2021 has been a trying year for businesses attempting to recover from the worst impacts of the pandemic.
The new year will be upon us soon, and that means getting briefed and being ready for the latest piece of the EU exit jigsaw to fit in place – the introduction of GB inbound border controls on goods arriving from the EU from 1 January.
In NI, arrangements for goods moving to or arriving from the EU continue as in 2021, under the Protocol. Goods moving from ROI into GB will enter GB as they did in 2021 until the negotiations on the Protocol are completed in 2022 – and will not follow the new requirements above for the rest of the EU until notified by the UK Government.
Several aspects change at the GB-EU border immediately on 1 January, while others will be phased in through 2022, until 1 November. At that point, all of the GB inbound formalities and checks on EU imports will be in place.
Here’s what you need to be ready for as an importer in GB, and speaking to EU suppliers (excluding those in the Republic of Ireland for now) and customers about ahead of 1 January:
- Expiry of easement on suppliers’ declaration usage not being required at time of export. Companies can prove origin through an EUR1 certificate supplied by their Chamber of Commerce, a statement of origin made on a supplier invoice, a suppliers’ declaration being in place at the time of export of the goods or for goods arriving in GB, or by relying on 'importer’s knowledge'.
- Expiry of easement on deferred supplementary customs declarations (importers have been permitted to defer these by up to 175 days during 2021). Declarations will need to be made at the point of entry alongside the goods from this date (although some traders may be authorised in advance on application to make simplified declarations).
- Check whether the UK Commodity Codes for your goods have changed. 351 sets of amendments are being made, impacting over 5500 HS Headings and Subheadings.
- Introduction of GVMS (Goods Vehicle Movement System) in GB. Your customs broker, hauliers or freight forwarders should be able to create a GVMS entry for your goods - now is the time to speak to them. The system is easy to operate and should not incur any costs, ChamberCustoms provide this service free to their customers.
- Pre-notification of plant products and products of animal origin before consignments leave EU for GB begins. Goods not pre-notified to the UK IPAFFS database cannot travel.
From 1 July 2022 safety and security certificates will be required to accompany inbound consignments from the EU into GB.
For GB exporters to the EU, the corresponding easement on the use of suppliers’ declarations to declare the origin of the goods for consignments being exported to the EU also expires on 1 January 2022. Firms that have not obtained authorisation to use simplified declarations by 1 January must make full customs declarations at the point of entry of the goods from that date, quite different from the practices they have followed in 2021.
Border Control Posts are being constructed at ports and border entry points across GB.
For animal and plant products, prenotification has been partly decoupled from the documentary and physical checks to provide a further grace period of several months duration. From the middle of the year documentary checks of export health certificates (EHCs) for products of animal origin, phytosanitary certificates for plants and plant products, together with identity and physical checks of some consignments, will be introduced at BCPs in three phases:
- 1 July Documentary and identity checks on plant products and meats or meat products from the EU begins from this date.
- 1 September Documentary and physical checks on dairy and dairy products from the EU begins from this date.
- 1 November Documentary and physical checks on fish, fish products and composite products (ready meals, meat or fish pizzas, cream liqueurs) from the EU begins from this date.
The changes on 1 January are not completely confined to imports to GB.
Some new requirements for GB exports to the EU come in on this date too:
- The easement on the use of a suppliers' declaration to declare the origin of the goods for consignments being exported from GB to the EU also expires – so suppliers’ declarations will be required
- GB exporters sending goods to France will be required to register in France for VAT purposes, even if they have already registered for VAT as a third country seller in another EU member state. This is due to the French General Directorate of Public Finance (DGFiP) not the General Directorate of Customs and Indirect Taxes (DGDDI) being responsible for collection of import VAT on third country imports from 1 January and new online systems being introduced.
Importers and exporters in GB should speak to ChamberCustoms, their local Chambers of Commerce, hauliers, and any fiscal representatives about these changes and ensuring their suppliers and customers know what is required, and indeed their own duties as an importer or exporter. Rules will not change for NI importers/exporters of goods to the EU, but it is still worthwhile checking in with NI Chambers of Commerce and ChamberCustoms to re-familiarise how the Protocol works on NI-EU trade.