Important new post-BREXIT procedures for businesses importing and exporting goods to and from the UK
Amongst several procedural changes now impacting businesses due to BREXIT is the need to use an EORI number (Economic Operators Registration and Identification) as an identification number in all customs procedures when exchanging information with Customs administrations.
The UK now has its own customs regulations and customs tariff; click here for more information: https://www.gov.uk/guidance/uk-tariffs-from-1-january-2021
Imports from the EU will be treated the same as the rest of the world, so this means they will be subject to a range of customs regulations, declarations and duties/tariffs based on their country of origin and value. Exports of goods to the EU will again requiring customs declarations and potential tariffs in the EU.
The new Free Trade Agreement (FTA) allows for certain goods that meet the specific origin list rules to be shipped between the EU and UK free of duty. However, the onus is on businesses to determine whether goods meet the origin list rules and how to provide evidence and certification of this.
What should you do now?
1. Examine the customs impact of Brexit (customs’ duty costs, customs declaration costs etc.).
2. Work with customers and suppliers to determine who will take on responsibility for exports, imports, customs’ costs and compliance.
3. Implement mitigation planning to reduce customs costs.
4. Highlight and address the barriers to movements.
5. Ensure you hold the necessary authorisations including EORI number and fiscal representation. For the EORI number in particular, your business will likely fall into one of the following categories:
- Business in the UK; to trade goods with EU countries, you’ll will need an EORI number that starts with GB. However, if your business only moves goods between Northern Ireland and the Republic of Ireland and nowhere else, it will not usually require an EORI number.
- Businesses moving goods to or from Northern Ireland; if you move goods to or from Northern Ireland, you’ll need a second EORI number that starts with XI. This includes moving goods between Northern Ireland and the rest of the UK and moving goods between Northern Ireland and non-EU countries.
- Businesses making declarations or getting customs decisions in EU countries; if your business makes declarations or gets customs decisions in an EU country, you’ll need to get an EORI from the customs authority in the EU country where you submit your first declaration or request your first decision.
6. Engage customs brokers, freight forwarders or other parties to make the necessary customs declarations and determine documentation, data flows and processes to control this (this area is subject to audit-based control).
7. Determine the necessary customs elements (classifications, origins, valuation adjustments etc.) required by the customs declarations.
Other things you could do now in preparation are:
Find out how to declare goods and check the rules for importing goods such as:
a. Licences or certificates needed.
b. Marking, labelling and marketing standards.
Also, consider the impact on excise goods (alcohol, tobacco and certain oils) and check the rates of tax and duty you will need to pay on these as well as non-excise goods. Finally, review your trading terms and conditions (such as Incoterms) for your sales and purchases.
If you require any further information on matters raised in this briefing note, please email Paul Townsend – pt@london-corporate.co.uk
- on December 15, 2020