The TNs published so far have covered areas including medical supplies, financial services, nuclear safeguards, farming and organic food production. We have identified and summarised just those TNs which are most relevant to our industry.
Tariff checker for imported goods
It may be helpful to get an early idea of what the World Trade Organisation's tariffs are, if these are to be applied to EK-EU trade. InterIreland, an Irish trade body, have trawled through the possible World Trade Organisation (WTO) tariffs that may apply to the movement of goods that your business may use or produce. Their tariff checker is available to view and search here.
Quick guide to Authorised Economic Operator (AEO) status - could you benefit?
The AEO is a quality mark that shows your role in the supply chain is secure and that your customs controls and procedures are efficient and meet EU standards.
You don't have to have it, but it gives you quicker access to some simplified customs procedures and - in some cases - the right to fast track your shipments through some customs, safety and security procedures.
Around 600 traders are registered for AEO in the UK.
No-deal Brexit - Day One
The Government has published a new document Preparing for Changes at the UK Border after a 'No Deal' EU Exit. It includes fact sheets covering what to expect at the border on Day 1 of a no-deal Brexit. For businesses importing from the EU, trade will broadly follow the customs controls that apply for the rest of the world - you'll need to adapt to comply with these new systems, processes and controls. This means that you will need to make an import declaration for goods entering the UK from the EU.
You'll need to:
- have a UK Economic Operator Registration and Identification (EORI) number (find out how to register)
- ensure your contracts and International Terms and Conditions of Service (INCOTERMS) show that you are now an importer.
- consider how you will submit import declarations. It's up to you whether you choose to make declarations yourself or do it through a third party such as a customs broker, freight forwarder or logistics provider. If you choose to do it yourself, you'll need the right software and the necessary authorisations from HMRC. Check how to complete a customs declaration. There's also some funding available for training in this area - see below.
- check if you need a licence to import or export your goods - you may also need to apply for an import licence or provide supporting documents to import specific types of goods into the UK, or to meet the conditions of the relevant customs import procedure.
- find out the commodity code of your goods to ensure you're paying the right amount of customs duty, excise duty and/or VAT.
Important no-deal news for importers
a. Entry Summary Declarations
This month the Government has made some announcements designed to give businesses more time to make changes, if the UK leaves the EU without a deal. If this happens, HMRC plans to phase in Entry Summary Declarations (pre-arrival forms for UK imports). So, from 29 March, if Brexit takes place without a deal, the status quo will be temporarily maintained as hauliers will not need to submit Entry Summary Declarations on imports for a period of six months.
Importers will still be required to submit import declarations for customs purposes (these are not the same as Entry Summary Declarations, see below).
b. Customs/Import Declarations
Plans have also been made that, in the event of a no-deal, Transitional Simplified Procedures (TSP) can be used for at least 15 months for customs declarations. The TSPs are intended to make importing easier for an initial period of one year. Once businesses are registered for TSP, they will be able to:
- transport goods from theEU into the UK without having to make a full customs declaration at the border (full declaration can be made after the goods have crossed the border)
- postpone paying any import duties until the month after the import.
VAT registered businesses which trade with the EU should have received a letter from HMRC with more details about TSPs. If you've not been contacted, you can read the letter on the HMRC website and you can sign up to TSP online too. You'll need your EORI number.
If you still need to apply for your EORI number, it can take three days to be processed, so we recommend doing this as soon as possible.
Commodity codes checker
Here's a link to an easy-to-use tariffs/commodity code database, If you're still not sure of a commodity code for an item, you can contact HMRC and they will check it for you. Some of our members have already done this and received responses within a day or two. Email [email protected] with the following information:
- company name
- contact name
- contact details
- the option which best describes your item:
- agricultural, chemical, textiles or ceramics (including food, drink, plastics, cosmetics, sports equipment, games, toys, clothing, shoes)
- electrical, mechanical or miscellaneous (including vehicles, optical and measuring devices, machinery, musical instruments, metal, furniture, lighting, paper, printed matter, straw, glass, wood, jewellery)
- what the goods are made of (if more than one material, provide a breakdown of materials)
- what the goods are used for
- how the goods work or function
- how the goods are presented or packaged
- the code you consider to be appropriate for your goods
It can help to include photographs if the item is unusual or difficult to describe.
