UK Import Complexity
The Brexit transition period ends on December 31st 2020 and has greatly increased UK Import Complexity. From this point onwards any goods entering, or transiting through Great Britain (GB) will need customs declarations. The British government has proposed a plan for the introduction of border controls on imports of goods from EU states to the UK after 2020. This will give UK and EU importers time to comply with new controls. It will also give the UK time to build and resource a full border control infrastructure, including the new Border Control Posts (BCP).
This will affect goods entering Great Britain (GB) – the UK excluding Northern Ireland since the latter will effectively remain inside the EU single market.
- January 2021: Customs declarations will not be required for the importation of goods from the EU, and may be deferred for up to six months. Import tariffs, at UK Global Tariff rates, may also be deferred until the submission of the declaration. But full import records must be maintained. The CFSP EIR easement will be in place until July 2021. Controlled goods, including alcohol, tobacco and chemicals, will require full declarations. Live animal and high-risk plants will need pre-notification. Controls will be carried out away from the GB border.
- April 2021: Goods of animal origin (meat, honey or dairy) and regulated plants will require pre-notification and health documentation.
- July 2021: All goods entering GB from the EU must be accompanied with full declarations and tariffs will be due. This will include full safety and security declarations – sanitary and phytosanitary (SPS) on animals etc.
UK importers need to establish the following before making any customs declarations:
- What is your EORI number?
- What mode of transport are you using road/sea/air/other?
- Which ports do you use and are they inventory linked?
- Do you have the appropriate badge for your trade?
- Do you have all of the licenses, quotas and commodity codes required?
- Do you know your INCOTERMS?
- Do you have a duty deferment account set up?
- Do you have an agent?
Another factor that has increased UK Import Complexity when importing goods to the UK is dealing with the Community Service Providers (CSPs). There are four major CSPs in operation today and between them they own or operate over 50 UK ports. Many of these ports are what is called “inventory linked”. This means that the port collects data on UK imports on behalf of the UK government. Some ports, or specific sections or berths in ports are non-inventory linked, which means that a statistical record for a given shipment is not processed through the CSPs system.
The British government decided earlier this year to permit all RoRo traffic into GB on a non-inventory basis, to ease restrictions on trade and road freight, post Brexit. However, anyone importing RoRo goods into GB will still need to engage with one of the CSPs in order to get an import badge. A RoRo import badge from any of the CSPs will allow access through any GB port.
Importers and exporters who intend making their own declarations to HMRC will need to engage with the CSPs in order to get set up properly for a particular port. The trader will have to apply and pay for a badge from one of the CSPs. If the port a trader is using is inventory linked, then the trader will have to purchase a badge from the CSP that operates that port. This is often the case with LoLo traffic. Annual fee payments and transaction costs are also charged to the trader from the CSP. The declarant, whether it is the trader themselves, or an agent working on their behalf, will still need to use a third party software platform when making declarations to HMRC.
This means that the cost of importing goods into GB will be significantly more than importing in Ireland as CSPs, as commercial entities, are placed between the declarant and HMRC. This cannot be avoided. The only other option is to use an agent. Agents will pass on the costs of dealing with CSPs to their customers as well as adding their own service cost to the total bill.
All of this would be more manageable if the political situation and Brexit negotiations between the EU and the UK were finalised. Traders and agents are heading into the New Year without a clear picture as to what is happening in January 2021 increasing UK Import Complexity and uncertainty.
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