measures for reducing the costs burden on freight operators would be for a major expansion in the use of queue management systems alongside the provision of off road parking at suitably equipped terminals. For maximum impact, both need to be introduced as queue management has not necessarily reduced crossing times but has reduced the amount of time (and therefore costs) incurred in unproductive waiting which is regarded as being working time for drivers. The project particularly notes that the Estonian GoSwift system, introduced on a compulsory basis in 2011, is now to be tested by Rosgrantisa on the Russian side of the Russian – Estonian border from 1st July 2012. The above measures are being introduced at several locations on the Schengen Area / CU border and active discussions should take place regarding harmonizing procedures on both sides of the border and on introducing queue management systems near simultaneously. Improved portable sanitation facilities need to be provided as a matter of urgency at several locations. . The Project Team proposes that these measures be considered for early introduction on at least one BCP in each of the core network corridors, together with at least one major alternative route. Consideration should be given to the long term secondment of staff between adjacent BCPs. Such deployments would provide experience which might be used as a basis for considering the introduction of joint BCPs. Capabilities for a joint BCP already exist at the Koroszczyn terminal on the Polish border with Belarus in relation to the Kukuryki (Poland) – Kozlowiczy (Belarus ) BCPs. The thinking in recommending the BCPs appropriate for early introduction of these measures is that the Norwegian / Russian border crossings will link deep water ports of Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 6
  7. 7. increasing importance, and the Russian / Finnish choice is the direct link between Moscow and St. Petersburg with Scandinavia. The proposals in the Baltic States are intended to ensure more effective movements of passengers and goods to and from both St. Petersburg and Moscow. The routes from Belarus to Lithuania and, especially, Poland are suggested in order the meet the wider needs of the key Europe wide transport corridor between Berlin, Warsaw, Minsk and Moscow and to assist modernization of links with the Kaliningrad region of Russia. The suggested locations are Storskog (Kirkenes) – Borisoglebsk (Norway – Russia), Valimaa – Trorfyanovka and Nuijimaa- Brusnichnoe (Finland – Russia), Narva – Ivangorod and Luhamaa – Shumilkino ( Estonia – Russia), Terehova – Burachki and Grebneva – Ubylinka ( Latvia – Russia), Kybartu- Chernyshevskoe ( Lithuania- Russia – Kaliningrad) and Medininkai – Kamenny Log ( Lithuania – Belarus) and all the Polish – Belarus crossing points in the immediate area of Terespol / Koroszczyn and Brest ( Kukuryki- Kozlowiczy and Terespol- Brest) together with Grzechotki-Mamonowo and / or Bezledy -Bagrationovsk ( both Poland – Kaliningrad). The PT recommends that the suggested modernisation measures be tested out by carrying out objectively based trials of the recommended measures under close local (BCP) regional and national supervision. Because the relationships between factors impacting upon the speed of movements are complex, it is suggested that individual factors be examined at individual BCPs, with the results being then examined alongside similar trials of other factors at other BCPs. Given the relatively fast flows of commercial freight at the Finnish – Russian border and the recent introduction of a queue management system in Estonia, it is suggested that particular attention be paid to the views of the BMAs on both sides of these particular borders. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 7
  8. 8. Glossary AEO ANPR API ASMAP ATP BCP BG BMA BY CBCP CBM CCTV CIS COMECON CTN CU EC ECICS EDI EE EEAS EORI EU FCS FFAs FI Frontex HBD HQ HS IBM IRU IT ITMS KGD KZ LED LT LV MUR NATO NCTS Authorised Economic Operator Automatic Number Plate Recognition Advanced Passenger Information Association of International Road Carriers (of Russia) Agreement of the International Carriage of Perishable Foodstuffs Border Crossing Point Border Guards Border Management Agency Belarus Customs Border Crossing Point ? Coordinated Border Management Closed Circuit Television Commonwealth of Independent States Council for Mutual Economic Assistance Core Transport Network Customs Union (Russian Federation, Belarus and Kazakhstan) European Commission European Customs Inventory and Chemical Substances Electronic Data interchange Estonia (EU) European External Action Service Economic Operators Registration and Identification European Union Federal Customs Service (of Russia) Freight Forwarders Associations Finland Frontieres Exterieures – European Agency for the Management of Operational Cooperation at the External Borders of the EU Heart Beat Detector Head Quarters Harmonized System Integrated Border Management International Road Users (Association) Information Technology Integrated Transport Management System Kaliningrad oblast of Russia Kazakhstan Leningrad oblast of Russia Lithuania Latvia Murmansk oblast of Russia North Atlantic Treaty Organization New Computerised Transit System Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 8
  9. 9. NDP NDP TL NII NORDIM OSCE PL PSK PT RU SIS TIR TOR UN UNECE VAT WCO WTO Northern Dimension Partnership Northern Dimension Partnership for Transport & Logistics Non-Intrusive Inspection Northern Dimension Partnership on Transport and Logistics, especially Final Report of 30.06.11 Organisation for Security and Cooperation in Europe Poland Pskov oblast of Russia Project Team Russia Schengen Information System Transports Internationaux Routiers Terms of Reference United Nations UN Economic Commission for Europe Value Added Tax World Customs Organisation World Trade Organisation Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 9
  10. 10. Map showing major BCPs between Schengen Area and Russia and Belarus Storskog (NOR) - Borisoglebsk Imatra - Svetogorsk Nujamaa - Brusnichnoe Vaalimaa - Torfianovka Narva - Ivangorod Koidulla – Kunichina Gora Luhamaa - Shumilkino Grebneva - Ubylinka Terehova - Burachki Silene - Urbany Panemune - Sovietsk Salchininkai - Beniakoni Medidnkai – Kamenny Log Kybartu - Chernyshevskoe Bezledy – Bagrationovsk Gronowo – Mamonovo Grzhechotki – Mamonovo 2 Kuznitsa Bialostoka - Bruzgi Bobrowniki - Berestovitca Kukuryki - Kozlovichi Terespol - Brest Slawaticze - Dolmachevo Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 1
  11. 11. 1. Introduction The Project Team (PT) hereby submits its draft Study Report for approval by the NDP TL Secretariat and its Steering Committee. The Study Report fulfils the requirements of the Terms of Reference (TOR) to provide a description and in depth analysis of current border control practices at Border Crossing Points (BCPs) between the Schengen Area (EU Member States and Norway) and both Russia and Belarus (as members of the Customs Union – CU – with Kazakhstan). The Report also analyses procedures for communicating and coordinating between agencies on both sides of the border and makes recommendations for further development of these communications and resulting operational procedures. The Report examines and assesses the logistical procedures applied at both road and rail crossing points, and for both passengers and freight. Finally, the Report proposes a list of BCPs which especially require improvements in BCP management. All these analyses, assessments, proposals and recommendations need to be seen in the context that they are all connected, and that they may well be applicable to other BCPs in the border areas within the Project’s scope, and indeed beyond. In addition, infrastructure improvements will be ineffective without accompanying changes and adjustments in BCP management procedures. On the other hand, BCP's can improve their performance in many cases by improved management, even without infrastructure investments. While physical infrastructure issues beyond the BCPs, especially regarding modernization of road and rail networks, have not been subjects for detailed study, it became clear during the Field Visits that road and rail network capacities had to be taken into account. This was especially when considering the need for vehicle terminals and traffic queue management systems. 2. Methodology In accordance with the requirements of the TOR, the Project Team made use of multiple sources within Border Management Agencies (BMA) and the private transport sector. The main information tools were a BMA Questionnaire which was completed by members of those Agencies, mainly after the Project Team had completed a series of field visits to key road and rail BCPs in Lithuania, Latvia, Estonia, Finland and Poland, and a Driver’s Questionnaire. These are reproduced in the Appendices. The views of the private sector were recorded in separate reports which are also reproduced in Section 13. of the Study Report. In addition, the Project Team’s summary of interviews carried out with drivers at or near BCPs in the EU Member States and in Russia and Belarus is included at Section 14. Separate interviews were carried out in several EU states and in Russia and, by telephone, in Belarus with representative associations of road transport operators. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 2
