“Let’s get going” is the tag line from the UK Government this week, which feels a bit like someone who has spent an hour looking for their car keys and working out the route whilst their partner waits by the door impatiently knowing where they will end up.
Many of you may have already waded through The Border Operating Model published on Monday 13th July and the associated guides for importing into and exporting from the UK after the end of the Brexit transition period.
Here some key points that we may not have covered previously.
Firstly, it is stressed that “All traders will need to have considered these actions before they move goods. The UK’s negotiations with the European Union will have no impact on the need to take these actions.”
Secondly, the new GVMS (Goods Vehicle Movement Service) process will play a key part in the future border model, not only for Northern Ireland, but also for Transit from the EU from 1st January 2021 and then extended later to all imports and exports by July.
As well as GVMS for exports there is also a new Smart Freight System, which appears to be more of a guidance portal and a declaration of conformance to aid traffic management around and on route to ports but details are thin as to whether any verification would be done with EU authorities or if this would be a tick box exercise.
With regards to the 6 month deferral option for non-controlled goods HMRC have already clarified that to be able to submit the declaration in the future the trader, or their appointed broker, will need to be authorised for simplified procedures; so before this option is used companies should ensure they have started the process to become authorised or have contracted with a broker who is already registered.
The document also lists what are “Controlled Goods” and as previously stated it includes not only excise goods, but also goods subject to Anti-Dumping or Safeguard measures, but apparently not Live Animals or Products of Animal origin.
It is worth noting that HMRC intend that companies or individuals with a poor compliance history will be barred from benefiting from the deferral process and will be required to submit standard customs declarations. Apparently, traders who fall into this category will be contacted by HMRC, but how will this be policed by CHIEF/CDS or expected due diligence by the brokers?
And on that point, for Postponed Accounting and checking whether a company is established within the UK, what tools will be available to help UK traders – will there be an equivalent to the current EU VIES and EORI checker services?
Even for VAT registered business the initial burden is not totally removed by deferring the declaration, they will need to estimate the VAT to report on their returns, (remember this Value for VAT is not the same as was recorded, as Intra EU traffic as will be increased by any customs duties, freight, insurance, storage and clearance costs) and corrected later once the declarations are submitted. There is therefore a continuing need for Intrastat for at least the first six months and ongoing for NI to ROI trade.
For goods of less than £135 there may be some relief for approved parcel operators to continue to bulk consignments declarations, but there is the need for business to know if the VAT has been accounted for by the seller (or e-Commerce platform) or whether it should be accounted for via the reverse charge scheme.
Overall much of the initial 6 months is similar to the previous Day 1 No Deal planning; for example - Excise Traders wanting to move goods under duty suspension will need to hold or use an Authorised Consignor, submit a full or simplified declaration before arrival, followed by an EMCS movement and subsequent arrival notification by the following day.
Initially there will be additional overheads for the handling goods that arrive in the UK from 1 January 2021 but which were dispatched from the EU before that time. EMCS cannot be used to create reports of receipt and close the movement, but instead you will need to use manual procedures.
With regards to exports up to July 2021, as per the Day 1 No Deal, all RoRo (roll-on, Roll-off) traffic will need to be declared as “arrived” and only move to the port when permission to progress has been granted. What is interesting is that from July not only will the GVMS system be used for RoRo but the ability to declare as “arrived” will be limited to certain ports, presumably this will be where the capacity to inspect goods at the port does not exist and need to be diverted beforehand to an inland facility.
On this point of diversion, the following is mentioned:
“The UK Government is developing a capability to request any consignment changes its routing or to not proceed at any point of its journey from loading (notification of intent to proceed to port) to arrival at the port. This will enable the UK Government to prioritise flow of consignments as required (e.g. Class 1 goods/perishable goods) in response to any unplanned event.”
Will this be some form of unsolicited message on CHIEF / CDS?
We are now coming to end of July 2020 and whilst we have just received notification of the NCTS service, we are still waiting on technical specifications in a number of areas, whilst some may not impact until July 2021 there are a number that will apply immediately.
- Northern Ireland CDS changes
- Northern Ireland EMCS
- Notification of RoRo exports to divert
- Smart Freight System
- GB Safety & Security
For those that are interested in passing data to other Port Systems, particularly those in Belgium and Netherlands then please contact us as we are already connected to both Portbase and the C-Point / Rx Seaport systems although you will need your own accounts.