Registration of trailers after 29th March 2019

The UK has not traditionally required the registration of trailers. A trailer unit, whether a large commercial unit or smaller private use trailer, has only needed to display the plate bearing the registration mark (commonly known as the registration number) of the registered towing vehicle. Trailer registration is commonplace throughout much of continental Europe and it is often compulsory to display the separate registration number of the trailer.

From 28 March 2019, the same date as the 1968 Convention comes into force for the UK, it will be prohibited to use unregistered trailers in certain categories on international journeys to, or through, a foreign country that has ratified the 1968 Convention. This prohibition applies to commercial trailers with a gross weight over 750kg and all trailers with a gross weight over 3,500kg. Unregistered trailers may also be subject to enforcement action while abroad from this date.

The registration system is operated by the Driver and Vehicle Licensing Agency (DVLA). The fee to register a trailer is £26. This scheme will be introduced regardless of the outcome of negotiations with the EU as the 1968 Convention will be coming into force for the UK in any event. Detailed information can be found here on the Government website.

Update from the Thoroughbred Industries Brexit Steering Group

The British Racing and Breeding industries, represented by the Thoroughbred Industries Brexit Steering Group, hope that a Withdrawal Agreement between the United Kingdom and European Union can be reached in the coming weeks. Any implementation period following a withdrawal agreement would, for example, see a continuation of the current free movement of thoroughbreds between Britain, Ireland and France until at least December 2020 with work proceeding on longer-term arrangements beyond any such period. However, we are making no assumptions and therefore ruling out no scenarios.

As such, we are increasing our preparations for the event of the UK’s departure from the EU on 29 March without a deal. We will be communicating further and formally with our stakeholders and participants over the next month with practical guidance and advice, and continue our regular contact with UK Government, colleagues elsewhere in the horse sector, and the Irish and French thoroughbred industries, in particular.

We have had productive discussions with the Department for the Environment, Food and Rural Affairs (Defra) in the last two weeks and are encouraged by the level of ‘no deal’ planning in place.

An online hub to provide guidance to industry participants on what to do as the UK leaves the EU has been set up on the BHA website (https://www.britishhorseracing.com/regulation/brexit/), collating industry relevant information which is regularly updated as further advice from government departments becomes available.

Julian Richmond-Watson, Chairman of the Thoroughbred Breeders’ Association (TBA) and of the British Thoroughbred Industries Brexit Steering Group, said:

“With continuing uncertainty around the outcome of the Brexit negotiations, it is only right that the thoroughbred industries prepare for all scenarios, including a No Deal which we hope can be avoided. We have been very encouraged by our engagement with Government around preparations for a No Deal, and endorse its stance that current systems for horse movement into the UK will continue in these circumstances.”

Thoroughbred movement

We would reiterate that the UK Government has made clear that in the event of no deal, thoroughbreds will still be able travel freely into the UK from Ireland and France, as current systems will be replicated. These current systems under the pre-existing Tripartite Agreement work well and have evolved over decades. They facilitate and foster growing international competition and allow for smooth and efficient trade, most importantly prioritising the welfare of our horses and reflecting their high health, high welfare status.

We fully support and lobbied for this position adopted by the UK Government as the pragmatic and right thing to do and to minimise unnecessary disruption.

The UK’s third country status post-Brexit

We have recently had confirmation from the Government that if the UK does leave the EU without a deal then it will be treated as a third country, and in order to be prepared for all possible outcomes, the UK Government has submitted its application for listing as a third country to continue exporting live animals and animal products to the EU after Brexit. The Commission’s recently published Contingency Action Plan states that: “On the basis of the EU veterinary legislation, the Commission will – if justified – swiftly ʻlistʼ the United Kingdom [as a third country], if all applicable conditions are fulfilled, so as to allow the entry of live animals and animal products from the United Kingdom into the European Union”.

We understand that the technical discussions between Defra officials and the European Commission are currently ongoing and are hopeful that they will reach a positive and timely conclusion. Upon the UK achieving such listing the process for thoroughbreds returning or travelling to, for instance, Ireland or France, will become clearer, and the relevant guidance will be provided.

Transport

The Government’s priority continues to be to secure a deal which maintains the current, liberalised access arrangements for transporters, and in the meantime is working to ensure the UK is ready for all exit scenarios.

There was a significant concern within the industry that the administrative barriers that the EU could apply for transporters as the UK becomes a third country would add to the challenges with the movement of horses in the event of a no deal. The European Commission however has recently published proposals that would allow UK hauliers to continue carrying goods into the EU until the end of 2019 if there is no deal, without the need for an ECMT permit. The UK Government has welcomed the proposal as a positive step forward for UK hauliers and intends to reciprocate.