Do you have your EORI number?
We've said it before but it's worth saying again! You need to register for an EORI number if you trade with the EU and wish to continue doing so. If you currently trade with non-EU countries, you should already have one and you don't need to re-register. If you're not sure if you have one, or can't find it, call HMRC on 0300 322 7067.
If you need one, it's important to register now, before we leave the EU. You can apply online and it'll take about 10 minutes, with your EORI number being sent to you by email three days later.
HMRC are currently saying they anticipate a high number of registrations over the next few weeks, so apply as soon as possible.
What's my SIC code?
We've covered the importance of getting an EORI number for trading with the EU. To apply for your EORI number, you'll need to know your SIC code. You SIC code is your Standard Industrial Classification Code, it defines the nature of your business activity. You can find it on your company's entry on the Companies House Register.
Manufacturing exports and stockpiling slows
Research from IHS Markit and the Chartered Institute of Procurement and Supply shows that fears of the threat of a disorderly Brexit lost UK manufacturing companies new orders from international clients last month. The rush in stockpiling also began to reduce.
If you export - whether to countries inside or outside the EU - existing trade agreements won't apply if we leave the EU without a deal. As you know, trade will take place on WTO terms while the UK works to secure replacement agreements with each country. The Government's published information on a country-by-country basis, updating the status of those replacement agreements. Most update that engagement is ongoing, but in regard to some countries - Japan, Algeria - the Government makes clear that deals won't be made by exit day on October 31st.
There is also a helpful list of countries which have already signed trade agreements with the UK.
We've previously published information about the Temporary Tariff Regime on imports that will come into force if the UK leaves the EU without a deal. Under this regime, 87% of imports will be eligible for tariff free access for at least a year following a no-deal Brexit.
Boris Johnson claimed this month that a provision under the General Agreement on Tariffs and Trade - known as Gatt 24 - could be used to avoid tariffs on both imports and exports under World Trade Organisation (WTO) rules for up to 10 years. International Trade Secretary Liam Fox argues that such an arrangement would require the agreement of the EU, which has not been given. Governor of the Bank of England, Mark Carney, has also previously stated that a no-deal Brexit would mean that there are tariffs "automatically, because the Europeans have to apply the same rules to us as they apply to everyone else."
Automatic EORI registration
We've been keen to highlight the importance of registering for your EORI number if you trade with the EU, or plan to do so in future. Last week HMRC announced it is stepping up efforts to ensure businesses are ready to trade post-Brexit by automatically registering companies with EORI.
Over the next two weeks, 88,000 companies will be allocated an EORI number, joining the 71,000 companies already registered.
Business who currently do not have an EORI number will receive a letter from HMRC over the next two weeks.
Traders also need to consider how they will make customs declarations and whether to apply for Transitional Simplified Procedures.
We've put together a handy checklist for those who intend to trade with the EU following Brexit.
Government Steering Committee for Trade Continuity
The Confederation of British Industry (CBI), of which BOSS through the British Printing Industries Federatoin is represented, have secured a seat on the Department for International Trade's new Expert Trade Advisory Group for Trade Agreement Continuity. The Group will advise Ministers and officials on continuity of trade for UK firms around the world post-Brexit.
Firms accelerated onto simplified import procedures
Following its decision to automatically register businesses for EORI, has now automatically registered 95,000 businesses for Transitional Simplified Procedures (TSPs) on importing. This will allow most traders up to six months to pay import duties and submit customs declarations if the UK leaves the EU without a deal.
Businesses being registered for TSP are UK-based traders who HMRC has a record of having imported goods from the EU in 2018. HMRC is in the process of sending letters to these traders with further details of their TSP registration.
