News & Media

14 July, 2020

Brexit Update – July 2020

What is the latest situation?

Unless there is agreement in the next few months, there will be a need to lodge import and export documents for all shipments to and from the EU, in the same way we do at present with 3rd country shipments.

The UK government is proposing to be very lenient with the lodging of import and export declarations although there is no such offer from the EU at present.

The UK Government has now published guidance material on the how the border with the EU will work after the end of the transition period on 31st December:

https://www.gov.uk/government/publications/the-border-operating-model

The customs border implementation plan for EU Movements is broadly split into three phases, as follows:

Phase 1 -

From January 2021, Importers will be required to submit a full customs declaration to HMRC for goods imported from the EU.

With the exception of controlled goods (such as Excise Goods) Importers may delay the lodgement of the customs declaration and therefore delay payment of any import customs duty. Importers must keep sufficient records of the imported goods which will need to be submitted to HMRC by July 2021.

The liability to pay Import Customs Duty at the applicable rate has been established by the importation.

VAT can be postponed. This means that UK VAT-registered businesses will account for the import VAT on the goods imported into the UK on their VAT returns and both pay and recover import VAT on the same VAT return.

Postponed VAT accounting is also being extended to all 3rd country imports.

UK Safety and Security declarations will not be required on imports for the first six months.

Export declarations and UK exit Safety and Security declarations will be required for all goods.

Phase 2 –

From April 2021, all imported products of animal origin e.g. dairy and meat products, regulated plant products, will require both pre-notification and relevant health certification, but fewer physical checks will take place than typically expected.

Phase 3 –

From July 2021, importers will be required to make full customs declarations, and full safety and security declarations, with all physical checks on Phase 2 products, animals and plants coming into force and taking place at Border Control Posts. 

None of the above easements relates to the flow of goods between Great Britain and Northern Ireland, the details of which have yet to be finalised. 

What are Controlled Goods?

Reference Phase 1 and “controlled goods”, these include excise goods such as:

  • Alcohol (wine and made-wine, beer, cider and perry, spirits), low alcohol beverages, denatured alcohol, imported composite goods containing alcohol (for example liquor chocolates)
  • Tobacco products (for example, cigarettes, cigars, hand-rolling tobacco, chewing tobacco, other smoking tobacco, unmanufactured tobacco and tobacco refuse, tobacco product manufacturing machines)
  • Hydrocarbon oil
  • Goods subject to Climate Change Levy
  • Biofuels

Plus others, including but not limited to:

  • Controlled drugs
  • Fish
  • Fertilisers - Ammonium Nitrate
  • Plants and Plant products
  • Explosives
  • Fireworks
  • Military goods
  • Nuclear materials

What do I need to do?

Firstly it is best to identify either as a ship owner a ‘cargo interest’.

The impact on ship owners is the responsibility regarding advanced safety and security declarations (ENS / EXS).

Export declarations and UK exit Safety and Security declarations will be required for all goods from 1st Jan 2021.

UK Safety and Security declarations will not be required on imports for the first six months.

There is no evidence at this stage that the EU will agree to this timescale and not insist upon on a separate declaration on UK-EU movements from 1st Jan 2021.

It may be prudent therefore to be prepared to lodge ENS/EXS declarations for movements between the EU/UK and UK/EU from 1/1/21.

For cargo interests, i.e. importers and exporters to the EU, they will need to consider what they need to do even if they are not moving controlled goods as they will be building up a liability on all goods moved after 1st Jan 2021.

Traders moving controlled goods into GB will be required to complete a full customs declaration when the goods enter GB, in line with the requirements for goods moving into GB from the Rest of the World.

Where goods are currently moved to the EU with a T2 transit document, an export entry will be required either in addition to, or instead of the T2L. A UK certificate of Origin issued by the Chamber of Commerce might also be required. This should become clear ahead of 1st January 2021.

Inchcape Shipping Services UK

Don’t leave it until Christmas to consider the impact on your business, please contact Inchcape Shipping Services and we’ll be glad to explain the exact scenario you are likely to face.

We are always available to discuss your specific Brexit questions and general enquiries; please contact us at:

Andrew Hogg
andrew.hogg@iss-shipping.com
Direct:  +44 (0) 1472 330 514
Mobile: +44 (0) 7801 397 788