Written evidence submitted by Getlink Group (EEE0018)

 

European Scrutiny Committee EU Entry/Exit System Enquiry

Getlink Group

Getlink manages and operates the Channel Tunnel between Folkestone and Calais. Its subsidiary, Eurotunnel, operates the Channel Tunnel and the LeShuttle car and truck carrying shuttle service between Folkestone and Coquelles. Eurotunnel also gives passage to high-speed passenger trains and rail freight services. These activities are operated under a long-term Concession between Eurotunnel and the governments of the United Kingdom and France.

Our LeShuttle services provide a vital cross-Channel link for passenger and freight journeys. Here are a few headline statistics:

 

of the UK’s just in time supply chain, including high value and perishable goods.

Our key recommendations

1.      It is essential that the EES app proposed by the European Commission is developed quickly to allow for testing in advance of the system’s introduction and to enable the lengthy enrolment phase at the border point to be shortened;

2.      A solution for EES enrolment needs to be found for the Port of Dover, which currently lacks the space needed to construct the necessary infrastructure. Traffic queues from the port risk causing delays to access to the Channel Tunnel;

3.      To ensure smooth implementation of the UK ETA requirement for EU nationals, the UK government should seek to avoid any potential clash with the introduction of EES and ETIAS systems; and

4.      The UK Government will need to run a widespread awareness campaign, to ensure that passengers are aware of the new requirements for travel into the EU and the need to complete remote data entry via the app.

Questions

1.      The EU first proposed an entry/exit system for the Schengen Area in February 2008. How have proposals for its introduction developed over the last 15 years?

The European Commission presented the proposal for EES on 6 April 2016 as part of the revised Smart Borders Package. After negotiations with the European Parliament and the Council the co-legislators reached an agreement in July 2017. The EES Regulation, together with a targeted amendment of the Schengen Border Code, were adopted on 20 November 2017 and entered into force on 29 December 2017.

EES was originally due to be launched in 2022, however during this period the scheme has been subject to multiple delays and uncertainty. Its implementation was rescheduled for May 2023, then it was pushed back further until the end of that year. The system is now expected to start operating in October 2024, provided all 27 EU Member States can demonstrate a sufficient level of technical readiness for the changes, according to the Commission.

Getlink is preparing for the introduction of the system in October 2024 as currently scheduled, with groundwork underway to reconfigure the Eurotunnel terminals in Folkestone and Coquelles for the purposes of EES enrollment and processing. Kiosks will be installed in each of the designated parking bays early in 2024, with systems testing scheduled to take place over the summer.

2.      Are there currently any other domestic or transnational systems either planned or in operation that are similar to EES?

The introduction of EES is part of a broader trend towards increased security and digitisation at international borders. Similar systems requiring both biographic passenger information and biometric data capture are either established or being trialled in other countries around the world, including the United States, Canada, Australia and Singapore.

3.      The EU’s Entry/Exit System was initially due to be introduced in 2022. What challenges do the EU

and its Member States face in ensuring the full introduction and effective operation of EES?

The introduction of EES requires EU Member States to develop complex technical infrastructure involving biometric technology and compatible supporting databases. It also requires interoperability with existing systems and significant investment in border technology. Border agencies also need to consider staffing levels, as more border agents will be required to monitor and verify enrolment in the system.

The scale of the infrastructure required will vary by location and between Member States depending on the volume of third country travellers they expect. Some southern European states are likely to experience large numbers of travellers from third countries during busy summer months, while eastern Member States will need to prepare for land crossings on the EU’s external border to the east. This also means the relative levels of preparedness will likely vary between Member States.

4.      What challenges will ‘third country’ (non-EU Member State) ports and operators face servicing destinations in the Schengen Area when EES becomes fully operational?

Third country ports and operators will need to be prepared for the impact of third country nationals seeking to travel to the EU. This will affect UK business travelers and truck drivers as well as people travelling for leisure purposes. The impact will be most noticeable at the terminals operating juxtaposed border controls (Port of Dover, Channel Tunnel, St Pancras), where UK and French border controls are only a short distance from each other. At these terminals the delays caused by EES enrolment and processing will be experienced in the UK before departure rather than in the EU at the point of arrival.

5.      How will EES affect the travel experience of third country nationals?

The system will inevitably cause lengthier processing times for third country nationals entering the EU after the system is introduced. EES has been designed with airport style travel in mind and this is a very different in practice to vehicle-based travel, such as ferry ports or the Channel Tunnel. Passengers entering the EU for the first time after the system is introduced will be required to leave their vehicles to register

 


 

facial and fingerprint biometrics, as well as answering a questionnaire, and for identity verification in the presence of a border official. We anticipate this process will add 5-7 minutes, on average, to the overall journey time of passengers using the Channel Tunnel. People travelling in large groups or on coach trips are also likely to experience lengthier processing times at the border crossing.

