Brexit: How Importers & Exporters Can Prepare For ‘No Deal’

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With the UK’s departure from the European Union subject to further delay, there is a great deal of uncertainty about what this means for the country going forward – especially as a no-deal Brexit is yet to be officially ruled out. Of course, this is of particular concern to companies that ship items to and from other EU countries.

At Hemisphere Freight Services (HFS), we are proud of our reputation for reliable, efficient freight forwarding, and want to reassure clients that, while it is important to ready your company for a potential ‘no deal’ Brexit, we will continue to provide first-class customs clearance services. By managing the necessary customs procedures for our clients, we will help keep supply chains moving in the event of a no deal.

 

Essential Preparations for a No-Deal Brexit

While HFS can still support all your shipping needs if the UK leaves the EU without a deal, there are a number of key steps you will need to take to ensure we can continue to manage the process of your behalf.

 

Economic Operator and Registration Identification (EORI)

If the United Kingdom does leave the European Union without a deal, all businesses which wish to import or export goods to and from the EU will require an Economic Operator and Registration Identification number, or EORI. These unique numbers are used to monitor trade between EU and non-EU countries.

Currently, UK businesses which only trade within the EU do not require an EORI – but should the UK leave the EU without a deal, your business will no longer be able to trade with other EU countries unless it has an EORI number. It takes three days to be issued with an EORI number, so it’s important to organise this as soon as possible.

Once you have applied for an EORI number, you will be able to decide how you want to make customs declarations. Although you can do this yourself, authorising HFS to undertake the lengthy procedure of completing import and export entries can save your business time and money.

If your EORI number does not start with ‘GB’, you may continue to use it to export and import with the EU for a temporary period after the UK leaves the EU. The government will provide further guidance once the UK leaves the EU on when your business will need to apply for a UK EORI number.

However, we recommend that businesses consider applying for a GB EORI ahead of the current ‘leave’ date, in preparation for the possibility of a no deal. There is no cost involved in applying for an EORI.

For more information, take a look at our guide to EORI registration, as well as the government’s official guidance.

 

Transitional Simplified Procedures (TSP)

In the event of a ‘no deal’ Brexit, UK businesses will be obliged to implement the same procedures for trade within the EU as they do when trading with the rest of the world. This means that goods cannot be released from customs control without a full import declaration and until duties have been paid.

Transitional Simplified Procedures – or TSPs – allow you to defer declaration and payment of outstanding excise duties, paying monthly via direct debit each month rather than each time your goods pass through customs. The day that your direct debit is taken will vary as follows:

  • For customs duties and any import VAT, direct debit will be taken on on the 15th day of the month in which your supplementary declaration is made.
  • For excise duties, payment will be taken on the 29th day of the month that your declaration was made in.

Should you wish to delay declaration in order to allow time to prepare your business, you will still need to submit by 4 October.

TSPs apply at ‘roll on roll off’ (RORO) locations such as Dover and the Eurotunnel terminal at Folkestone. They were previously intended for RORO port operations, but will now be usable at all UK ports. This should make it a lot easier for companies to import EU goods – although controlled goods such as alcohol and tobacco require a controlled goods procedure.

To register for TSP, your company must be established in the UK (not just a UK postal address namesake), you must have an EORI number and you must be importing goods from the EU into the UK. Once you have registered for TSP, HFS will be able to submit customs declarations on your behalf.

You cannot use TSP without a deferment account, unless the goods you are importing are free from customs duty and import VAT. Successful TSP applicants will need to arrange a customs guarantee by 30 September 2019. You can reduce your deferment guarantee by 70% by becoming AEO-certified, as outlined below.

For more information, please review the government’s official guidance on TSP. If you apply and don’t hear from HMRC after 15 days, you can call 0300 200 3700.

 

Authorised Economic Operator Status (AEO)

Authorised Economic Operator Status – better known as AEO status – is an internationally accepted mark of quality which confirms that your company’s customs controls and procedures meet EU standards, and that your role in the international supply chain is secure.

AEO status is available to any business that is a legal entity, is established in the EU, is involved in customs operations and international trade, and that has an EORI number. By becoming AEO-accredited, you can benefit from simplified customs procedures and even fast-track shipments in certain cases. In the event of a ‘no-deal’ Brexit, it is highly likely that the UK and the EU will recognise each other’s AEO procedures, so AEO status will be highly desirable for companies that either import or export.

The government’s official guidance provides additional information on AEO status, including how to apply. HFS were early adopters of AEO status and continue to be fully-certified, so we can support you through the application process if required.

 

Other Considerations

As well as all of the above, there are numerous other questions your company will need to consider in the event of a no-deal Brexit:

  • Will your goods be licensable?
  • What customs procedures and controls apply to your goods? HMRC’s licensable/controlled goods list will give you the necessary guidance on this.
  • What customs procedure codes need to be stated on your import/export documents?
  • Will you need other documents for UK road exports? We advise looking at HMRC’s guidance on this.
  • Do you need to add tariff classification information to your documentation?
  • Will import duties now be applicable for your goods? Check your commodity codes

Your trade routes may also change if the UK leaves the EU without a deal. For example, in the event of no deal, you will  only be able to import or export CITES-listed endangered animals, plants or products through the designated land, sea and air ports as outlined by HMRC. This includes products such as animal skin/leather luxury items, as well as foodstuffs where ingredients derive from animal or plant origins.

It is also important to remember that Dover, Eurotunnel and Holyhead do not have border inspection posts (BIPs), so goods such as food and products under vet certifications cannot pass through these entry points, and may be returned or destroyed. The latest guidance from Defra provides additional information on how the food, drink and farming sectors can prepare for a no-deal Brexit scenario.

HFS is registered for government-secured freight capacity of CAT 1 goods, so you move category 1 goods via ferry from EU states to the UK, this may help reduce potential delays by using other ferry lanes.

Keeping You Updated

The government’s import/export policies will be reviewed between three and six months after the UK leaves the EU, so it is essential that you keep up to date with any changes in the near future.

The HMRC website provides plenty of useful information on the following:

  • What your business may need to do to prepare for the UK’s departure from the EU
  • How Brexit could impact your industry
  • Information about specific rules and regulations

HFS will endeavour to keep you updated with any further developments, but please get in touch if you have any questions or need advice. Our expert team is fully prepared for any eventuality post-Brexit, and will be more than happy to offer the guidance and assistance that you require.

 

This article was last updated on 4 April 2019. We will endeavour to update it as and when guidance changes, but we also recommend keeping an eye on the HMRC website to ensure your business is fully prepared ahead of the UK leaving the EU.