Brexit: your 5 step ‘no-deal’ plan for customs declarations
If the UK leaves the EU without a deal, UK businesses that import or export goods will need to apply the same procedures to EU trade that apply when trading with the rest of the world.
Under the current system, goods imported into the EU are only released from Customs if a full import declaration is made and any duty paid in full at the time of import.
There is a risk that, if you do not have the appropriate systems set up, there will be delays in delivery times and possible additional cost. You may therefore be behind the competition. If we leave without a deal these changes take effect from when we leave. If this is 31 October, as widely predicted, there is not much time left to make sure that you are prepared.
Follow the five steps below to help prepare:
1) Apply for an Economic Operator Registration and Identification (EORI) number
Currently you only need an EORI number if you trade with non-EU countries. You will need to apply for an EORI number if we leave the EU without a deal.
This will enable you to trade goods into or out of the UK and submit declarations to HMRC. You may also need another EORI for the EU.
It takes 10 minutes to apply and currently takes three days to be issued. Obtain an EORI number here.
2) Consider the Transitional Simplified Procedures
The Transitional Simplified Procedures (TSP) have been brought in by HMRC to reduce the administrative burden at the time of importation post Brexit.
It is primarily aimed at VAT registered entities that import goods from the EU (whether a freight forwarder is used to complete the import paperwork or not) on a semi-regular basis. Goods are not normally released from Customs control until a full import declaration has been made and any Customs duty and VAT have been paid in full. These simplified procedures reduce the amount of information needed at the time of importation essentially delaying the need to submit a full declaration and pay any duty.
You can register for TSP here.
3) Seek Authorised Economic Operator (AEO) status
AEO status is recognised internationally as a quality mark and demonstrates that you have sufficient controls and procedures in place. This is aimed at larger business that have significant trade outside the UK. Depending on the type of AEO authorisation the key benefits can include access to customs simplifications and deferment guarantees or waivers. There is a lead time for authorisation possibly of around four months which should be taken into account.
There has been speculation recently that the EU countries may not, in the event of a no-deal Brexit, accept AEO status that has been awarded by HMRC and give preferential status to UK businesses, but until that is confirmed (and in any event for the purposes of facilitating goods moving at UK ports and airports) the consensus of opinion is that an AEO application is a sensible precautionary step.
You can apply for AEO status here.
4) Review the current simplification processes
There are a number of reliefs and simplification measures that currently exist to ease non-EU trade, and these may assist when we leave the EU. Examples include:
- Inward processing relief
- Outward processing relief
- Temporary admission
- ATA Carnets
- Common Trust Convention (CTC)
- Transit Simplifications
- Authorised consignor/consignee status
- Setting up a Customs warehouse/storage facility
- Duty deferment
5) Read our VAT and Duty guide: Brexit update and practical considerations!
Our one-page guide sets out some of the basic questions that arise as a result of a no-deal Brexit and is designed to be a helpful resource when prioritising your actions ahead of Brexit. Download your copy here or in the ‘Downloadable documents’ section below.
There is no one-size-fits-all situation and specific advice should be sought depending on your particular circumstances. For further information please contact our VAT and Duty specialists, Rupert Moyle, VAT & Duty Partner here or Colin Laidlaw, VAT & Duty Director here or phone us on +44 (0)330 124 1399.
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