  12. 12. The interviews took place during or around the series of Field Visits to key BCPs previously identified in Phase One of the Project, or proposed by the host BMAs. As the Project accepted the recommendations of the BMAs regarding the BCPs which should be visited, rather than necessarily those the Project had identified as worthy of particular attention, the list of BCPs which are, in accordance with the required outputs in the TOR, particularly requiring improvements in management are not identical with the BCPs actually visited. The Project believes these differences are not material, as the management procedures identified and which are the subject of the Conclusions and Recommendations at sections 17, 18 and 19 are common across most or all BCPs. In all cases, the Project’s Summaries also included the views of the Project Team (PT) as source documents for the Conclusions and Recommendations. The Summaries of the views of the BMAs are not simply accounts of the key views of the BMAs but have been used to make suggestions for future developments. As the BMAs have agreed the contents of their Questionnaires and any amendments they have made have been incorporated into the final versions of the Questionnaires, the Project is satisfied that these are accurate assessments. . 3. Constraints and Opportunities There were a number of constraints experienced during the Project’s research and Field Visits. Partly due to time limitations, it was not possible to formally meet with the BMAs of the Russian Federation. Obviously this is a major limitation. The Border Guard Service of Belarus as lead BMA in Belarus was unable to provide the Project Team with an invitation to visit Belarus and meet BMA personnel formally, though this has partially been offset by a meeting with the Belarusian Customs. The PT is very grateful to Polish Customs for arranging for these colleagues to join the PT in Poland. These are significant constraints, especially as all the Conclusions and Recommendations Sections are, wholly or partly, intended to be considered on both sides of the border ideally simultaneously or near simultaneously. However, these constraints were partially mitigated by the above mentioned meeting with Belarusian customs as well as visits to selected BCP's as travellers. BMA staff interviewed in all the EU States visited included personnel with specific responsibilities for cooperation with their Russian or Belarusian counterparts. These colleagues stressed their cooperation with their Russian and Belarusian colleagues, especially from Border Guards and Customs. The PT believes that the opinions given to it are likely to be reasonable and broadly very accurate representations of the views of their colleagues, although clearly there are likely to be some differences from the actual views of their counterparts. Thanks to the assistance of the Polish Customs Service, the Belarus Customs colleagues were able to join the Project Team’s visit to the Polish – Belarus border. Their views are represented by the Project Team in Appendix B in the polish BMA Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 3
  13. 13. Questionnaire and in the issues highlighted in the Conclusions (Section 17) and in the proposals made in the Recommendations (Section 18). The PT was able, when deploying to the series of Field Visits by traveling from Lithuania to Belarus, and later from Ukraine through Belarus to Poland, to observe passenger vehicle processing procedures and systems for the arrival of EU and non EU ( Schengen visa holding) persons. A similar opportunity also has been taken at the Russian – Estonian and the Russian Finnish borders, which were crossed by the PT as well. There were also opportunities throughout the Field Visits to interview truck drivers from the EU and CU regarding their experiences in relation to freight traffic on both sides of the EU / CU border. There were some practical constraints regarding the delivery and analysis of data from drivers as the questionnaires did take far more time to be returned than anticipated. Drivers appear to be often away for more than one month and international mail, even in EU member states from the remote border areas is slow. Furthermore, some associations declined to meet the Project, and another gave only limited information, relying on the Project Team to draw its own conclusion. However, the Project does not believe that these constraints materially affect the Conclusions and Recommendations listed at Sections 17, 18 and 19 below. There was an obvious consensus among all the EU Border Management Agencies, including regarding the views of their Russian and Belarusian counterparts. The responses from drivers and transport operators showed a similar consensus. Therefore, the Project Team believes that its findings are based on reliable evidence, obtained in sufficient quantity. The level of consensus from both the official sector and the private sector, and the congruence of the views within the EU with the imminent and longer term modernization plans of the Belarus and Russian Federation BMAs in relation to what are commonly agreed as key transport facilitation challenges give the PT a high degree of confidence in its Conclusions at Section 17 below. We therefore believe that further information which can be expected to be available in the near future will confirm the basic validity of the Conclusions or identify where those Conclusions are incorrect or require further study. Examples of such new data might include the early and longer term results of imminent Russian Federation Customs moves towards reductions in the number of Customs procedures at import and the June 2012 introduction of a compulsory web based system for pre arrival declaration of imports of goods. Such fresh data should allow early modification of our Conclusions, with some resulting modifications of our Recommendations. 4. Schedule of Field Visits In all the Field Visits the PT met Border Management Agencies of the Schengen Area States at BCPs proposed by the PT as being of particular significance on key transport corridors, or which the Schengen area BMAs felt had facilities and capabilities which were of particular relevance to the Study. During the Polish visit, representatives Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 4
  14. 14. of the State Customs Committee of Belarus crossed the border to join the meeting. These colleagues were given details of the entire schedule, as were contacts in the Customs Service of the Russian Federation, through introductions made by Finnish Customs. However, some states proposed visits to other locations. These proposals were accepted. However, the PT did not restrict its recommendations regarding the BCPs to be prioritized for modernization to the sites visited. The opportunity was taken at all Field Visits sites to issue drivers’ questionnaires and to interview drivers informally. Some transport operators were interviewed separately at around the same time. In order to ensure the maximum level of frankness, anonymity was guaranteed. The first set of BCP visits were to the Lithuanian Belarus border (Medininkai BCP with Kamenny Log 2nd April) and the Lithuanian – Russian border (Panemune BCP with Sovietsk 3rd April). The second visit was to the Latvian – Russian border ( Terehova – Burachki and the Latgale Rail BCP at Zilupe ) on 4th April. The third visit was to the Finnish – Russian Border ( Nuijamaa- Sosnovskoye / Brusnichnoe) on 16th April. Following a meeting with Estonian BMA HQ staff in Tallinn on 17th April, visits were made to the Estonian – Russian border at both Koidula – Pechory / Kunichina Gora and Narva – Ivangorod on 18th and 19th April respectively with road and rail BCPs being visited at both locations. The Polish – Belarusian border was visited at Koroszczyn Terminal on 25th April in relation to the Kukuryki BCP and nearby at Terespol ( road and th rail BCP on the Polish side of the Bug river opposite Brest) on 26 April. Members of the Project Team also carried out an informal Field Visit when travelling between deployments, i.e. at Medininkai and Kamenny Log on 8 th April and at Brest – Terespol road on 12th April. 5. International Conventions relating to Border Crossing Facilitation A wide range of international Conventions provide for the regulation of the movements of passengers, goods and, inter alia, commercial and private vehicles. The most important of them are listed in Appendix D, together with wider and more detailed descriptions of their provisions. Many of them have not been ratified by the Customs Union States or by their Schengen neighbours. However, the most important conventions such as the:  Convention on the Harmonised Commodity Description and Coding System.  International Convention on the Harmonisation of Frontier Controls of Goods  International Convention on the Simplification and Harmonization of Customs procedures (1973 and 2006 amendments)  Customs Convention on the International Transport of Goods under Cover of TIR Carnets (1975 with amendments)  Convention on Temporary admission (1990) Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 5
  15. 15. have been ratified by all reviewed countries. By ratifying or acceding to these Conventions, the countries committed themselves to undertake a number of commitments which can be summarised as follows:          to ensure sufficient staff and infrastructure at BCP's, taking into consideration traffic demands1, to carry out only those controls that are absolutely necessary as established on the basis of risk assessments2 especially in the case of transit shipments, to the extent practically possible, to carry out multiple controls simultaneously or with minimum delay, to have customs clearance to take place away from the border as much as possible, to share information with each-other that facilitates the processes at the border, in case of rail cargo crossings, to carry out both export and import controls as much as possible at the same station near to the border (joint controls) to give priority to vehicles carrying perishable foodstuffs and live animals, provide facilities to create a competitive market in customs brokerage service at the border crossing points, to use IT based systems to the extent practically possible. In addition to the above commitments made on relation to goods transport, countries have to a more or lesser extent ratified certain conventions related to the passenger traffic. These are discussed in detail in the annex to this document. Notwithstanding the above, the fact that a Convention has not been ratified or acceded to does not, of course, mean that the procedures required or suggested in a Convention cannot be introduced under purely domestic legislation. However, we wish to point out that in many cases there is the need for procedures to be introduced on both sides of a border. Clearly, the effectiveness of the procedure is reduced significantly if this is not the case. Throughout this Study, we have made our evaluations on this understanding, and that even if a Convention is not signed there need not necessarily be valid reasons for not introducing its provisions. Equally, the reverse applies. Because a Convention has been ratified does not mean its provisions are necessarily implemented. This is especially the case regarding Conventions which have major impacts on cross border movements, particularly economic ones. The key Conventions here are in the view of the PT, the TIR Convention ( International Transport of Goods under Cover of TIR Carnets) and the International Convention on the Harmonisation of Frontier Controls of Goods.. Many private and official sources made it clear that if the requirements of the Convention were being more fully adhered to in the Customs Union, then movements of goods would be significantly faster. 1 No specific target has been set for waiting delays or the duration of the BCP crossing process though two hours waiting and two hours of processing should be considered as a maximum. 2 A high percentage of cargo inspected and / or X-rayed does not constitute controls based on risk assessment. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 6