6.      The EU is not planning to allow registration for EES remotely—e.g. via a dedicated website or mobile phone application—or physically at a location away from London St Pancras, Dover or Folkestone (such as an EU or Member State facility in a major UK city). Is this approach justified? Would remote registration be justifiable for nationals of countries with comparable immigration and security standards to the EU?

The European Commission (via its Agency FRONTEX) is proposing to allow some of the pre-registration process to be completed via a specialised mobile app, currently under development. The app should allow first-time third-country travelers to register their biographic details in advance of arriving at the border. The app should also enable facial recognition which means part of the biometric data requirement could also be possible away from the border. The capture of fingerprints will still need to take place at the border kiosk in the presence of a border official.

The Commission's position is that a centralised app will be intended for the EU Member States, which will be responsible for adapting it to the specific circumstances of each border crossing point.

The remote registration of biographic information and some biometric data (facial recognition) is an important step towards reducing the time needed to process passengers at the border. It is therefore essential that the app is developed quickly to allow for testing in advance of the system’s introduction.

7.      Juxtaposed UK/France (Schengen) border controls are in operation at London St Pancras International, Folkestone and Dover. 1. introduced in its current form, what challenges will EES present UK sites facilitating juxtaposed border controls? 2. Should special dispensation for remote registration or remote pre-registration for EES be provided for at these sites.

At juxtaposed border controls, where controls take place before departure, the disruption caused by the new system will be felt here in the UK at already space-constrained terminals. Remote registration and the use of the EES app will help reduce the time required to process passengers and contribute to the maintenance of flow through the terminals, however additional time will be required to time for passengers to enrol in the system.

Getlink is having to invest over €80 million in developing the terminals in Folkestone and Coquelles in preparation for the new requirements under EES. It constitutes a major infrastructure project to reconfigure the terminals on both sides of the Channel and create the space needed for the covered parking bays and kiosks for the enrollment process. System testing will commence following the completion of the infrastructure work and installation of kiosks in Q2 2024.

Fluidity is a vital element in the operation of an infrastructure designed to carry millions of vehicles and passengers. This investment will ensure we are well placed to facilitate the continued seamless movement goods and people through the border without risk of disruption beyond the terminal.

 


 

A solution also needs to be found for the Port of Dover, which currently lacks the space needed to construct the necessary infrastructure. If the port is forced to rely on the existing border check points then there is a serious risk of delays and queues, which at busy times could also impact access to the Channel Tunnel. The volume and value of trade passing through the Short Straits means that any disruption on this route will also have a significant economic impact for the UK as a whole.

8.      In addition to EES, the EU plans to introduce a ‘European Travel Information and Authorisation System’ (ETIAS) in 2024. The UK’s ‘Electronic Travel Authorisation scheme will go live in November 2023. 1. What challenges does the introduction of new EU and UK electronic travel systems present for operators and travellers? 2. Should the UK EU and international partners prioritise interoperability between their respective systems?

The introduction of EES coincides with the roll out of the ETIAS and ETA systems for travel to the EU and the UK respectively. These schemes offer important benefits in terms of the remote provision of passenger information and will help facilitate border processes going forward. However, there is a risk that the introduction of the three systems in a relatively short time period could cause some confusion at the point of introduction.

To ensure smooth introduction and adoption of the ETA requirement for EU nationals it would be logical to avoid any potential clash with the EES and ETIAS systems. This would in effect mean extending the scheme to EU nationals later in 2025, when the EES and ETIAS systems have already been established and should be operating effectively. As the systems effectively require the same information on passengers, cooperation on data capture and sharing would facilitate travel and trade.

9.      What steps should the UK Government be taking to mitigate potential disruption stemming from the introduction of EES for UK ports, operators, and passengers travelling to the Schengen Area?

There is an important role for the Home Office in continuing its engagement with the French and EU counterparts in preparation for the introduction of EES. Communication between departments and agencies will be critical to ensuring the appropriate levels of staffing are in place to manage the process and to prepare for any potential disruption at ports and terminals.

The UK Government can also play an important role in communicating these changes to the public to raise awareness of the process ahead of implementation. A widespread awareness campaign will be essential to ensure that passengers are aware of the new requirements for travel into the EU, and arrive at the border having already completed part of the enrolment remotely via the app. The Government has run successful campaigns in recent years to raise awareness of Brexit border processes amongst travellers and traders, and this should be emulated in the case of EES in the months ahead.

Longer term, the government should be looking at data capture and sharing mechanisms and the introduction of digitisation of border control processes, including “face-as-passport” to facilitate trade and travel.

January 2024