No extension to the transition period confirmed – No time to relax

On 12 June 2020, the UK Government, confirmed there will be no extension to the Transition Period. Import and export declarations will be required from 1 January 2021 and whilst importers will have up to 6-months to complete the declarations they should do so sooner rather than later to avoid building up a big back log and administrative burden.   Excise goods or controlled goods will be excluded completely from deferred declarations.

Companies need to account for VAT separately, probably using Postponed Accounting and undertake some basic customs record keeping or reporting if they defer any declarations but it is best practice to keep on top of the import declarations from 1 January rather than wait 6 months.

Also, from 1 January 2021, any physical checks on live animals and high-risk plants and plant products can be arranged at the point of destination or approved locations, but will still require pre-notification and health documentation.

Pre-notification and health documents for all products of animal origin (e.g. Meat, Dairy, Honey etc) and all remaining regulated plants and plant products will only be required from April 2021.

There also appears to be a 6-month relaxation on submitting UK Safety & Security declarations until July 2021, when it is expected EU-GB trade will be treated essentially the same as the rest of the world. From that date traders moving all goods will have to make declarations at the point of importation and pay the relevant duties. Full Safety and Security declarations will be required, while for goods covered by sanitary and phytosanitary (SPS) controls there will be an increase in physical checks and the taking of samples: checks for animals, plants and their products will then also need to be taken at GB Border Control Posts.

This gives business time to adapt, and time for government systems and port infrastructure to be ready. To help with this, as well as extending the current grant system for customs intermediaries, new infrastructure is planned at the ports or inland if lack of space is an issue.

GB Northern Ireland

This only refers to imports into Great Britain from the EU. It does not apply to goods imported from third countries outside of the EU. It also does not facilitate exports to the EU and for trade between Great Britain and Northern Ireland these relaxations will not apply.

After much anticipation we are starting to see details about how HMRC are proposing to manage supply chains between Great Britain and Northern Ireland.

Faced with the challenge of the Northern Ireland protocol and the need to comply with EU-UCC rules, as well as the WCO SAFE framework, two potential models that Northern Ireland Ports can choose to implement have been proposed.

1. Firstly, for those ports that already operate a port community system then that remains an option and the normal temporary storage arrangements can continue.
2. Ports could also opt for a “pre-lodged” model where import declarations into Northern Ireland would be submitted prior to arrival at the port in Great Britain to enable risk assessment and declaration process to occur in whilst transit.

What would this look like in practice?

A record is created on a new system called the Goods Vehicle Movement Service (GVMS) and a reference number is obtained. This record will contain the intended Vehicle and Trailer identification (focus thus far is on road movements but could be extended to short sea or air).

Declarations for goods intended to travel to Northern Ireland are added to this record. A Declaration could be:

• a NI import Declaration which has been submitted to Customs (currently it is the position this will be via the new CDS system only) in which case the reference would be the MRN.
• a Transit Movement, which again would be referenced by MRN.
• an EORI Number if the Irish Importer is authorised for Simplified Procedures with Entry in the Declarants Records (EIDR).

Once the load and vehicle details are confirmed this Goods Vehicle Movement Service (GVMS) record will need to be finalised and only then should the vehicle move to the GB port.

The GB ports or carriers are then being asked on arrival at the GB port to check the GVMS system to confirm that the details match and that the GVMS reference is valid.

At the point of departure, the ports and carriers are being asked to notify the GVMS system of the GVMS references that have left so that the declaration processing can begin. By the time the goods arrive in Northern Ireland a determination will have been made whether they can be released or need to be held for inspection.

For Transit, this process also will facilitate an electronic Office of Transit process to avoid the physical presentation of the Transit Document to HMRC. On this point, it has been suggested GVMS will need to be used for all ports where a Transit declaration is used to act as an Electronic Office of Transit.

Does this sound familiar? Well yes, French Customs developed a similar system ready for Brexit last year, mandating pre-lodged import or transit declarations and requiring ferry or train companies to notify them once the goods had departed. They also proceeded to work with the port of Calais to install infrastructure, including Automatic Number Plate Recognition (ANPR) that facilitates movement through the port and examination bays for those vehicles that needed to be inspected.

It is also similar to the Express Border crossing being trialled between Norway and Sweden, where again ANPR has been used to avoid the need to report to Swedish or Norwegian Customs.

The difference here is that the infrastructure does not exist at most Northern Ireland ports and the UK GVMS is still to be developed and rolled out, although HMRC are confident it will be ready in time.

Export formalities from Northern Ireland to Great Britain should be the exception, with the clearance / hold being performed before the vehicles can board the ferry.

Many questions remain:

• How will the go / no go message be sent to the ports?
• How will EMCS goods be handled?
• Will a UK EMCS movement be required up to GB port and an EU EMCS declaration be required and ready to take over on arrival in Northern Ireland?
• Will Safety & Security Declarations still actually be required? Not because of any legislative requirement but because the HMRC declaration and ICS systems cannot “talk” to each other.
• What about movements starting in the Republic of Ireland and going to the UK via Northern Ireland or goods destined for Northern Ireland from the rest of the UK going via the Republic of Ireland

We expect further information and technical details to be released over the next couple of months but what is clear is that UK business should no longer be putting off decisions over their post Transition processes.

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