  16. 16. It is for this reason that the PT has highlighted in its Conclusions and Recommendations at Sections 17, 18 and 19 below that the implementation of the TIR Convention and the international Convention on the Harmonisation of Frontier Controls of Goods should be a priority for the Customs Union states in close cooperation with their EU neighbours, especially in relation to risk analysis procedures and the logical resulting reductions in the number of physical inspections. We stress that the implementation of the letter and spirit of these conventions and the resulting reductions in the number of processes, with enhanced risk management based supplementary checks, is our number one recommendation. It is accepted that the TIR Convention does recognise the need to qualify the provisions regarding the prevention of irregularities. Further discussion on how this might be done in the context of developing and improving cross-border cooperation is provided in Section 9 below - Cross border cooperation between Border Crossing Points Management Agencies. 6. Domestic legislation impacting on Border Control processes As mentioned at Section 5. above, all of the states in the Partnership have ratified several key international Conventions for facilitating the movement of persons and goods across borders. Under common practice, this makes that the convention provisions supersede domestic law. However, much of the actual implementation of these procedures is implemented by domestic legislation or in the case of the EU Member States and Norway3 sometimes by EU Regulations. (which also applies to Norway in respect of the Schengen Agreement’s provisions). The practical compliance of these states with the provisions of the Agreement is subject to regular scrutiny by external evaluation teams. The introduction of the Customs Union (CU) between Russia, Kazakhstan and Belarus as well as the easing of border controls between Russia and Belarus for movements of persons has created a somewhat similar situation to that pertaining in the EU for customs purposes and movements of persons. Each external border state is in effect responsible for not just its own borders but the borders of the fellow members of the respective Customs Union or free movement area. Therefore domestic legislation is increasingly impacting upon the interests of those other states. Accordingly, such legislation ought to take account of common interests of all the states. It is for this reason that the PT now provides a detailed description of current and imminent Russian legislation and practice in relation to Customs operations in Russia, on the understanding that both the legislation and practice will impact on operations in Belarus too. 3 Norway, as part of the EEA is bound to the provisions of EU Regulations like a member state. Furthermore, in case of EU Directives, Norway is also obliged to transpose their provisions in to domestic legislation. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 7
  17. 17. We provide these details because we believe that the description of the current and planned situations, and the criticisms made by drivers and transport operators provide an extremely useful and important overview of current challenges and opportunities. We also believe that the challenges are consistent with similar experiences of the EU states in the past in relation to their own operations, and to their comments about areas of operations where they would like to enhance cooperation with Russian (and by extension) Belarus Customs. We also stress that the reports by private sector sources regarding scepticism about the concerns of short term negative impacts from the introduction of the compulsory electronic pre- information system scheduled for 17th June 2012 are not unique. Worldwide experience has shown that when new technologies are introduced, there are often problems in the introduction period. It is for this reason that the PT includes in its Recommendations a proposal to monitor the positive and any possible negative results from a very early stage and to share the findings with Schengen Area neighbouring states. 6.1 Overview of strategies Russian Federal Customs Service’s operations and future Russian Customs (Federal Customs Service - is a part of the executive branch of the Government. In 2006 the Government of Russian Federation transferred public policy decisions and development of legal regulation in the area of customs administration from the Ministry of Economic Development and Trade to the Federal Customs Service (Resolution #459). The Federal Customs Service (FCS) reports directly to the Government of Russian Federation. Currently, the FCS is focused on implementation of the following initiatives, strongly related to border crossing operations: Integrated control (One-Stop control). The Federal Law #394-ФЗ (28/12/2010) fully assigned all transport control activities and documentary control on behalf of the Medical Sanitary, Phytosanitary and Veterinary control at the Border Crossing Points to Customs. Currently Customs fulfil (document) control on behalf of other Federal Control Agencies, but according to road operators, around 30% of BCP’s throughput capacity was lost due to insufficient training of customs officers in other forms of control delegated to them and low integration of Information Systems of various agencies, which requires multiple entry of the same data in several Information Systems. Further implementation of the integrated border control will focus on elimination of these gaps. Customs clearance in near-border Logistics Terminals. According to the ‘The concept of customs clearance and control in areas close to the State Border of the Russian Federation’ customs clearance will be mostly done in the frontier Logistics Terminals. It applies to many, but not all types of goods. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 8
  18. 18. According to this concept, private sector will invest in construction of border Logistics Terminals, with support from the State through Public-Private Partnership (PPP) mechanisms. It is planned that many terminals will be located side-by-side with BCPs. This will help eliminate transit declarations, which take several hours for opening at the BCPs and closing at the customs clearance depots. Several logistics terminals near the border have already been constructed. Logistics terminal Ubylinka was put into operation by a private investor in 2011. It is located sideby-side with the BCP Ubylinka. According to various publications in the mass-media, it does not work smoothly. Cargo still needs transit declarations and the total clearance takes days rather than hours. The investor – the local logistics company - TecoTerminal 1 – apparently, is not happy about the work of local customs. Carriers, who know about current operational challenges in the Logistics Centre Ubylinka drive past it and do customs clearance in large towns (Moscow, etc.) or choose alternative routes through Belarus. Remote customs clearance and electronic declarations. Remote customs clearance allows traders to clear goods, which arrived to the border logistics terminals, in their towns. This technology helps to implement the concept of customs clearance in the frontier logistics terminals. Active implementation of this technology started in 2010, when it was defined in the Customs Code of the Customs Union (Article 193-6). This technology requires that all internal and border customs are EDI or Internet connected to the server of the Federal Customs Service. According to the FCS, 100% of customs are now connected to the server and are ready to work with electronic declarations, and 90% of all declarations are submitted by traders through Internet channels. The two other countries of the Customs Union also achieved significant progress in implementing electronic declarations and remote customs clearance. The logistics community believes that although this technology gives traders certain flexibility in planning truck routes from the border to the final destination, it may cause more physical inspection at the border. This is because the trader is represented in the border terminal by a broker who may not be able to provide all answers about cargo to the customs officer. Shipments with multiple types of products will most likely go through physical inspection often. Preliminary information According to the Decision # 899 of the Customs Union Commission (09/12/2011), preliminary information should be provided for all goods to be imported at least 2 hours before crossing the border starting from 17 June 2012. Electronic preliminary information provided by a trader or a carrier should contain information about the goods (HS codes should be in HS6 format for transit goods and in HS4 for goods cleared at the border), consignors and consignees, carriers and vehicles, declarants, planned transloading (for transit goods) and applicable transport constraints (dangerous and other goods). Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 9
