Richard Price, Fruit Marketing
Changes to UK/EU border processing requirements
Whatever the outcome of the trade negotiations, Brexit means introducing controls of movement of goods and people. So the border processing requirements between GB and the EU will change.
From 1 January 2021, if you trade with any EU country you’ll need to submit customs declarations – as well as safety and security declarations where relevant. There are separate processes for Northern Ireland.
Whether you send or receive small packages by post, bulk packages by truck or container, or if you’re taking goods with you – there will be changes.
The key processes, requirements and classifications for moving goods between GB and the EU are set out in the Border Operating Model on www.gov.uk. There is a lot of information to sift through – the document has 262 pages!
So, most businesses will use an intermediary – such as couriers, freight forwarders or customs agents, to help them with all this red-tape. For more information, including lists of specialists, see https://www.gov.uk/guidance/list-of-customs-agents-and-fast-parcel-operators
Some businesses may wish to do it themselves, and training for this is available via your Chamber of Commerce. https://devonchamber.co.uk/customs-declaration-training
Either way, it’s the trader’s responsibility to complete UK and EU customs declarations, and importers will need to pay any duties/tariffs applicable to their goods under the new arrangements, as well as VAT.
You’ll need a GB EORI (Economic Operation Recognition Identification) number to move goods to or from the UK, and if undertaking any EU customs processes, you’ll also need an EU EORI.
The new UK border operating model
Imports
From 1 January 2021, controls on imports from EU to GB will be phased in to operate in line with existing imports from non-EU countries.
Traders will have to complete customs declarations; some ports (most roll on/ roll off or RoRo ferry ports including Eurotunnel) will require pre-lodgement of these, whilst others will allow temporary storage pending customs clearance (more on this later).
Importers will have to pay any duties or tariffs that apply to their goods under the new arrangements. As such they will need to know the origin, classification and customs value of their goods. Trade deals may reduce, remove or increase tariffs.
VAT will be due on imports from the EU and will follow the same approach as imports from the rest of the world. You can reclaim the VAT paid if the goods are for use in your business. More information from the VAT Helpline 0300 200 3700.
Changes to the UK system will be in 3 stages to allow extra time for preparations to be made.
1 January – 30 June
Declarations needed for controlled goods (eg chemicals, controlled drugs, firearms, fisheries) and excise goods (eg alcohol and tobacco). Non-controlled goods need to be recorded but declarations can be delayed until July. Duty and VAT can be deferred for 6 months. Deferment accounts allow monthly reconciliation, rather than paying shipment by shipment.
1 April – 30 June
Pre-notifications, health certificates, document checks and physical checks for products of animal origin (POAO) – including high risk food and feed, some plants, fisheries, and bi-valve molluscs. Checks will be at destination or other designated inland sites.
1 July onwards
Declarations and safety/security certificates at the point of import with payments for all types of goods will be required, and increased physical checks are planned. Border Control Points (BCP) will be in ports or at designated inland sites. Delayed declarations will no longer be available.
Declarations will need to be made to either the Customs Handling of Import and Export Freight (CHIEF) or the new Customs Declaration Service. The majority of traders are expected to use an intermediary to help them submit their declarations.
Special category goods may require special certificates, locations of entry and checks at the border or destination. These will be introduced in phases depending on the type of goods being shipped.
There will be two models of border processing, depending on the location and facilities of the port.
1. Temporary storage model – where goods can be stored for up to 90 days pending customs clearance. This requires significant storage at ports.
2. Pre-lodgement model – where customs declarations are submitted before goods leave the EU. This approach will be used by most ferry ports and Eurotunnel.
Many ports will have a hybrid model where both import processes will be available.
Traders/agents will need to ensure their transporter is set up to use the new IT platform called Goods Vehicle Movement Service (GVMS).
There will be more on the above in the next article.
If you’re transporting merchandise in baggage or small vehicles, you can make a simple declaration online or at the port (for goods valued at up to £1500). And if you’re moving £10k or more in cash, you’ll need to declare this too.
Comprehensive information on this and more is in the Border Operating Model https://www.gov.uk/government/publications/the-border-operating-model
Exports
Full custom export declarations and safety & security (S&S) certificates for all goods will be required from 1 January 2021.
You’ll need to consider the EU import processing requirements too. In all EU countries full customs procedures (export and import) will apply from the 1st January 2021, and Safety & Security declarations will also be required from day 1 for all imports. There will be more on this in the next article.
Most traders will use an intermediary to do this, but if not, traders will need to use the National Export System (NES) or other commercial software.
Like imports, you’ll need your EORI number, the commodity code of your goods and the customs value of your goods.
You will need to check the labelling and marketing standards for food, plant seeds and manufactured goods, and whether you’ll need export licenses or certificates for certain types of goods.
On VAT, from 1 January 2021 you can charge customers at 0% (known as ‘zero rate’) on most goods you export to the EU.
You may be able to benefit from simplified declaration procedures up front with supplementary declarations up to 4 weeks later.
Comprehensive information on this and more is in the Border Operating Model https://www.gov.uk/government/publications/the-border-operating-model
Transport options
For airport traffic or high volume movers, goods can be cleared at authorised business premises prior to moving to the point of departure at so-called Designated Export Places (DEP).
RoRo traders will need to make a declaration and wait for permission to proceed (P2P) before moving to the point of departure. There will be more on this in the next article.
Small packages parcels and post
If your business involves export or import of small packages to the EU, from 1 January 2021 you’ll need to make a customs declaration in the same way as if you were sending the package to/from a non-EU country.
If you use Royal Mail Group (RMG) – the UK’s designated universal postal service provider, the CN22/CN23 customs forms will apply for non-controlled goods up to £900 in value.
For all other postal movements, an electronic full customs declaration will need to be submitted to HMRC, unless the parcel operator is authorised by HMRC to submit a simplified bulked customs declaration. However, between 1 January and 1 July 2021 both RMG and parcel operators will be able to make delayed supplementary import declarations (assuming the operator and goods meet the eligibility requirements).
Items of correspondence (letters, postcards, and braille letters) can be imported through a declaration by conduct.
Cash Controls
From 1 January 2021 individuals travelling out of GB carrying £10,000 or more will
be required to declare this. These requirements will also fall on couriers who are
transporting cash on behalf of business.
Declarations can be made either online, by phone, or via a paper BOR9100 declaration submitted to Border Force officials at the border.
In summary
Unless you have in-house capability, and if you want to avoid border delays, appoint an intermediary to help you with all the red tape. Here’s a checklist of what else you’ll need.