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Imports: Overview in the Event of a No-Deal Brexit

Δ This symbol highlights new or updated information.

This information is also available as a pdf download. Please see the full list of pdf documents available at the end of this page.

As a company ChannelPorts have been involved in many meetings with various Government departments giving our input in to trying to shape the way in which the changes of BREXIT could impact on us all. You will find enclosed specific links and attachments that have been published to help guide companies should a no deal scenario happen. Below is our interpretation of certain areas that as a company we feel needs bringing to your attention.

We know you are looking for an indication of costs from ourselves but currently the information released by the UK Government does not give us sufficient details to do this.

We cannot cover all scenarios or business sectors so you will need to ensure for your particular business all of the information being published by Government departments is taken into account when planning for a no deal BREXIT. Steps will need to be taken to evaluate and put in place procedures to ensure your company meets the potential new requirements.

Whilst we do our utmost to keep you abreast of any changes it is important you keep yourself updated from the government website.

https://www.gov.uk/find-eu-exit-guidance-business

There is a specific pack which is enclosed, however if we are emailing this the link below will take you to the pack.

https://www.gov.uk/government/publications/partnership-pack-preparing-for-a-no-deal-eu-exit

If you have not already registered to receive updates from the UK Government use the link below:
https://public.govdelivery.com/accounts/UKHMRCED/subscriber/new?preferences=true#tab1

Also enclosed is the latest “Walk-through of end to end roll on roll off process for goods entering or leaving the UK” which has been provided by Government as a simple guide.

Sections in yellow refer you to the section within the BREXIT pack from Government which gives you more detailed information.

Δ This symbol indicates sections which we have updated.

Additional sections have been issued.

The link below is to an article published in Lloyds Loading List and is a titled “Eurotunnel Ready for 29th March”
Whilst this is an article highlighting the changes Eurotunnel are having to put in place the areas they are having to address equally apply to Dover and the vast majority of other RoRo ports. We highly recommend you read this to give you an understanding of the impact BREXIT is having on the companies within this sector.

https://www.lloydsloadinglist.com/freight-directory/news/Eurotunnel-%E2%80%98ready-for-29-March%E2%80%99/73747.htm?cl=article_1&elqTrack=true&mc_cid=bda3ec3c08&mc_eid=819c073a63#.XF2R7KDgrVg

 ΔTransitional Simplified Procedures

This is new and strongly recommend all importers apply immediately.

Customs have released details of Transitional Simplified Procedures (TSP) which we would strongly recommend all importers apply for.

Only importers are able to apply for this authorisation. Freight Forwarders, transport companies and intermediaries cannot apply.

The simplified procedure will applies to goods from the EU27 arriving in the UK via any RoRo locations.

Importers will be required to have a record in your own systems of the arrival of the goods. Greater detail of the exact information required is contained in the notice issued by Customs. As part of the approval process it will give details of simplified payment methods for an initial period.

At the end of each calendar month you will need to submit the Customs Declarations.

We know certain goods will be excluded from the simplification or will require a Simplified Frontier declaration. We are currently waiting for further guidance on this although we know excise goods and licensable goods will need a Simplified Frontier Declaration pre lodged in advance of the goods arrival.

Goods arriving in the UK with a Community Transit (T-form, NCTS, T1, or T2) document will be excluded from this simplification. All goods covered by a Community Transit document will need to go to an approved premises such as ChannelPorts for clearance. This is provided an agreement is in place with ChannelPorts.

To apply for this simplification registered direct with Customs using the following link:-

https://www.tax.service.gov.uk/submissions/form/transitional-simplified-procedures/Are-you-legally-established-within-the-United-Kingdom?n=0

The following link will take you to the guidance on Transitional Simplified Procedures (TSP) published by Customs:-

Click here

ΔAuthorisation to clear

ChannelPorts will only act as a Direct Representative when completing any documents, either on behalf a forwarder, Transport Company, importer or exporter.

To ensure we are fully compliant with customs regulations at the end of this pack is a declaration we will require completed and returned by all customers prior to commencement of any new business.

Due to the changes in the relationship between the UK and the EU if you are an EU registered company then this will need to be completed by the UK importer or exporter. This will also apply for all current 3rd country business. We would suggest you start requesting these from your current customers.

Does the Importer have a Valid EORI Number?

All companies will need to be EORI registered in the UK to import goods, even from the EU27. If you or your customer are importing just from the EU currently then the chances are you not registered for EORI.

What to expect on day one of a ‘no deal’ scenario: Traders importing from the EU only section

Classification of Goods – Commodity codes or tariff headings

It is the importer and exporter’s legal responsibility to provide the correct information to the Custom Broker completing the declaration.