  19. 19. Customs should review preliminary information and within 2 hours make a decision about types of control applied to the cargo. The transit declaration is automatically generated from preliminary information provided by the consignor or the carrier. Mandatory preliminary information is closely linked to the implementation of Customs Risk Management System. Requirements to the Risk Management System are provided in the Customs Code of the Customs Union (Chapter 18, Articles 128-130) and in the Federal Law #311-ФЗ on Customs Regulation in the Russian Federation (Article 162). Unlike the Kazakh Law on Customs Affairs (Article 23), which defines the key objective of their Risk Management System as the simplification of control procedures for the Authorized Economic Operators, neither the Customs Code of the Customs Union, nor the Federal Law #311-ФЗ set this goal for the Risk Management System. Readiness of Russian Customs was one of the main issues raised by international road carriers, who believe that borders crossing delays on and shortly after 17 June will increase considerably. 6.2 Overview of Belarus State Customs Committee’s operations and future strategies The following comments by the PT are shorter than those for the Russian Customs Service. However, our comments make it clear that the current draft Law on Customs Regulation is intended to bring national Customs legislation, introduced before the CU, into line with the requirements arising logically from the introduction of the CU. We also note that, as was clear from our Field Visits to the Lithuanian and Polish borders with Belarus, and our discussions with State Customs Committee colleagues from Minsk that Belarus’ border management procedures will become of increasing importance to Russia, given the location of key transport corridors through Belarus. An example of this was the reporting of increased use of Belarus BCPs by transport operators from and through Latvia for traffic destined for Russia, following the introduction of the CU. The Belorussian State Customs Committee is regulated by the National Customs Code (#204-3 adopted on 4 January 2007). Additional provisions, regulating customs administration were stipulated in the Presidential Decree #228 (21 April 2008). Since 2010 most issues of customs operations and administration in Belorussia are regulated by the Customs Union Customs Code. Accordingly, Belorussian Customs is working on replacing the provisions of the current national Customs Code, not covered by the Customs Union Customs Code, by a new law on Customs Regulation. The Law on Customs Regulation is going to be introduced in 2012 subject to the approval in the Cabinet of Ministers and in the Parliament (in September). The proposed Law will cover a number of topics not regulated by the CU Customs Code, such as the organizational and administrative issues related to work of Belarusian customs. This law will also regulate work of customs representatives, customs carriers, Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 10
  20. 20. and customs warehouses and will also define requirements to the Authorized Economic Operators. Belorussian Customs implement similar initiatives and programs as Russian Customs. Within the concept program e-Customs (2011 – 2015) they plan to implement electronic declarations, Singe Electronic Window for traders and One Stop control at the borders. It is planned that Belorussia will follow the World Customs Organization (WCO) recommendations and will soon leave only two Border Management Agencies (BMA) on their borders – Border Guards and Customs. Two other initiatives related to logistics infrastructure and border control technologies are implementation of Non-Intrusive Inspection (NII) equipment and construction of logistics terminals. Unlike Russia, which plans to build logistics terminals in close proximity to the borders, Belorussia plans to build logistics terminals in regional (oblast) centers. Belorussia achieved significant progress in implementing anticorruption measures. The base document regulating anticorruption activities in Belorussia is the Law on Anticorruption Measures (20 July 2006). The next important step was adoption of the state program of anticorruption measures for 2007 – 2010, approved by the Presidential Decree #220 (8 May 2007). Important component of the anticorruption program in Belorussia was promoting feedback from the society and mass-media. International road carriers reported that although Belorussian border control is slow and inefficient, rent seeking by the BMA was negligible for the last several years. 7. Border Control processes as actually practiced The BMAs who were visited by the PT during the Field Visits responded positively to the request to complete the BMA Questionnaire. These are listed in full at Appendix B. The Questions and Answers are intended to provide data which enable all aspects of the required Project Outputs to be delivered. The emphases were on identifying the current levels of traffic movements and delays, expected changes and how BMAs work with each other and with their counterparts across the external border. For reasons explained at section 5. above Constraints and Opportunities the formal meetings were limited to those on the EU side of the external border, although the PT are extremely grateful to the colleagues of the Belarus State Customs Committee who participated in the Polish Field Visit. Their views and the key points of their presentation on 25th April are taken into account in the Conclusions and Recommendations at Sections 17, 18 and 19. During the Field Visits, the PT discussed with Border Guards and Customs jointly the past, current and expected future levels and natures of cross border traffic patterns. The PT visited the traffic lanes and examined passenger and vehicle terminals and Queue Management vehicle parks where these exist. The physical layouts of the BCPs were observed, as were the procedures for the movements of persons and of freight. The road infrastructures in the region were also noted, particularly as the PT travelled by car, typically along the major transport corridors and there was therefore considerable Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 11
  21. 21. opportunity to examine the road infrastructures, which inevitably impact on the levels of traffic. Particular attention was paid to the nature and levels of cross border information exchanges in all their forms, e.g. in relation to traffic management, on operational “casework” issues in the customs and immigration fields, and in opportunities for automated exchanges of customs import, export and transit data in a systematic manner. In order to discuss these matters effectively, it was also necessary to discuss and observe the working relationships and information sharing procedures between BMAs within the BCP. There was a clear consensus among BMAs regarding the key issues which needed to be considered. Improvements to the physical infrastructure of BCPs and of the nearby transport networks need to be considered together. Where BCPs and the access roads between them are in urban areas ( often connected by lane restricted bridges) there was seen to be a need to increase such lane capacity, such as by new bridges as once planned at Ivangorod – Narva / Riigikula (Russia – Estonia) and whose status is now in doubt, and as currently planned at Panemune – Sovietsk (Lithuania – Russia). Similar points were raised at non- bridge locations such as Medininkai – Kamenny Log (Lithuania- Belarus) and Terehova – Burachky (Latvia – Russia). However, these nonetheless very important points were felt to be secondary to improving the management of border crossing processing and the more efficient and flexible use existing infrastructure. The introduction of queue management systems, such as introduced on a compulsory basis in Estonia in August 2011 was felt to be a major positive development and was being examined closely by other regional states. The speed of handling of both freight (customs) and passengers (customs and border guards) can be enhanced by the proper use of such queue management systems in risk management, using the management system as a form of advanced passenger information processing and analysis. While it is crucial to note that the Estonian system does not necessarily reduce the crossing time it does allow much more productive waiting time as the vehicles and their drivers do not have to wait in a queue but can do other productive activities or at least wait in terminal vehicle parks which have more comfortable facilities, especially sanitary facilities, as was seen as Narva and Koidula in Estonia. Further explanations of the opportunities the GoSwift system offers, as well as its values are found in the joint Estonian / Russian audit of border crossing issues (March 2012), listed in Appendix C“Border Crossing of cargo at the land boundary between Estonia and Russia”. The impact of this Report, and of GoSwift specifically, has been demonstrated by the decision of Rosgranitsa, as the lead agency for the management of infrastructure issues in relation to BCPs, to introduce trial operations of GoSwift at Russian BCPs, including Ivangorod, from 1st July 2012. The fact that such management systems do not necessarily reduce the time to cross (but provide some certainty and reduce unproductive queue by allowing “ prebooking” of Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 12
