I am responsible, but you get fined.
Seems reasonable to me. The responsibility for completing the paperwork may be with one person (the freight forwarder) but they cannot be present on every vehicle to ensure that all the paperwork is retained, unaltered, and that no additions/subtraction of cargo happen.

All I can say it does not sound reasonable to me. Firstly, this is a permit to travel: cargo is not relevant to it, except in so far it is determinations whether it is a priority permit or or normal one.    Secondly, this is an electronic system: the master is the electronic record - eg for ANPR - not the paper one.   In most cases, while the driver could write anything he or she fancies on any paper record, it is the electronic one that counts, and my guess is that very few of them have access to that. But even if they have, make it an offence to alter the record. Then the person who issues it gets fined if it is not issued correctly, and the driver gets fined if they commit the sort of offences you list. It may be ignorance or lack of imagination on my part, but I can't think of another case where the legal responsibility is on one person, and no penalty at all on them if they breach the rules, but there is a penalty on the person who may not even have a right of access to the system. It seems an exceptionally odd arrangement to me.


Think of a simple case: some admin clerk mistypes the licence plate. I pick that as an example because it happened to my wife her car insurance and she was detained for nearly two hours because she was thought to have no insurance. SO that can happen. The consequence under this law: the driver gets fined.

As for the Operation Brook comment: yes, I know it only details with Dover. That means similar things are needed for Portsmouth, and Southampton, and Liverpool and Shields and all the rest. My comment was not that the document is not wide enough. It was that many more such documents will also be required to adequately deal with congestion at ports.