This information should be quoted exporters or importers invoices.

The link below gives information on how to classify your goods.

https://www.gov.uk/guidance/finding-commodity-codes-for-imports-or-exports

Δ Payment of Customs taxes / Deferment Accounts

Whilst it is the UK Governments intention to use Postponed accounting for import VAT in the event of a No Deal BREXIT scenario customs duties and excise duty will be payable at the time of import. This will mean that a deferment account will be required.

For imports approved for TSP they will benefit from easier access to a deferment account.

A lot of UK companies that have a deferment will have a VAT only deferment account. This means you will need to start discussions with your clients to find out exactly what type of deferment they have. You will need this information to avoid delaying your vehicles.

All Importers, Forwarders, Transport Companies and Customs brokers will need to ensure that deferments accounts will have

  • Approval to defer customs duties
  • Have sufficient limits in place with Customs to cover all of the potential duties in a calendar month.

ChannelPorts will not be in a position to provide deferment facilities on your behalf. As a company you will need to have in place your own facilities to service your customers or your own requirements.

It is important to remember if you are using your deferment rather than an importers deferment you are liable for those charges as soon as an entry is pre lodged. You may need to consider how you secure your funds.

You need to apply for any changes to your current deferment or apply for a new deferment now.

What to expect on day one of a ‘no deal’ scenario: Traders importing from the EU.

How to apply for a deferment – https://www.gov.uk/government/publications/notice-101-deferring-duty-vat-and-other-charges/notice-101-deferring-duty-vat-and-other-charges

Δ Pre-lodgement of Import Customs Entries

This section has been updated in line with latest information published by Customs, including the new TSP approval.

If an importer is approved for simplified procedures then the haulier will to need to know

  • The importers EORI number or unique movement reference number (MRN)

or

  • For controlled goods a Simplified Frontier Declaration(SFD) has been pre lodged in advance of arrival at the RoRo port.

For shipments not covered by simplified procedures a full pre entry will need to be lodged on the system in advance of the driver’s arrival at the port.

Goods covered by a Transit (T1,T2,NCTS, T-form) document then TSP or any other simplified approvals will not apply.

  • Goods covered by a Transit document will need to go to an Approved Premises such ChannelPorts only with prior agreement.
  • Goods covered by a Transit document will be treated as third country goods for the purpose of transit to an Approved Premises exactly the same as third country goods are today.

Please make sure you read the section on Safety & Security Declarations as these declarations are required in addition to the above.

Walk-through of end to end roll on roll off process for goods entering or leaving the UK

Δ How will entries be “arrived?” – For goods not covered by an Transit (T1, T2, NCTS, T-form) or simplified approvals

By arrived we mean how customs will be notified that the goods have arrived in UK so that the entry can be updated.

For RoRo it is our understanding the driver will need to call the company completing the entry. The company completing the entry will then have to update Customs computer system (CHIEF or CDS) accordingly.

This is unless the trader is approved for simplified approvals such as TSP. In these circumstances the trader has agreement with Customs for the entry to be completed with 4 working days of the end of the month.

The exception to this is if the goods are controlled goods in which case the driver will need to call the company completing the entry for the SFD to be arrived.

Δ Safety and Security

All vehicles will need to have a safety and security declaration made in advance of the vehicles arrival at the port of departure from Europe.

Traveling by ferry this will need to be done at least two hours prior to arrival at the port of departure.

Travelling by Eurotunnel this will need to be done at least 1 hour prior to arrival at the Eurotunnel terminal.

A safety and security declaration will not be needed if the goods are moving under Transit (T1, T2, NCTS, T-form) procedures as the information required by UK Customs will be contained within the information that is sent to them at the time the Transit is issued in the country of departure, for instance France.

Our understanding that in addition to a safety & security message being required for the UK authorities a safety & security may also be required by the EU. This is something that you will need to clarify with your partners. Currently we are still waiting for updated guidance to be issued on this subject by UK authorities and once this is issued it may well clarify this point.

It is ultimately the responsibility of the haulier actually providing the vehicle to ensure all the necessary Safety & Security Declarations are completed.

We understand software will be required to submit this information.

Δ Controlled Goods – High-risk food & Feed, Goods of Animal origin – EU27

The guidance issued in version 1 of our overview has been updated by Government and we strongly recommend that all parties involved in the import of products listed below study fully the impact on their business and put in place the necessary processes.

  • Live animals
  • Animal products
  • Fish and fishery products
  • High risk food
  • Feed not of animal origin

The link below as well as giving information on imports from the EU27 also gives information on the chances to imports from 3rd countries.

