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Brexit Update: The UK Border Operating Model for Trade with the EU

Mon , 10 Aug 2020 | Customs, International trade, import, export, Brexit, UK, EU

On July 14, 2020, the UK Government published a comprehensive, 206-page document providing detailed guidance on UK import/export requirements beginning January 1, 2021.

As announced by the UK government on June 12, the new UK border controls on the movement of goods between the EU and Great Britain (GB) will be gradually implemented in three stages between January 1 and July 1, 2021. Note that these three stages only apply to imports into GB (England, Scotland and Wales). Requirements for exports from GB are also covered by this guidance document but there will be no transitional phase-in. The movement of goods to and from Northern Ireland are not covered, as those will follow different rules set forth in the Northern Ireland Protocol in the Withdrawal Agreement between the EU and the UK.

Brexit chess

The same core processes will apply throughout all three stages:

  1. Making a customs declaration which requires a GB EORI number, as an EU EORI will no longer be valid in the UK.
  2. Having other applicable customs authorisations, permits, and certificates.
  3. Paying UK customs duties and import VAT.
  4. Making a safety and security declaration, called an Entry Summary Declaration in the EU.

Stage 1 Effective January 1, 2021

UK importers will need to check whether or not their products are classified as “controlled goods.” HMRC included a list of controlled product categories in Annex C, page 205 of its UK Border Model document. Goods which are not on this list are referred to as standard goods.

UK import declarations for STANDARD goods

Between January 1 and June 30, 2021, standard goods may be imported into the UK by using a deferred declarations process, which consists of 2 steps:

  1. Upon entry of the goods into the UK, the importer must note the import details in its own records (EIDR).
  2. The submission to CHIEF of a supplementary declaration within six months of the arrival of the goods in the UK. This means that the payment of UK import duties and import VAT may also be postponed for six months.

Some conditions apply to be able to use the deferred declarations process.

  • The UK importer must have an authorisation for simplified declaration procedures, i.e., a CFSP authorisation.
  • The importer must have a duty deferment account (DDA).

Importers not having their own CFSP authorization may use the CFSP and the DDA of their customs representative.

When leaving the EU, the haulier should be informed of the GB EORI number of the UK importer.

It will still be possible to use existing customs processes by submitting a standard full declaration (pre-lodged) or use the Simplified Declaration Procedure (CFSP), if so authorised.

UK import declarations for CONTROLLED goods

Imports of controlled goods require a pre-lodge of a full import declaration in CHIEF. Alternatively, importers that have a CFSP authorisation can lodge a simplified frontier declaration (SFD), followed by a supplementary declaration on the fourth working day of the month following acceptance of the SFD. In addition, for live animals and high-risk animal by-products (ABP’s) not intended for human consumption a pre-notification into IPAFFS is required. This must be done latest 24 hours before arrival in GB. IPAFFS (Import of Products, Animals, Food and Feed System) is the UK’s equivalent of EU TRACES.

Transit Declarations

From January 1, 2021, traders will be able to move goods into the UK customs territory under the Common Transit Convention (CTC). Upon arrival in the UK, the lorry driver needs to carry and present the goods and the Transit Accompanying Document (TAD) at an office of transit. Transit movements are completed either at the UK customs office of destination or at the premises of an authorised consignee. If the transit shipment contains only standard goods, the deferred declarations procedure can be used until July 1, 2021.

HMRC will establish a new IT platform called Transit and Goods Vehicle Movement Service (GVMS) which will allow to link together the MRN of a TAD’s representing the different consignments on a lorry in one single Goods Movement Reference (GMR) to which must also be added the vehicle/trailer registration number. This must be done by the haulier already at the EU port of departure. The GVMS is linked to CHIEF. When the transit shipment arrives in the UK, GVMS will be updated and automatically send an arrival notification to the customs office of transit. This facility will not be available at all ports. HMRC shall communicate later which ports are connected to GVMS.

Entry Summary Declaration (ENS)

The obligation to lodge an ENS into CHIEF is waived until July 1, 2021.

Stage 2 Effective April 1, 2021

From April 1, 2021, imports of products of animal origin (POAO) must be pre-notified using IPAFFS at least 24 hours before arrival in GB. These products must also be accompanied by a Health certificate which the EU exporter must obtain from its national authorities.

The pre-notification requirement into IPAFFS applies also to high-risk food and feed not from animal origin

For all these products, full or simplified import declarations need to be pre-lodged.