Importers do not have to use TSP: they still also have the option to use full import processes instead. However, HMRC strongly advises traders new to dealing with customs to take advantage of the benefits of TSP.
New border arrangements
As we've always said, the application of tariffs is merely one barrier to trade. Whether a Free Trade Agreement is reached or not, there will be increased barriers and costs to trade.
The Government's original plan was to introduce full border checks on January 1. However, after intensive lobbying by business organisations already concerns about the impact of COVID-19, Michael Gove this month announced a new plan.
Border control will now be introduced in three stages, which will begin on 1 January 2021 (under both a deal or no-deal scenario).
The stages are:
From January 2021
From April 2021
From July 2021
Officials concede that goods flowing to the EU from the UK are likely to face full checks as they enter France.
Border Operating Model
Businesses will need to take action, regardless of the outcome of the EU/UK negotiations. Preparations are along the same lines as preparations made in earlier years:
1. Apply for a GB EORI number
Chances are you have one by now, if you move goods into or out of the country. All VAT-registered businesses which trade with the EU should have received an automatic enrolment from HMRC last year, with your EORI number coming in the post, so check whether you have one before applying.
If not, you can apply here for one here. The application process should take under ten minutes and the EORI number will be supplied in around a week.
You must have one if you're VAT-registered and want to continue to trade with the EU!
2. Get a Customs Intermediary
Intermediaries can help traders find the information needed to complete formalities and submit the required declarations. This simplifies the declaration processes for traders. Further information can be found here.
For business that want to do their own declarations, and for intermediary businesses themselves, we've covered the available funding for training in previous Bulletins and on our website.
If you decide not to use an intermediary, you will need to make declarations yourself. To do this you will need to get access to HMRC systems and to purchase software.
3. Apply for a Duty Deferment Account
Traders who import goods regularly may benefit from having a duty deferment account (DDA). This enables customs charges including customs duty, excise duty, and import VAT to be paid once a month through Direct Debit instead of being paid on individual consignments. VAT registered traders can instead account for import VAT on their VAT return using postponed VAT accounting, as detailed below.
To set up a DDA, traders, or their representatives, apply for a deferment account number (DAN) and will need to be authorised by HMRC. New rules are being introduced which will allow most traders to use duty deferment without a Customs Comprehensive Guarantee (CCG).
4. Prepare to Pay or Account for VAT on Imported Goods
VAT-registered traders will be able to account for import VAT on their VAT return by using postponed VAT accounting from 1 January 2021. Unless they are eligible to defer their supplementary declarations, they will not be compelled to use postponed VAT accounting.
5. Ensure drivers have correct International Driving Permits
Hauliers need to ensure their drivers have the correct documentation, for example an international driving permit (IDP) or an additional licence may be required to drive in some countries.
6. Know all about import tariffs
Businesses importing goods into GB should ensure they are familiar with using the Trade with the UK tool which provides detailed information on tariffs, taxes and rules. The tariffs shown are those currently being applied until 1 January 2021. Use the UK UK Global Tariff tool to check the tariffs that will apply to goods imported from 1 January 2021. Most print-related tariffs are, and will remain, 0%.
7. And duties and customs procedures for exporting
If you export goods from Great Britain you should ensure you are familiar with using the 'Check How to Export Goods' tool which provides detailed information on duties and customs procedures for over 160 countries.
Northern Ireland Protocol update
The Government has, this month, issued further guidance for businesses moving goods under the Northern Ireland Protocol. Due to take effect at the end of the Transition Period, the Protocol is the practical solution designed to avoid a hard border between Northern Ireland and the Republic.
Exporting NI to GB
Moving goods from Northern Ireland to Great Britain should take place as it does now – there will be no additional process, paperwork, or restrictions on Northern Ireland goods moving to Great Britain, delivering unfettered access.