Traders importing live animals, animal products and high-risk food and feed not of animal origin from the EU and the rest of the world – what to expect on day one of a ‘no deal’ scenario – https://www.gov.uk/government/publications/partnership-pack-preparing-for-a-no-deal-eu-exit/what-to-expect-on-day-one-of-a-no-deal-scenario-traders-importing-live-animals-animal-products-and-high-risk-food-and-feed-from-the-eu-and-the-res

Later in this pack you will find a list of UK RoRo ports. Also a list of the current UK Border Inspection Posts (BIPs). We recommend you familiarise yourselves with the information provided by Customs as there are changes to which ports are able to take certain 3rd country goods.

These can be found online at:- RoRo ports – https://www.gov.uk/guidance/list-of-roll-on-roll-off-ports

List of Border Inspection Posts – https://ec.europa.eu/food/sites/food/files/animals/docs/bips_contact_unitedkingdom.pdf

Controlled Goods – Plants and plant based goods – EU27

For the companies importing any plants, fruits, vegetables or plant based materials then you will need to ensure that you have a system in place to

  • Obtain the necessary certificates from your suppliers, such as phytosanitary certificates.
  • Pre-lodge advance a notification of arrival which will require a copy of the documents to be uploaded.
  • A system to notify your Customs Broker the declaration has been done and the associated reference.

PEACH remains the system for pre notification and if you are not already registered you will need to apply online. This is a quick and simple process and we recommend that you apply to become an authorised trade premises so in the event the goods do need to be inspected this can be done at your own premises.

To register for PEACH the link is http://ehmipeach.defra.gov.uk/Default.aspx?Module=Register

To register for authorised traders premises is https://www.gov.uk/government/publications/approval-of-premises-as-place-of-first-arrival-application

This also includes timber products which has its own rules and guidance can be found at https://www.gov.uk/guidance/trading-timber-imports-and-exports-if-theres-no-brexit-deal?utm_source=d8b25d9f-5d23-4b18-8669-11fd3a9525d2&utm_medium=email&utm_campaign=govuk-notifications&utm_content=immediate

Traders Importing Plants and plant products from the EU27

https://www.gov.uk/government/publications/partnership-pack-preparing-for-a-no-deal-eu-exit/traders-importing-plants-and-plant-products-from-the-eu-what-to-expect-on-day-one-of-a-no-deal-scenario

For the import of both goods of animal origin high risk food and feed and goods of plants and plant based goods given the differing nature of the types of goods being imported ChannelPorts will not undertake any of the pre notification processes. All of these will have to be done by the traders.

Impact on current imports from outside of the EU.

In the vast majority of cases the systems currently in place for the import of goods from third countries will not change. There are two areas we would like to bring your attention to:

Imports via road of animal products, or goods categorised as high risk requiring a CVED or CED.

  • As an example the import of hazelnuts or fish from Turkey require a CVED and will have to be imported via a port that has a Border Inspection Post (BIP). Whilst currently these goods arriving into the UK by road will have had the necessary checks and documents issued on the first entry point into the EU this will not be the case in the current envisaged no deal BREXIT scenario. These goods would need to be imported into a port that has a BIP. Currently Dover and Eurotunnel do NOT have a BIP so an alternative port of arrival would be required.

Preferential Agreement.

  • From day 1 of a No Deal BREXIT scenario not all Preferential Agreements are likely to apply and could result in importers having to pay duty on goods which they do not currently. In these circumstances importers will review their deferment arrangements as mentioned previously.

We strongly recommend all importers investigate for themselves if their products will be impacted by the changes.

Downloadable Files with Further Information

Below you will find links to pdf documents that contain more information. If you need to rotate the page view in your pdf reader use the pdf reader’s menu and select View> Rotate View.

  1. Partnership pack intro
  2. What to expect Day 1
  3. Importing from the EU only
  4. EU & Rest of the world
  5. Rest of the world
  6. Live animals & feed
  7. Plants & plant products
  8. Timber products
  9. Duty suspend alcohol & tobacco
  10. Medicines & medical devices
  11. Organs & tissues
  12. Drug precursor chemicals
  13. Chemicals
  14. Fluorinated gases & Ozone
  15. Waste
  16. Haulage companies
  17. Ferry or Channel tunnel operators
  18. Freight forwarders
  19. Customs agents
  20. Ports & airports
  21. Customs warehouse
  22. Temporary storage
  23. Summary
  24. Preparing for a No-Deal Brexit. Step-by-step guide to importing
  25. Imports: Channel Ports Overview in the Event of a No-Deal Brexit
  26. Ro Ro & BIPS


For more details or to discuss your requirements
call 01304 203 105 or click here to enquire online.