  22. 22. the queue place) demonstrates that it is the actual border crossing processes which matter. Crossing times varied enormously despite most BCPs visited having significant numbers of vehicle processing lanes and these being well prioritized ( with special lanes for passenger coaches, perishable goods, low risk goods as identified in advance through existing (EU) or planned (Russia) web based pre arrival declaration systems, or through Queue Management Systems). Given the ranges of times reported for crossing, it is clear that other factors are more important. Crossing times from Finland to Russia are generally shorter than crossing times from Estonia to Russia, where on the Russian side there are a large number of sequential, and not simultaneous processes, which are currently required by Russian Customs. Many operators on the Finnish – Russian routes are Finnish registered, Russian owned companies, while drivers are Russian nationals employed by these companies. This suggests that there may be significant opportunities for making use of risk analysis based on greater awareness of the identities and operational and ethical standards of the operators, with more of them deemed to be low risk. These long crossing times from Estonia occur despite the queue management system there, and are consistent with the experiences of transport operators working between Latvia and Russia and Belarus and between Lithuania and Belarus. At the Russian Finnish border there were reports of relatively fast crossing times especially from Russia, whereas there were reports from drivers elsewhere (e.g. from Estonia into Russia) of delays of as much as five days in extreme cases. Factors given in relation to faster movements included the truck being empty and being subject to fewer checks outwards. Factors given as exacerbating delays were, not surprisingly, several sequential inspections (x rays, physical examination) and bad weather, delays due to shift changes and incorrect completion of import declarations, such as use of incorrect HS tariff codes. . The need to consider reductions in processes as a priority alongside the simultaneous monitoring of the management systems designed to allow significant reductions in the crucially time consuming procedure of physical inspection of goods is demonstrated by recent Latvian and Russian experience. Latvia has reported that a recent pilot scheme for submission of transit data to Russia via the NCTS SPEED platform ( the EU New Computerised Transit System for use by economic operators eligible to use Simplified Procedures) has not - yet - resulted in reductions to crossing times. This pilot cross border scheme has been carried out under an EU level project with Russia. Clearly, other factors are impacting on the apparent lack of positive results. This demonstrates the need to consider measures in the context of other developments and not in isolation. In relation to this Latvian – Russian example, the PT would therefore advise that, if adopted, our proposals be shared with the other participants in this pilot scheme. Given the great interest in shown in Estonia’s use of their GoSwift system for pre booking of vehicles’ place in BCP queues, and that system’s use in providing greater time for the carrying out of risk analysis, Estonian involvement would be logical in order to determine what the relevant additional factors might be. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 13
  23. 23. All BMAs stressed close cooperation between agencies within the BCP. Staff of Border guards, customs and phytosanitary and veterinary staff were generally co located or were easily contactable. In the EU States, essential private sector providers such as insurance brokers (for vehicle insurance) and banks were generally collocated in weather protected buildings. Times spent in the open at the BCPs themselves were usually not excessive, though in urban BCPs such as at Narva passport check queues at vehicle, as opposed to pedestrians, limited terminal space meant that significant numbers of passengers in coaches and private vehicles had to queue in the open. In the EU States visited, both road and rail passengers are normally cleared through border controls and customs controls in close sequence. However, there were examples of lack of awareness among some staff regarding the practical process of carrying out of mandatory (fingerprint) checks on non EU citizens and especially those requiring visas. The sending of enquiries into the SIS and the input of suspect documents often took time and the system was not always available. The PT had noted this when travelling into Poland from Belarus when deploying to the Field Visits, and these challenges were highlighted by Border Guards. Together with wider equipment reliability issues ( such as portable passport scanners for border guards and X ray scanners for Customs) the overall issue of proper training in the use of equipment and the need to take account of higher maintenance requirements – reflecting often severe weather conditions – and the need for significantly greater communications capacity to allow for speedier transmission times now and in the future - were seen as the key technical equipment issues. 7.1. Current sequential processes in Russia and Belarus The PT now produces in detail a diagram outlining the sequential processes applied in BCPs in Russia and Belarus in relation to freight movements. The principle of highly sequential, rather than near simultaneous processes also applies, to a lesser extent, to the movements of vehicle passengers. It is noted particularly that where batch systems are operated, with no movement until all participants in a group (e.g. of trucks) have been processed, movement is significantly slower than when continuous flow systems are applied. Different systems sometimes apply at nearby BCPs on the same border, such as at the Russian – Finnish border, where a batch system is used at Torfianovka whereas a free flow system is used at Brusnichnoe. This section leads naturally into the further comments at Section 8. below. The following Diagram shows border control process in Russian and Belorussian BCPs. The depicted process shows sequence of control procedures for trucks entering from the European Union to Russia/Belorussia. Exit from Russia and Belorussia includes the same steps, except that passport control is done first for vehicles entering to the BCP from the EU, and last – for vehicles going out to the EU. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 14
  24. 24. In Russian BCPs, Customs perform transport control and documentary control on behalf of the phytosanitary and veterinary inspection. In Belorussian BCPs all controls are implemented by separate agencies (i.e. Transport control by Transport inspection of the Ministry of Transport, Phyto and Veterinary controls by inspectors of the Ministry of Agriculture) Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 15
  25. 25. Diagram 1. Border control at Russian and Belarusian BCPs: entry from the EU Entry gate, from EU Document control area (Passport control line) Physical Inspection Area Exit Gate, to RU Preliminary document check (Border Guards) Immigration card Border control checklist (BCC) Physical Check (by BG) Passport control (by BG) BCC stamped by BG Suspected infection Medical Sanitary control Suspected infection No suspected infection (cargo, driver) No infection (cargo) Transport documentary and physical control BCC stamped by MSI Weights printed in BCC Customs prelim document check and vehicle examination Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 16
  26. 26. Entry Gate, from EU Document control area (Passport control line) Veterinary, Phytosanitary control needed Veterinary, Phytosanitary control not needed Physical Inspection Area Exit Gate, to RU Veterinary or Phytosanitary Control Suspected infection No infection (cargo) BCC stamped Customs documentary control Physical Inspection required (Customs or BG) Physical Inspection not required NII and Physical Inspection Transport docs stamped BCC stamped by Customs BCC and docs stamped by inspecting agency BCC with all stamps collected by BG Normally trucks stop in 3 or 4 control areas, depending on the applied types of control:  Entry Gate – all vehicles  Document control area – all vehicles  Physical Inspection Area – high risk vehicles  Exit Gate – all vehicles Entry Gate Entry to the BCP normally takes several minutes. Border Guards check driver and vehicle documents, and issue a Borer Control Checklist (BCC). This is some sort of a Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 17
  27. 27. runner, which needs to be filled with stamps and signatures of the control authorities. The BCC has names of controls, and fields for stamps and signatures Example of the Belorussian Border Control Checklist :------------------------------------------------------------------: : Контрольный талон № ______ : : : :Марка, регистрационный номер транспортного средства _____________ : : : :Фамилия водителя ________________________________________________ : : : :Количество пассажиров ___________________________________________ : : (прописью) : : : :Фамилия лица, пересекающего государственную границу в пешем : :порядке _________________________________________________________ : :_______________ "__" ____________ 200_ г. : : (время) (дата) : : : : ВЪЕЗД (entry) : ВЫЕЗД (departure) : :---------------:-------------:--------------:---------------------: : Зеленый канал :Красный канал:Зеленый канал : Красный канал : : Green channel : Red channel :Green channel : Red channel : :---------------:-------------:--------------:---------------------: : : : : : :---------------:-------------:--------------:---------------------: : Подпись : Подпись : Подпись : Подпись : : Signature : Signature : Signature : Signature : :---------------:-------------:--------------:---------------------: : Вид контроля :Время осуществления контроля:Отметка о прохождении: : : : контроля : :---------------:-------------:--------------:---------------------: : : начало : окончание : : :---------------:-------------:--------------:---------------------: :Пограничный : : : : :---------------:-------------:--------------:---------------------: :Таможенный : : : : :---------------:-------------:--------------:---------------------: :Автомобильный : : : : :---------------:-------------:--------------:---------------------: : : : : : :---------------:-------------:--------------:---------------------: : : : : : :---------------:-------------:--------------:---------------------: Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 18
