1.  The particular focus of the Treasury Sub-Committee, as set out in the first two of the three indents of the call for evidence, appears to give a distinct bias to the investigation. It is hoped that the terms of reference for the inquiry are not concentrated on these topics, to the detriment of the whole picture.

  2.  I work for Nissan Motor Manufacturing (UK) Ltd, with particular responsibility for Customs and Excise matters relating to imported goods, a position I have held for 10 years. The views expressed in this document are mine and do not reflect any opinions espoused by my employer. I am actively involved in Customs related trade associations, and several committees organised by HM Customs & Excise and other governmental agencies related to Customs activities.

  3.  It is my opinion, taking an holistic view, that HM Customs & Excise are doing a good job. They have set themselves the target of being the best in the world, and I suggest that when anyone considers "who is best", that HM Customs and Excise must be considered. On that basis they are achieving their objective, but to remain one of the best, HM Customs & Excise need to work hard to improve their regimes and activities.

  4.  My experience with HM Customs & Excise has been favourable, though I have not always achieved what I had hoped to, the high proportion of activity has lead to benefits for myself and for Customs.

  5.  HM Customs & Excise have two main constraining factors—legal and financial.

5.1  The legal requirements fall into two categories, European and Domestic:

—  Domestic: There appears little that can not, and has not, been achieved in this environment—where parliamentary time has inhibited immediate improvements, other measures are undertaken.

—  European: This area is fraught with difficulties, especially when many of the representatives of other Member States do not understand the law over which they are making decisions. [It could be seen that it epitomizes the maxim that all political decisions are wrong. If a valid reason or compromise is practical or expedient, then it is quoted, if it is a political decision it therefore follows it is the wrong decision]

5.2  The financial constraints should be well known to the Treasury Sub-Committee and are under constant pressure, as evidenced by the Fundamental Expenditure Review and the significant reduction of officers.

  In light of the thrust of this inquiry the reduction of resources would seem to be the most significant.

—  Early retirement leads to loss of experience and a significant training requirement, which at best can only be selective.

—  Lack of resources indicates that known criminal and fraudulent activities are prioritised for the greatest effect, and local opinion sees wrong doers being left to pursue their illegal trade.

  6.  The financial pressures on HM Customs & Excise were recently brought into sharp focus by the reported insistence of the Treasury, that the impact of the Euro, and the creation and setting up of dual currency systems and operations, must be completed within existing budgets.

  7.  The Joint Customs Consultative Committee is the conduit through which most policy is communicated through to the trade. This forum, however, through its openness, leads to discussion on and expectation of many subjects, the resources for which are not always available to satisfy these expectations. This has lead to other forums, which deal with greater detail and try to ensure that development work is conducted in a structured manner, to meet the international obligations of HM Customs & Excise and the expectations of HM Government and the Trade in general.

  8.  A recent detailed examination of the operation of Inward Processing Relief (IPR) was so well received by the Commission DGXXI, that the examining working party were asked to examine and review all procedures where matters having economic impact were involved.

  9.  HM Customs & Excise have embraced the new philosophy of co-operation. The practice has changed from "catching out" the mistakes of inherently honest traders, to one of assistance, especially during formative times, though the reckless and fraudulent should expect little mercy. HM Customs & Excise are batting on the side of "UK PLC".

  10.  Customs' Charter Standards were originally set so as not to embarrass the Department, by using figures near to the Lowest Common Denominator. I feel that the time has now been reached when those standards should be reappraised, with year on year improvements being published. Internally each office being asked to establish its own improvement plans. Our best customers are the most demanding ones, as they help us to improve.

  11.  It is my opinion that the focus of the treasury sub-committee, as alluded to earlier, is regarding subjects that have their roots in the social structure of this country. The removal of the "Black economy" and the elimination of commercial smuggling, are very laudable ideals, but cannot be realised, containment is the only viable option.

  12.  Although I am not desirous of giving evidence in person, I will do so if required by the Select Sub-Committee.

13 August 1999