As the EU puts pressure on the UK Government to put proposals for a new deal in writing within the next two weeks and the Commons leader reported as saying that the Prime Minister was on course to deliver a "fundamentally different" Brexit deal to ensure the UK leaves on October 31st, how closer are we now to a no deal or even if an agreement is reached how different will it be to that presented to Parliament previously and what if any transitional measures will be included for a government who does not want to be tied to the EU Customs Union or Single Market. 

Anyone listening to the radio or driving on the motorways will have heard and seen the constant reminders that the UK will leave the EU on the 31st October and that on the 1st November Freight may change and to check documents.

HMRC have also published a number of papers which if you have not seen, some are listed below.

For those of you looking to operate Transitional Simplified Procedures then please remember if the goods are entering via an Inventory Linked Port it will still be necessary to get a release from the port inventory system even if you are just making an initial declaration in your records (EIDR) , this may involve an action by you or you forwarder / broker. We understand the details are still being finalised and awaiting HMRC approval.
Specifically, for CHIEF, whilst the proposed temporary tariff is not yet available, the following changes which will be implemented in the case of a no deal can be tested on CHIEF via your test environment.

Imports from the EU

If goods require a frontier declaration at RoRo locations the goods must be declared as Pre-Arrival or Pre-Lodged. 
The current list of RoRo ports can be found here and new port codes have also been created:

  • Dover / Eurotunnel DEU
  • Eurotunnel EUT
  • Killingholme KIL
  • Purfleet PUF

Specific field completion rules:

  • The declaration type must be IMD (Full Declaration), IMF (SFD), or IMK (C21)
  • Transport Mode must be 6 for designated RoRo ports
  • Transport ID should be the vehicle registration and or the trailer number
  • An Additional Information Statement “ROIMP”

Once the goods have arrived then you will need to amend the declaration and change the declaration type to

  • IMA (Full Declaration), IMC(SFD), or IMJ (C21)

This must be done by the end of the next working day after the goods arrived in the UK.

Where a simplified or EIDR declaration is made then a supplementary declaration must be submitted by the 4th working day of the month after the goods arrive unless any extension has been agreed by HMRC. 

We understand that in the TSP authorisations there is mention of declaring your Entry in the Declarants records authorisation number (GBEIR******). Whilst this is possible in CDS there is no specific instructions on how to do this in CHIEF, in the absence of specific guidance we would suggest a GEN45 Additional information Statement at Item level or in the Goods Description.

Exports to the EU

At RoRo locations goods must be declared as Arrived

  • The declaration type must be EXA (Full Declaration), EXC (Simplified Declaration), or EXJ (C21). A new field is visible to capture this.
  • Transport Mode must be 6 for designated RoRo ports
  • Goods Locn Cntry and Goods Location where the goods are intended to export the UK from.
  • An Additional Information Statement “ROVRN” with the vehicle registration and/or trailer number.
  • For Excise goods, or any other goods requiring an actual departure notification, a second Additional Information Statement “RODEP” which will suppress the CHIEF auto departure process. In such cases the exporter must arrange for a departure notification to be made in CHIEF either via a loader or HMRC.

In case you have missed it we have also made the following enhancements in the e-Customs application:

  • Ability to choose a template when creating an EMCS movement from an import declaration.
  • Ability to choose a template when creating an export from an EMCS movement
  • The ability to create a single NCTS movement from multiple exports.
  • For more details please refer to the e-Customs release notes.

Irish Land Border

Should any declarations be required a new goods location code has been created:

  • Irish Land Border ILB

An Additional Information statement NIROI is required where the Goods Location is ILB or an exiting NI Customs Office. If this is not present duty and VAT may be calculated as normal by CHIEF.

Transit

Transit remains an option to move the goods via ports without the need for presenting additional declarations, however the transit movement will need to be completed at an authorised location e.g. an approved temporary storage facility either under Normal or Registered Consignee arrangements. If you do not have a temporary storage facility and are interested in operating one for Road movements please contact us.

Postponed Accounting

In the case of a no deal Brexit then the UK will introduced VAT Postponed Accounting for all UK VAT Registered Traders, this though relies on declaring the correct method of payment “G” against any VAT tax lines. If “G” is not declared CHIEF will take the VAT amount from the declared payment method type.

Written by Martin Meacock

Director, Product Management