  28. 28. Document Control After entry drivers park their trucks at the Border Guards documentary control area, pass passport control and drive to the weighbridge. This control takes several minutes, but with a queue can often take about one hour. Weights are printed on the back side of the BCC. Transport control can take more time for exit from Belorussia, because drivers often obtain driving permits to the EU countries in the BCP. Bilateral driving permits are purchased from the Transport control authority stationed at the BCP. This involves payment of the required fee in the bank (located in the BCP) and preparation of the road permit of the designated country (Poland, Lithuania, etc.) by the Transport authority. Both steps can take from several minutes (without queues) to more than an hour (with queues). Russian drivers obtain road permits outside of the BCP areas, normally through local offices of the Russian International Road Carriers Association (ASMAP). After weighting drivers park their vehicles in a designated location and arrive to the customs control terminal for documentary customs control. Phytosanitary and Veterinary certificates are checked here as well, either by customs (Russia) or by the Ministry of Agriculture inspectors (Belorussia). Documentary control and preparation of transit declaration take about half an hour. But often drivers have to spend much more time in the terminal because of queues. Waiting for 2-3 hours is considered normal, and waiting for more than 6 hours is not uncommon. The Customs documentary control zone has a number of customs inspectors. In BCP Torfianovka ( Russian – Finnish border) there are 12-14 inspectors in separate booths in for entry to Russia, and 3-4 inspectors for exit from Russia. There may be separate queues to inspectors (like in the BCP Torfianovka) or one common line (as at the BCP Brusnichnoe). The common line procedure should be encouraged everywhere. After document control, drivers can either get their documents stamped and allowed to drive to the Exit Gate, or may be required to drive to the inspection area. Physical Inspection Area Trucks can end up in the Physical Inspection Area for a number of reasons. reasons. As shown in the diagram 1 above, any of the border control agency may want to conduct detailed control checks. Sometimes trucks can be even sent back to the NonIntrusive Inspection (NII) by Border Guards at the Exit Gate. About 25% of trucks are sent to the Non-Intrusive Inspection by x-ray stationary or mobile units. This control takes about 15 minutes, if a driver is lucky. But because of the large proportion of trucks sent to the NII, trucks have to queue for the NII for many hours. If control authorities are not satisfied by the results of the NII control, more detailed physical inspection, often with full or partial unloading can be required. When unloading Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 19
  29. 29. is required, this results in delays for days. To minimize delays consignors can buy unloading services of customs terminals (managed by ROSTEK). Exit Gate After several hours (if very lucky) or several days, trucks arrive to the Exit Gate. The border guards verify that all documents have been checked and all required controls have been completed. The Border Control Checklists are collected, and the departure time is recorded. 8. Deficiencies and discrepancies in actual Border Control management practices This Section has reached its assessments based upon its own observations in the Field Visits, and from the data supplied by the BMAs in their answers to the Questionnaires, presented in Appendix B.. It particularly addresses issues in 2.1. a and b and d and e. of the TOR, i.e. issues which are generic as they impact on most other BCP management issues. All BMAs were open and honest regarding the factors which limit the effectiveness of border controls in ensuring the safe and speedy cross border movements of goods and persons which maintaining proper border controls. The difficulties were made quite clear to the PT and were usually visibly obvious. While there was no single reason for extensive delays, the dramatic differences in crossing times for road freight, especially, made it clear that several factors were particularly important. Rail issues – passengers Rail passenger movements were generally reported as being achieved satisfactorily, without undue delay. The checking of passports on board long distance trains or in wellappointed passenger terminals which offer protection from the weather (e.g. Narva and Koidula in Estonia regarding trains from St. Petersburg and Moscow respectively, and at Terespol in Poland from Moscow and Minsk) involves processing times which are acceptable given the length of the journeys. However, Estonian Border Guards advised there concern about the risk of delays to both road and rail passengers in the event of visa relaxations between the Schengen Area and Russia and Belarus. Therefore the Project has noted in the Conclusions and Recommendations at Sections 17, 18 and 19 below, that the introduction of more and higher reliability mobile passport readers should be actively considered and that consideration should be given to the introduction of Advance Passenger Information (API) for long distance trains and coaches. The inconvenience of this to passengers, and possible extra costs to them and the road and rail operators would be at least partially offset if such travel were able to use priority crossing procedures, reducing overall travel times. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 20
  30. 30. Rail issues – freight Rail freight movements were generally reported as being achieved satisfactorily, without undue delay. The general effectiveness of rail freight procedures is described in detail at Section 15. below. In general, the nature of rail freight is well known in advance to the BMAs of export, import and transit countries. Customs clearance is normally not carried out at the border. There are therefore seen to be no major challenges in relation to rail freight, and the capacities examined at, for instance, the Polish Belarus and the Estonian – Russian and Latvian – Russian borders appeared sufficient for current and expected traffic levels. However, following the carrying out of the Field Visits, Polish colleagues did point out to the PT that there were significant opportunities for streamlining procedures through greater use of the CIM / SMGS Consignment Note, which from experience on key east west freight routes, has been a major step forward. This matter is suggested as a key issue for consideration in future phases following on from this project. This general effectiveness offers indicators as to what needs to be done in relation to improving the admittedly more challenging situations regarding movements of passenger vehicles, including coaches, and freight. Generic road traffic issues Queues varied greatly, with there generally being little link between the levels of road network and BCP lane capacity and the levels of delays. At the risk of stating the obvious, capacity increases on one side of the border lost much of their effectiveness if there were no physical capacity increases on the other side (e.g. at Koidula – Pechory/ Kunichina Gora between Estonia and Russia, where the full benefit of the introduction of terminals and queue management on the Estonian side will be limited until the ongoing Russian vehicle park upgrades are completed). Major examples of this situation were at Medininkai – Kamenny Log (Latvia – Belarus) and Terehova – Burachky (Latvia – Russia) and Koroszczyn ( Kukuryki – Kozlowiczy) freight and Terespol – Brest passenger vehicle crossings from Poland to Belarus. The levels of delays were very severe at all these sites, with freight queues especially being in excess of 10 kilometres and crossing times being well over 24 hours in some cases. As previously mentioned, several drivers spoke not of hours but of days when describing delays. Extensive funding has delivered significant new road capacity in Poland in the Terespol and Koroszczyn area, while capacity is less extensive at Medininkai and is limited at Terehova (although upgrades have started on the regional Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 21
  31. 31. network). The significant on BCP terminal facilities available at Koroszczyn are of limited support to transport operators as the queues to get to the terminal are so long. Road issues – freight These observations made it clear that the main opportunities and challenges relate to the number and effectiveness of processes required to cross. While the introduction of queue management systems such as that introduced in Estonia has, as previously noted, led to much more comfortable conditions at vehicle terminals for truck operators especially, it has not necessarily reduced crossing times. Given that the delays are much greater for trucks, it is clear that the solutions going forward need to involve the introduction of fewer and simpler processes. These need to include the reduction on the CU side in the number of physical checks ( e.g. x raying and physical examination of cargo, and to a lesser extent weighing which is more automated) and , accordingly, much greater use of Risk Analysis systems and procedures for automated clearance with post clearance audit checks away from the border. Concern was raised by several operators, and in the media, that the June 2012 introduction of compulsory electronic submission of customs preliminary information in advance of arrival would actually lead to longer delays, at least in the short term. Economic operators’ unfamiliarity with the new system might lead to increased numbers of rejections, with vehicles being turned back or subjected to higher levels of physical controls. Therefore, it is suggested that there is close cooperation between Russian and Belarus Customs and their EU counterparts in order to share views on what degree of licence can be allowed to operators for mistakes which are not felt to be significant. EU experience in relation to the introduction of its own system would be likely to be highly relevant. The use of free flow systems as opposed to batching is strongly recommended. Delays caused by batching (delays which are multiplied when applied to several processes, such as passport control followed by Customs clearance ) were stressed by several BMAs as a major cause of delays. See Section 10. below for a detailed description of the benefits of free flow systems. Road issues – passengers in private vehicles and in coaches On the road borders, both sides face a set of challenges that, though in themselves are only minor, accumulate to require substantial resources and therefore are a cause of delays. All countries in the Schengen zone face challenges in relation to illegal migration and the proper processing of asylum seekers and the use of false documents. There was a clear need seen to coordinate on a regional basis the sharing of subject specific information on refused persons and the use of false documents. There seem to be weaknesses here. Persons refused entry into the EU in Estonia and who were returned to Russia were identified as attempting to enter into Finland a few days later, with the inevitable result that they were refused entry there. This problem is worsened by the fact that, though these persons are attempting to cross illegally into Europe, their presence Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 22
