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Brexit – a Three-Phased Approach

Wed , 17 Jun 2020 | Customs, International trade, import, export, Brexit, UK, EU, Transition period

The UK Will Not Seek an Extension

On June 12, the Chancellor of the Duchy of Lancaster, Michael Gove, formally notified the EU that the UK will neither accept nor seek any extension to the transition period. This announcement came after a meeting of the UK Withdrawal Agreement Joint Committee, which was the last formal meeting before the July 1 deadline to agree on an extension. Consequently, UK border controls and customs procedures will come into effect on January 1, 2021.

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The UK Will Introduce Border Controls on Imports from the EU in Stages, Beginning January 1, 2021

Following the formal communication by the UK government to the EU that the UK will not seek an extension of the transition period, the UK Government announced the following temporary measures in the field of customs. They will allow for a gradual transition in three stages during the first half of 2021 before full UK border controls are implemented on July 1, 2021. These measures will only apply to imports from the EU into Great Britain, not on trade between the Republic of Ireland and Northern Ireland or between Northern Ireland and Great Britain.

Each of these temporary measures needs to be further clarified by the UK government since a lot of questions remain. C4T will keep you informed on updates.

Beginning January 2021

  1. Imports of STANDARD goods to the UK
  • Upon arrival of goods in the UK, only an entry into the importer’s records (EIDR) will need to be made (no import declaration must be lodged).
  • This entry is to be followed by a supplementary declaration into the UK’s customs system, CHIEF, within 6 months of the arrival date.
  • Import duties are due at the rate set in the UK Global Tariff Schedule.
  • VAT and duty payments may be deferred until the time the supplementary declaration is lodged.
  • No Entry Summary declaration (ENS) is required for a 6-month period (January-June 2021).
  1. Imports of CONTROLLED goods such as toxic chemicals and excise goods (alcohol, tobacco)
  • A full import declaration must be lodged in CHIEF upon entry in the UK.
  • These will follow the same procedure as for Rest of the World (ROW) imports for duty and VAT payment.
  1. Imports of high-risk plants and plant products, animal by-products, and live animals
  • A pre-notification and the required health permits and documentation are necessary.
  • A full import declaration upon entry in the UK is required.
  • There will be physical checks at the destination or other authorised premises inland.
  • Documentary checks will be carried out remotely.

 Beginning April 2021

  • All products of animal origin (POAO) and all regulated plants and plant products will require pre-notification and presentation of the relevant health certificates.
  • Full or simplified import declarations are possible.

Beginning July 2021

  • For all goods (including standard goods), import declarations must be lodged at the port of entry.
  • For the UK imports, the import declaration may be lodged at the port of entry, but for RoRo shipments, the UK import declarations must be lodged prior to departure from the EU.
  • ENS must be lodged at least two hours before arrival in the UK for shortsea transport and one hour before arrival at the French Eurotunnel terminal.
  • Import duties are due at the rate set in the UK Global Tariff Schedule.
  • Inspections will be made on SPS products at GB Border Control Posts and occur more frequently.

The possibility to postpone the lodging of import declarations and related duty payments for UK imports of standard goods in the first half of 2021 may be a good option for companies less prepared for the Brexit, but one should also consider the benefits of lodging a full import declaration, as it requires no follow-up or declaration filing after the arrival of the goods in the UK.

In the absence of a Free Trade Agreement, UK duty rates are set at the full MFN rate with some exceptions where the UK already introduced a reduced tariff rate. For controlled goods, full import declarations are required but with some exceptions. Simplified procedures may also be used, as is the case today for non-EU imports in the UK.

C4T can help companies become Brexit-proof with regards to customs and trade compliance. We have incorporated Brexit flows into our automated customs management system, as well as instituted a fast onboarding process to help businesses implement a light version of CAS without the need for IT support. Contact us today to keep your trade flowing throughout this transition.

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