For many, the onset of Brexit’s transitional period, which began on February 1, 2020, probably seems like an eternity ago, particularly considering the global pandemic that has consumed world affairs since that time.
But while the outcome of the transitional period may no longer be top of mind, its final stages are rapidly approaching, and businesses engaged in trade with the UK, the EU or both will need to begin preparing for changes that will take place as early as January 1, 2021. The governments of the UK and EU have now publicized clear guidance on what will be required with the official splitting of ties between the two entities – guidance that will determine how enterprises will trade, and what processes they will be required to follow in a post-Brexit landscape.
In February 2020, the UK’s government said it would implement full border controls on imports coming into Great Britain from the European Union. This statement has now been eased with the UK taking the decision to introduce the new border controls in three stages ending July 1, 2021. Downing Street has also published the “Border Operating Model,” which provides visibility and instruction to traders.
The details of these three stages of border controls for imports are as follows:
1st January 2021
-Importers of non-controlled goods will need to prepare for basic customs requirements, such as keeping sufficient records of imported goods and completing customs declarations within six months of the date of import.
-Importers of 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 where there is a biosecurity risk.
1st April 2021
-All Products of Animal Origin (POAO) will require pre-notification to British customs authorities along with the requisite 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 July 1st
-All regulated plants and plant products require pre-notification to British customs authorities along with the requisite 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 British Customs Authorities in advance of the goods’ arrival.
-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
-Importers 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 that will support pre-lodgement. This will enable the linking of goods, customs brokers and customs through a referencing system, allowing the shipment to be customs cleared enroute to the UK or providing notification of a customs inspection upon arrival.
-Full Safety and Security declarations are required.
-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.
Any exports from Great Britain after January 1, 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, such as a customs broker.
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:
–Register for National Export System (NES)
–Apply for CHIEF badges from HMRC
–If applicable, 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
Understanding these requirements and preparing for them in advance will allow exporters to the UK — and those trans-shipping goods to the EU via the UK to avoid border delays and/or penalties for incomplete or inaccurate customs documentation.