  32. 32. in the CIS is fully legal and as long as they do not actually attempt to cross the border outside of BCP's, there is nothing that can stop them from moving around. Furthermore, there are also challenges for the EU states regarding smuggling of alcohol, cigarettes and road fuel from Belarus and Russia where prices are much lower. These are not risk areas for the CU but the need to carry out significant numbers of physical examinations using risk analysis and spot checks means that delays can occur at EU entry points. There are severe practical limitations to what can be done to reduce these problems. It is suggested that all the States in the Partnership consider maximizing the use of Border Guards to carry out Customs checks (i.e. first line physical checks of vehicles), as several already do. Where BCPs do not yet have access to central nationwide databases holding ANPR data, this should be introduced and considered for extension to link several states. Such access would potentially increase the effectiveness of risk analysis by identifying suspiciously frequent movements across a border, where different BCPs are used in attempts to allay suspicion. At the CU side, a major source of delays is the need for filling in a customs declaration to fulfill the requirements in relation to temporary importation of (foreign) motor vehicles. At present, the source of identification of a vehicle movement from an importation or temporary importation point of view is the Customs declaration, the completion and delivery of which does take time. Up to 10 minutes processing time by customs has been noted4. Consideration should be given to evaluating other means of recording the import or temporary import, perhaps taking the example of Ukraine, which has abolished the use of a manual Customs Declaration. The coordinated national and transnational use of ANPR data in relation to vehicle movements, especially passenger vehicle movements would potentially have significant benefits for the Customs Union. The centralization of movement data would also make it easier for Border Guards to cooperate with customs in identifying the passengers in, and particularly the drivers of, vehicles of potential interest from both the perspective of identifying the smuggling of goods. Such measures would also be consistent with the general viewpoint of the PT that basic customs checks be undertaken by Border Guards as improvements in passport integrity technology frees up resources for other purposes. The PT noted that at several BCPs Customs and Border Guards worked exceptionally closely together, to an extent that they might almost be regarded as one service, so such measures are considered feasible. 9. Cross border cooperation between Border Crossing Points Management Agencies 4 At the Belarus – Poland border, when the vehicle is crossing the border at the particular crossing for the first time. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 23
  33. 33. This part of the Report addresses the requirements of Section 2.1. d and of the TOR, i.e. communication and common decisions and personnel knowledge. The PT accepts that its comments here must be considered as being largely based on the views of EU Member States BMAs. With the exception of the meeting with Belarus State Customs Committee at Koroszczyn terminal and the Kukuryki and Terespol BCPs in Poland in April 2012 the PT was not able to meet BMA representatives from the CU, although it did seek to keep them informed through the host BMAs before, during and after the Field Visits. The PT’s assessment of the situation regarding cross border cooperation between BMAs is drawn from our observations during the Field Visits and the cross border cooperation section of the Questionnaire. While the effectiveness of such cooperation is a separate issue from such internal cooperation between the BMAs of a single country, the PT believes the two need to be looked at together. There are considerable bases for developing operational and tactical (case by case) cooperation, especially regarding increasing the quantity and particularly the quality of risk analysis. The operational / organizational issue of regulating traffic flow between BCPs used by Belarus and Polish Customs should be considered for adoption elsewhere, to the extent that it is not currently adopted. There are well established 24/7 procedures overseen by senior officers and their deputies on both sides which ensure that vehicles are only released from the truck BCP when sufficient space is available for them to cross. This does not in itself speed up clearance times, but does allow drivers to rest to some extent and to make use of refreshment facilities. However, given the sheer volume of freight traffic at Koroszczyn ( Kukuryki-Kozlowiczy), even with this system there were still delays of 8 to 10 hours (and in some cases of up to 24 hours) in the area between the Polish controls and the Belarus controls, i.e. after the Polish terminal. There were no refreshment facilities in this area, which clearly demonstrates the sheer scale of the challenges on this key east – west route. There were, at all BCPs visited, arrangements whereby specific BMA staff and their deputies or replacements had direct responsibilities for exchange of information on operational and tactical matters, staff often referred to as Border Delegates. There were normally regular formal meetings on topics of mutual interest, especially on organizational issues. These were typically monthly or quarterly, with other meetings held as necessary. “Hotlines” were established at several BCPs, such as at Koidula in Estonia for contact with Pechory / Kunichina Gora BCP. In that case, given the very close cooperation between Estonian Border Guards and Customs, the link was in effect for all services. There have also been cases of short term deployments of BMA personnel between BCPS. In April 2012 Russian Border Guards were due to be based at Terehova during Operation ZAPAT, a joint exercise against illegal migration. In June 2012, there will be extended cooperation between all the BMAs of Poland, Belarus and Russia regarding ensuring speedy processing of football supporters travelling to Poland for the European Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 24
  34. 34. football championships. These special measures will, the PT was informed, involve some forms of API use. The PT has noted these positive developments in the Conclusions and Recommendations at Sections 17, 18 and 19 below, and suggested that they be developed further with more special joint cross border operations, the results of which should be shared with all other States in the Partnership and not merely within the States taking part in a particular exercise. The information exchanges through the methods of formal regular meetings, and hotline notifications on urgent organizational (traffic flow) or tactical situations do have some gaps. All BMAs and especially Customs pointed out that there was a need to coordinate cooperation in relation to the considerably different Customs risks situations for the EU states and the CU states regarding smuggling of excise dutiable goods and drugs into the EU, and the undervaluation and misdescription of consumer goods into the CU. It is the view of the PT that both automated exchanges of data enabling the accuracy of export and import valuations and regular operational meetings should take place. These operational meetings would seek to build upon the automated exchanges of core declaration data by discussing ways of dealing with particular tactical cases of mutual concern, within the context of dealing with the generic challenges, rather than simply dealing with each case as it comes. In view of the importance of this issue, it is now discussed further, immediately below. 9.1 Automated exchanges of Information on Customs movements within the context of operational level coordination between Customs Services The following comments seek to make proposals which strike a balance between the desirability of reducing passage times by implementing the provisions of the TIR Convention regarding the free flow of goods, while ensuring that the very real revenue and public protection issues of concern to the CU and the EU are taken into full account. This section particularly addresses the requirements outlined in the TOR at 2.1. (b) and (d). interoperability of technologies and procedures and communication and common decisions. In relation to the clause requiring the avoidance of detailed scrutiny of goods at an external border customs post, the TIR Convention allows in accordance to Article 5 (2) of the Convention: “ prevent abuses, Customs authorities may in exceptional cases, and particularly when irregularity is suspected, carry out an examination of the goods at such offices” Clearly, systems need to be in place to prevent such abuse. The PT has therefore recommended that extensive and early efforts be taken to introduce long term automatic sharing of risk profiling information and the mutual recognition of Authorised Economic Operators between Schengen Area states and Customs Union states. It is recognised that there are domestic data protection issues here and that there is also the need to recognise key national interests in all states regarding the regulation of law enforcement agencies IT systems. However, the introduction of international good Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 25