Additional requirements for road travel within the EU for UK citizens and registered companies remains likely, whether in the short or medium term, and seeking clarity on the practicalities for companies and individuals transporting thoroughbreds continues to be a priority area for the Steering Group.  We will provide a further update in this area as soon as there is greater clarity.

Stud Book Recognition

As of 1 November 2018, a new EU regulation came into place for horses coming from Non-EU countries. This legislation states that, if a Stud Book or Breed Society from a third country is not listed as being permitted to trade with the EU, horses of that country are not allowed to enter any EU country or to be registered in that country.

Weatherbys has lodged an application with Defra for submission to the EU Commission for the General Stud Book to be recognised by the EU Commission and to be added to its list of breeding bodies. In requesting a listing, we agree to respect the legal right of entry in the General Stud Book of Thoroughbreds from stud books in EU Member States.

European Union citizens working in the British thoroughbred industry
The UK Government has launched a website outlining details of the EU Settlement Scheme for European Union citizens, and their families, to continue living in the UK after 30 June 2021 with either settled or pre-settled status. The application process opens in full on 30 March 2019 and further guidance will be provided in advance of that date.

The Steering Group has been making representations, with the support of the Department for Digital, Culture, Media and Sport (DCMS), to the ongoing Migration Advisory Committee process to ensure as far as possible that the requirements of our industry of the future UK immigration system are satisfied. This includes a submission to the recently closed consultation on the composition of the Shortage Occupation List to apply for the Racing industry to be returned to the list. If that were to happen, it would mean that those wishing to come to the UK to work in the racing industry could be processed far more quickly.

Notes to Editors:

1. Useful links

UK Government – Settled and pre-settled status for EU citizens and their families

New legislation for horse transport in France

The French Government has recently introduced legislation requiring that foreign truck drivers whose journeys either begin or terminate in France carry a statement with them that during their professional stay in France they are paid the French statutory minimum wage (around £8.18 at current exchange rates.) Drivers are required to carry this document (an attestation of posting) with them and that each company posting drivers in France must have a French authorised agent.  The EU is currently challenging the introduction of the law.

To what extent this affects British-based trainers sending their boxes with drivers to France is unclear from the guidance currently available and in most cases the overall journey will not begin or terminate in France.

It would be advisable to ensure that work schedules show that the journey is starting and terminating in the UK and the TPA Docom should also reflect that.   We will continue to research how the legislation is interpreted; if any trainer has any contact with the French authorities in relation to this then please let us know.

Forthcoming road tolls in Belgium

Trainers who manage their own transport through the continent will be interested in forthcoming road tolls in Belgium. A representative of Motis is giving a presentation on the subject at the Racehorse Transporters Association AGM at 10.00am on Wednesday 13th April in The Lonsdale Room of The Rutland Arms Hotel, High Street, Newmarket.

Motis are able to supply a new toll box that will cover Belgium, France, Spain & Portugal. This will be vehicle / registration specific. There is a monthly rental charge of €6 per month but no administration fee or big up-front deposits required.

A Belgium toll box has an initial deposit of €180 per box (Deposit for equipment & initial usage). €135 will be rebated if the box is returned in good order. The box can be swapped to different vehicles but this must be registered online. It will be the operator’s responsibility to ensure the registrations match the vehicle. If the registrations do not match, there will be a fine from the Belgium Authorities.

Is your horse box over weight?

Trainers are reminded to be vigilant to maximum vehicle weights for their horseboxes as many could be unwittingly overloaded on a regular basis. Recent inspections close to Chester and Nottingham racecourse have resulted in fines for trainers particularly for the small 2 horse boxes. The manufactures or ministry plates (usually fixed to the inside of the passenger door frame) specify the weights that should be adhered to on the vehicle. These weights must not be exceeded on public roads and it is important to also appreciate that these weights include the driver, passengers, horses and fuel. Please see the British Horse Society’s guide for horse box and trailer owners here for further information.

Beware stowaways in Calais

A recent article in the Horse and Hound highlighted increasing problems for drivers resulting from migrants in Calais trying to stowaway on horseboxes.

If reasonable measures are not taken to secure and check vehicles before they embark for the UK, a penalty of up to £2,000 may be imposed for each stowaway.   The vehicle’s driver, owner or hirer can be fined.

The Home Office has advice for drivers and their employers which can be found at https://www.gov.uk/secure-your-vehicle-to-help-stop-illegal-immigration

List of approved shippers for new horse movement arrangements

Under the new Tripartite Agreement (TPA) for movements of horses between Britain, France and Ireland, only approved shippers can use the TRACES system to issue the necessary travel documents – DOCOMS. Some trainers have applied to the BHA for authorisation to use this system to generate their own DOCOMS. Other trainers need to use an approved shipper and inserted below this post there is a list of approved shippers with contact details.

BHA Approved Shippers Commercial