Amid the global COVID-19 pandemic, it would be easy to understand the apparent lack of focus regarding the ongoing Brexit saga. But while out of the news in recent months, we are now approaching the final stages with clear guidance now being made public by the UK Government in all forms of media and by the EU on what is required post 31st December 2020. This will determine how enterprises will trade, and what processes to follow in a Post Brexit landscape.
We are all aware by now on the key dates regarding Brexit, with the UK leaving the EU on 31st December 2020. Under the terms of the Withdrawal Agreement, this allowed the UK–EU Joint Committee to extend the transition period by up to two years – this period ended on the 1st July 2020 without a request for extension being made by the UK Government.
In February 2020 the UK Government said they would implement full border controls on imports coming into Great Britain from the European Union. This statement has now been eased with the UK government taking the decision to introduce the new border controls in three stages up until 1st July 2021 and publishing the “Border Operating Model” providing visibility and instruction to traders.
The context of these 3 stage border controls for imports are as follows:
IMPORTS
1st January 2021
§ Traders importing non-controlled goods will need to prepare for basic customs requirements, such as keeping sufficient records of products imported, the ability to have up to six months to complete customs declarations.
§ Traders importing controlled goods however will need to prepare for full customs declarations at the point of importation.
§ There will be physical checks by the authorities at the point of U.K. destination or other approved premises on all high risk live animals and plants.
1st April 2021
§ All products of animal origin (POAO) will require pre-notification to the Authorities and required health documentation. This includes meat, pet food, honey, milk or egg products.
§ Physical checks will continue to be conducted at point of U.K. destination until 1st July 2021
§ All regulated plants and plant products require pre-notification to the Authorities and required health documentation. A full listing of products will be published by the authorities prior to implementation.
§ High-Risk Food and Feed which is not of Animal Origin will also require import pre-notifications to the Authorities in advance of the goods’ arriving.
§ For any High-Risk Food and Feed which is not of Animal Origin importers will need to submit pre-notifications via the Import of products, animals, food and feed system (IPAFFS)
1st July 2021
§ Traders moving goods will have to make pre-lodged notice to HM Revenue & Customs (HMRC), complete full declarations and pay tariffs at the point of importation directly or via their nominated representatives.
§ The Pre-lodged model requires all goods coming into Great Britain to have been declared to HM Revenue & Customs prior to export, the carrier normally undertakes this declaration on behalf of traders. Pre-Lodgement allows HM Revenue and Customs (HMRC) to complete risk-assessments and clear many imports and transit movements prior to their arrival in the UK.
§ To support the pre-lodgement requirement of HMRC the UK Government will also be implementing the Goods Vehicle Movement System (GVMS). The GVMS system is an IT platform which will support pre-lodgement, this will enable the linking of goods, customs broker and customs through a referencing system. Allowing the shipment to be customs cleared en-route to the UK or providing notification of a customs upon arrival.
§ Full Safety and Security declarations are required while for Sanitary and Phytosanitary (SPS) commodities there will be an increase in physical checks that will now take place at Great Britain Border Control Posts.
EXPORTS
Any exports from Great Britain after the 1st January 2021, to European Union destinations will be treated as third country exports and as such full export customs processes and declarations will be required by HM Revenue and Customs. This includes a full Safety and Security declaration prior to exit from the UK and an export entry declaration
When declaring goods for export an organization will require the following:
§ An Economic Operator Registration and Identification Number (also known as an EORI number), which is a unique ID code used to track and register customs information.
§ Commodity Code for the goods
§ Correct Customs Procedure Code (CPC)
§ If required an Advanced Customs Ruling on the commodity code or country of Origin.
§ license validation and application as required.
§ All paperwork (including any licenses) to be submitted to customs usually via an intermediary.
If export customs formalities are to be completed by the organization rather than an intermediary the following steps must additionally be implemented:
§ Setup the organization for making customs declarations to include
o Register for National Export System (NES)
o Apply for CHIEF badges from HMRC
o If appropriate register to export plants or controlled goods
§ Complete internal training in the completion of export declarations and record keeping requirements
§ Submit all export declarations through NES or CDS.
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