  35. 35. practices in relation to making significant reductions in the number of Customs processes, and in reducing physical inspections is consistent with government and Customs Service policy in the Russian Federation and, by extension, with that of its Customs Union partners. A recent speech by President Putin, while still Prime Minister, highlighted the significant reduction in the number of Customs processes as a key priority for Customs to implement. Equally, the Russian Customs Service regularly publishes figures regarding the percentages of freight movements which are subject to intensive (physical) examinations. The publication of these figures implies recognition of the need to move to a more developed risk management system. Such risk management systems inevitably benefit significantly from the timely exchange of information between neighbouring states, especially those which are the points of entry to or from their respective customs unions. Accordingly, the PT highlights in its Recommendations the need for enhanced exchanges and the carrying out of special joint information exchange exercises, and the long term deployment of staff between states in relation to both the operational and “IT technical” aspects of information exchange. The PT believes that the carrying out of such recommendations should be notified before, during and after the results to all Customs agencies of the Northern Dimension Partnership. While we believe that all states would benefit from the carrying out of such recommendations, we would especially suggest that there be such exchanges between Poland and Belarus in view of the volume of traffic, and between Lithuania and Belarus in relation to transit traffic between the Kaliningrad region of Russia and Russia itself. The nature of the information to be exchanged would, of course, be matters for the BMAs themselves but we suggest that examples would include high consumer demand electronic goods imported into the CU and which are felt to be prone to serious undervaluation, as well as capital goods which may be free of Customs duties and may therefore be misdescribed, with the goods actually being different and subject to duties. In relation to exports from the CU, EU MS may be able to help regarding the verification of the integrity of the reported importers of goods which are suspected of being vulnerable to false export fraud from the CU. But we suggest that the key ways of reducing physical inspections would be to agree on criteria for mutual recognition of Authorised Economic Operators and the monitoring of their future compliance. Given that transport operators reported that clearance times were relatively short when entering or leaving Finland, there would also be opportunities for comparing the reasons for this with challenges experienced between Russia and Estonia and Latvia respectively. 10. The logistics of movements of passengers and goods at Border Crossing Points Introduction This section of the Report addresses particularly the requirements of Section 2.1 c of the TOR – terminal logistics. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 26
  36. 36. It is common practice to use a so called “batch” system to the flow of especially cargo vehicles through a BCP. Though not apparent immediately, this can have substantial influence on the overall throughput in a 24 hour period in comparison to a flow system due to delays caused by bottlenecks5 caused by infrastructure. This section attempts to explain and visualise the practical implications of the use of one or another system. The relative benefits of the “batch” system are summarised in the Table at the end of the Section. The common process To illustrate the difference, a simplified but not completely unusual process is taken as an example. The process concerns the following processes:  weighbridge,  customs clearance The processing duration for the weighbridge is 5 minutes, while the customs processing takes 20 minutes, but there are 4 windows, allowing for 4 vehicles to be processed at the same time. For simplicity of the explanation, it is assumed that there are no time delays going from one process to the other, or there are no queue's anywhere. In addition, the calculations reflect current practice as reported by drivers, that the next batch is only allowed into the BCP when the entire previous batch has been processed and has left the BCP at the other end. We do not however make the assumption that, like in normal practice for batch systems, all vehicles in the batch will first need to clear the first process before the second process can start, but we assume instead that the every vehicle clearing the first process can immediately proceed to the second process. 5 A bottleneck process is a process of which the throughput capacity is the smallest of all processes at a BCP. Most likely, these are processes that require specific pieces of hardware that are expensive to acquire and of which there is often only one. Managing the bottleneck, by for example ensuring that its process is only used in particular cases when justified by identified risks is one option that comes at very little or no cost. Alternatively, but already far more expensive is to increase the quantity of equipment available for the bottleneck process. More on managing bottlenecks can be found in the book “the goal” from Ely Goldrat. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 27
  37. 37. batch size 10 time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse process duration 1st 2nd 3rd 4th 5th 6th 7th 8th 9th 10th Weighbridge 5 5 10 15 20 25 30 35 40 45 50 Customs 1 20 Customs 2 20 Customs 3 20 Customs 4 20 time lapse from begin first process 20 20 20 20 20 20 25 30 35 20 20 20 40 45 50 55 20 60 Maximum process duration for individual vehicle: Time required to process 10 vehicles: 65 70 70 Minutes 50+20 = 70 minutes Continuous flow time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse process duration 1st 2nd 3rd 4th 5th 6th 7th 8th 8th 10th Weighbridge 5 5 5 5 5 5 5 5 5 5 5 Customs 1 20 Customs 2 20 Customs 3 20 Customs 4 20 time lapse from begin first process 20 20 20 20 20 20 25 25 25 20 20 20 25 25 25 25 Maximum process duration for individual vehicle: Time required to process 10 vehicles: 20 25 25 25 Minutes 50 + 20 = 70 minutes As can be noted from above, the application of a batch system substantially increases the waiting time for individual vehicles in the worst case scenario, in the example, it is 70 minutes for the batch processing versus 25 minutes for a continuous flow system. With regard to the duration of the total process (e.g.) from the total of 10 vehicles being processed, in this particular case, there is no difference in duration, for each situation, the total time to process 10 vehicles is 70 minutes. However, the numbers hide a more important difference, which does severely affect the total capacity to process vehicles in a certain period of time. In case of the batch processing approach, the there are several work stations that do not have any work for a certain period of time either before the first customer arrives (in case of customs) or after the last customer has left, such as in case of the weighbridge. As time dissipates when it goes forward, the lost production cannot be recovered easy. In the above example, the processing capacity of a continuous flow system would be at least 20%, but up to 40% higher than in the batch processing approach. If we once more take the example, in case of batch, the throughput in 70 minutes would be 10 vehicles, regardless what happens. In case of the continuous flow, the maximum throughput that can be achieved in the same 70 minute period at the bottleneck (the weighbridge) would be 14 vehicles, an improvement of 40%. This would then also provide for a more constant workflow at the customs posts and increase its capacity there through reducing idle time. Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 25 Page 28
  38. 38. Concluding, a critical assessment is essential of all processes at a BCP over a period of to identify the bottleneck processes6 . There is no single process that is solely or even very largely responsible for delays, though the PT felt that the replacement of batch systems with flow systems was perhaps the biggest step which could be taken. Table Batch v Flow Batch size st 10 st nd rd th Process duration, min 1 2 3 4 Weighbridg e 5 5 10 15 20 Customs 1 20 25 Customs 2 20 Customs 3 20 Customs 4 20 Total time in the BCP th Time lapse from arrival of a truck at the BCP (from 1 to 10 ) th th th th 6 7 8 25 30 35 40 45 45 10 50 65 50 35 70 55 40 30 th 9 30 25 th 5 35 40 60 45 50 55 60 65 70 Maximum duration of stay of a vehicle in the BCP is 70 minutes Time required to process 10 vehicles is 70 minutes Total number of vehicles in the BCP area at the same time is 10 Batch size st 1 st Process duration, min 1 Weighbridg e 5 5 Customs 1 20 Customs 2 20 Customs 3 20 Customs 4 nd rd 20 th 25 Total time in the BCP th Time lapse from arrival of a truck at the BCP (from 1 to 10 ) 2 5 3 5 4 5 th 5 5 th 6 5 th 7 5 5 25 25 5 25 25 th 10 5 25 25 25 25 th 9 25 25 25 th 8 25 25 25 25 25 25 25 25 Each vehicle is processed within 25 minutes since arrival at the BCP Time required to process 10 vehicles is 70 minutes 6 Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1 Page 29