Exporting GB to NI
Changes for goods moving from Great Britain to Northern Ireland will be kept to an absolute minimum but will entail some new admin processes, notably new electronic import declaration requirements, and safety and security information, for goods entering Northern Ireland from the rest of the UK. These are needed to make sure that tariffs are not paid on trade within the UK and that goods going to Ireland pay tariffs when they should.
A new Trader Support Service (more information below), available to all traders at no cost, will be available - alongside guidance on the processes for food and agricultural products.
Trader Support Service
As mentioned above, the new Trader Support Service will be made available to all traders who move goods between GB and NI, or bring goods into NI from outside the UK.
The TSS will be free to use and will guide you through any changes to the way goods move between Great Britain and Northern Ireland, and into Northern Ireland from outside the UK.
You can also use it to get customs declarations completed on your behalf.
You can register your interest now and the Service is expected to go live in September.
Exporting to the rest of the world
Trading agreements between the EU and non-EU countries will no longer apply to UK businesses from 1 January 2021.
Therefore the UK is seeking to replicate trading arrangements between EU and non-EU countries. To check rules about exporting to non-EU countries from 2021 onwards,
If you’re not exporting to worldwide countries, but thinking about finding opportunities in new markets, try out the Department for Trade & Industry’s Export Guides. It’ll tell you what that country’s GDP is, the size of various markets, demand, and visas you might need. It also tells you how easy it is to do business there, compared to other nations, based on simplicity of regulation and strength of intellectual property rights.
Curious? The World Bank says the below are the Top Ten most business-friendly countries, as of 2019, were:
1. New Zealand
3. Hong Kong, China
5. Korean Republic
6. United States
Lorrying to Kent? You'll need a KAP...
The Government has said this month that truck drivers will need a permit to enter Kent from neighbouring counties after the Brexit transition period ends.
A letter from Michael Gove to logistics campaign groups warned that queues of 7,000-trucks-long could clog up roads around the port of Dover and Channel Tunnel in a 'reasonable worse case scenario.'
To avoid such gridlock, he announced a 'Kent Access Permit' (KAP) system would be installed, and would be enforced by police and Automatic Number Plate Recognition cameras.
Drivers of lorries weighing more than 7.5 tonnes will need to apply for the permits online and show that they have all the paperwork they need to ferry goods to Europe.
Drivers who are found travelling to Dover or Folkestone without a Kent Access Permit face being given a £300 fine by the police or the Vehicle Standards Agency.
It's likely that, in order to minimise bureaucracy, KAPs will be issued to all drivers who simply claim their paperwork is in order. For this reason, the Road Haulage Association has criticised the new arrangement as being "an honesty box system...not an effective system to actually guarantee or ensure that someone is ready to cross the border."
The new UK-Japan Agreement
A little later than intended, on 7 September, the UK-Japan trade deal was announced. It's the first post-Brexit major trade deal to be done, with the aim of boosting trade between the countries following the end of the Transition Period.
This 'agreement in principle' says that 99% of exports from the UK to Japan will be free of tariffs, so it's fairly similar to the deal the EU agreed with Japan in 2018.
Even though trade with Japan accounts for just 2% of the UK's total trade, that trade value (both ways) is almost £30bn - and while it's a drop in the ocean compared to UK-EU trade, the Government is hoping the deal with Japan will serve to boost confidence for UK business.
- Brexit Bulletins Catch up with all our Brexit Bulletins so far.
- Northern Ireland Based in Northern Ireland, find more information here.
- No-deal scenario Leaving the EU without a deal is unlikely, but - just in case - here’s what will happen in print-relevant areas.
- Employment Do you have staff from the EU? Here’s what you - and they - need to know.
- Running your business Your customers may be checking their supply chains and some of you report back that you're also putting in the ground work to ensure continuity of service.
- Funding The Welsh Government has launched a £1m Brexit Resilience Fund, available to Welsh businesses, to help them adapt to the changes in a post-Brexit Welsh economy.
- Other resources Everyone’s talking about Brexit. We’ve pulled together some of the more interesting publications out there.
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