The UK is set to leave the EU (Brexit) on 29 March 2019. While it is unlikely at this stage that this deadline will be met it would be prudent to consider how Brexit will impact your business and to put in place arrangements that will lessen the impact on your business. We have considered some likely outcomes from a Customs perspective and have put forward some general recommendations. Specific recommendations can be provided for your business if you so require. There is much speculation as to whether the UK will seek or be granted a ‘soft’ or a ‘hard’ Brexit.
It is certain that regardless of which outcome there will be an impact on Customs procedures for trade with the UK.
All goods entering or leaving the EU must be declared to Customs. This requirement will apply to UK trade after Brexit even if the UK remains in the Customs Union, retains access to the Single Market, or becomes part of the European Economic Area.
Specific issues that might arise include:
- Import/Export declarations required for trade with the UK;
- Requirement to pay VAT at the point of entry;
- Requirement to classify goods using the Combined Nomenclature;
- In a ‘hard’ Brexit requirement to pay customs duty; and
- Requirement to have a deferred payment facility.
Any of the above has the potential to cause significant delays in the movement of goods. In the event of a ‘soft Brexit’ (perhaps the most likely outcome) these delays can be overcome by the use of simplified procedures or availing of customs procedures already available.
Simplified procedures are already provided for in customs legislation but their use is subject to authorisation from Customs. Any new simplifications will more than likely have the same requirement.
Authorisation to use a customs procedure allowing for storage or processing of non-EU goods will be required. Preference will be given to Authorised Economic Operators (AEO) in the granting of any such authorisations and it is strongly recommended that you commence the application for AEO status.
We will be following the Brexit negotiations closely and will advise of any significant issues that might affect your customs arrangements.