Stage 3 Effective July 1, 2021

Beginning July 1, 2021, both standard goods and controlled goods can be imported into GB using either the traditional temporary storage model, where goods coming into GB can be stored at the frontier for up to 90 days before being declared to customs, or the new pre-lodgement model, where goods arriving in GB will be required to have submitted a customs declaration in advance of boarding on the EU side. The pre-lodge model is set up especially for RoRo and/or as an alternative for ports that don’t have the space and infrastructure to operate temporary storage.

Which model applies will depend on in which location the goods are imported because each GB port operator will have to decide which model to implement. Ports that have both RoRo and deep-sea may accommodate both models, but then the import declaration needs to specify whether it concerns a RoRo destination or not. HMRC will communicate which GB ports will adopt the pre-lodgement model, however this may take time, since ports still need to make that decision.

The Pre-lodgment Model

This model requires that a UK import declaration is lodged before boarding the vessel (ferry) or shuttle train at the EU port of exit. This will be checked at departure in the EU and at arrival in GB. Goods will be refused EU exit/GB entry if they do not have proof of a pre-lodged declaration.

Following types of import declarations can be pre-lodged: a standard full import declaration or a Simplified Frontier declaration (SFD) under CFSP which needs to be followed by a supplementary declaration by the 4th working day of the following month. Instead of pre-lodging a simplified frontier declaration, an importer can just record the details of the goods entering the UK in its own system. This is the CFSP/EIDR procedure, which also requires presentation of a supplementary declaration by the 4th working day of the following month. To use either the CFSP/SDF or the CFSP/EIDR procedure one needs the appropriate authorisation from HMRC.

From July 1, 2021, the following controlled goods must enter GB through a port where an appropriate Border Control Post (BCP) is located: Products of animal origin, animal by-products and animals. This requires a pre-notification in IPAFFS at least 24 hours before presentation of the goods at the BCP. The BCP will perform documentary, identity and physical checks. Consignments must be accompanied by a Health Certificate issued by the competent authority of an EU Member State. High risk food and feed not of animal origin coming from outside the EU and imported in GB from the EU will also be subject to BCP and pre-notification requirements. Some high-risk plants and plant products must in addition have a phytosanitary certificate.

The Goods Vehicle Movement Service (GVMS)

The GVMS will also support the pre-lodgement model as from July 1, 2021.

  • The GVMS will allow to link together the MRNs of the UK import declarations covering the different consignments carried on a lorry/trailer in one single Goods Movement Reference, the GMR.
  • The person moving the goods (the haulier) needs to collect the MRN’s from the importer(s) of all consignments on its lorry and enter these in GVMS.
  • The haulier must then enter the correct vehicle/trailer registration number in GVMS and link it to the GMR before boarding the ferry or the Eurotunnel shuttle train.
  • The haulier/driver must present the GMR to the carrier (ferry or shuttle) at the EU port of departure to prove that all their goods have pre-lodged declarations.
  • The GVMS will allow automatic arrival in CHIEF as soon as goods board at the EU side so that UK import declarations can be processed by HMRC en route to the UK.
  • The GVMS will allow notification through CHIEF as to whether the declaration status is cleared or uncleared by the time the goods physically arrive in the UK so that the haulier/driver knows if he needs to proceed to an inspection point or not before continuing his journey to the end destination.
Entry Summary Declarations (ENS)

HMRC now calls ENS declarations also Safety & Security Import Declarations or S&S import declarations which must be submitted to the UK’s S&S system called ‘S&S GB’ instead of the ICS system applicable in the EU. ENS declaration numbers can also be entered in the GVMS to be linked to the relevant import declaration and vehicle/trailer.

Common Transit Declarations

The process is the same as described in Stage 1 for movements of goods into the UK customs territory under the Common Transit Convention (CTC). When transit movements arrive at the UK port, the goods and the TAD must be presented to the customs office of transit unless TAD and vehicle/trailer data were entered into GVMS before departure from the EU. However, some GB ports may still choose to operate a paper-based office of transit. The transit movement ends either at a customs office of destination or at the trader’s premises if he’s an authorised consignee.

Import VAT
  • UK VAT registered importers must use postponed VAT accounting, hence import VAT is accounted for in their periodic VAT return.
  • If the UK importer is not VAT registered, he must pay import VAT together with the import duties upon import in the UK or 30 days later if he has a Duty Deferment Account.

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