There will be a phased approach to border control, starting with some controls from 1 January 2021 and moving to full controls for all goods from 1 July 2021.
This means that from 31st December 2020 until 1st July 2021:
- Most traders importing most goods from the EU to GB will now have longer to prepare, and can delay the submission of information and payment of customs duties to HMRC for up to 6 months after the point of import, with full customs requirements introduced from 1 July 2021
- The requirement for safety and security declarations on imports Entry summary Declarations (ENS) will also be waived for 6 months
- Traders importing controlled goods will need to prepare for full customs requirements from 1 January 2021.
Access our Brexit guides here:
- How to import goods from the EU into GB from January 2021
- How to export goods from GB into the EU from January 2021
Requirements from 1 January to 1 July 2021
- be allowed to declare your goods by making an entry in your own records, rather than a full customs declaration. A supplementary customs declaration will be required to be made to HMG within the 1st 6 months.
- Need to make a declaration if you’re moving controlled goods (e.g. excise goods). This declaration can be full, simplified, or a Transit declaration depending on the trader's authorisation.
- Need to manually arrive the declaration in HMRC systems (including entry to the EMCS - Excise Movement and Control System) for excise duty suspended goods by the end of the working day following the physical crossing if the controlled goods are coming via a location without systems that would allow you to notify HMRC that goods have been imported.
However, you won’t:
- Need to submit frontier declarations for non-controlled goods before being allowed to move your goods away from the frontier
- Need to submit safety and security information for imports
Access our guide on how to import goods from the EU into GB from January 2021 here.
- Need to submit export declarations for all goods.
- Need to provide proof to HMRC that the goods have exited the UK should you have excise goods or goods moving under duty suspense and if you’re moving the goods through a location that does not have systems to automatically communicate to HMRC that the goods have left the country
- Need to submit safety and security information either via a combined export declaration, or a standalone Exit Summary Declaration.
However, there won’t:
- Be any border locations without existing systems and infrastructure required to facilitate the presentation of most goods to customs for exports purposes or to provide automatic departure messages to HMRC.
Access our guide on how to export goods from GB into the EU from January 2021 here.
All inbound vehicles will continue to pass through locations where Pre-lodgement is mandatory, from the disembarkation ramp to the dock/terminal exit, as freely as they do now, with:
- No need to demonstrate at the arrival terminal that a customs declaration has been made.
- No need to demonstrate at the arrival terminal that a haulier has the necessary permit (if one is needed) to use UK roads or that the driver has a valid licence.
- No need to stop unless pulled out of the flow (or offloaded) by Border Force or the Port Health Authority at its selection points.
- If pulled, evidence may need to be provided to demonstrate that appropriate customs declarations have been made (e.g. a Movement Reference Number for controlled goods or the declarant's EORI for non-controlled goods).
- At locations where pre-lodgement is mandatory the ferry operator / Eurotunnel must have a reasonable belief that the goods have associated pre-lodged customs declarations prior to allowing the vehicle to board the ferry / train.
- The ferry operator / Eurotunnel can obtain reasonable belief that these have been completed through use of terms and conditions of booking.
Requirements from 1 July 2021
HMRC will implement 2 models to help control import processes
- Pre-Lodgement Model
- To ensure all goods coming into the country have declarations before they board on the EU side
- To risk-assess and clear as many import and transit declarations as possible before goods physically arrive in the UK
- To communicate to the person in control of the goods (e.g. the driver of a lorry) by the time they arrive in the UK whether goods are cleared to proceed on their journey or need a check
- Temporary Storage Model
- Applicable for those operating a customs-approved warehouse
- All goods coming into the UK arrive at a temporary storage location pre-approved by HMRC – Declaration is made within 90 days of presentation and HMG carries out any checks before goods are approved for release from the facility by HMG
For both models, you will
- Be required to make sure you have all your commercial paperwork accurate and ready to present and declare all goods to customs
- Be required to present goods or documentation to customs upon request
Your nominated freight agent will provide you with guidance on which model they will make use of and how you can best prepare.
You will need to
- Ensure goods do not proceed to the point of departure until they have permission to progress and that HMG is notified when goods have physically left the country
The government will introduce a new IT platform called the Goods Vehicle Movement Service (GVMS) to support the Pre-Lodgement model for both imports and exports and to facilitate Transit movements.
Get ready for these changes:
Key terms, definitions and regulations explained to get you Brexit-ready:
The new Incoterms 2020, the international trade terms for the sale of goods published by the International Chamber of Commerce will come into effect on January 1st, 2020, replacing incoterms 2010. Find out what this means for you here.
Import VAT currently becomes payable once goods are customs cleared into the UK. VAT registered businesses can then claim this back from HMRC via their periodic (usually quarterly) VAT returns.
From 1st January 2021, VAT registered businesses will be able (but not compelled) to use postponed VAT Accounting. This allows them to account for import VAT on their periodic VAT return rather than paying initially, and then reclaiming.
This applies to all imports into the UK (not just from the EU), and will provide businesses with an important cash flow boost as they adapt to the UK’s new trading position outside of the EU.
It is worth noting that VAT registered businesses who delay their supplementary declarations using CFSP EIDR for the first six months of 2021 must still account for import VAT on their periodic VAT return, which includes the date when they imported the goods. To do this, they will need to estimate the import VAT due from the records of imports that they are required to keep. They will be able to adjust this estimate to precisely account for the import VAT due on a later VAT return.
Non-VAT registered businesses will be required to pay any import VAT due when they make their delayed declarations.
Intrastat is the system used for collecting information and producing trade statistics on the trade of goods between EU members. Traders need to be registered and make monthly Intrastat declarations if they export goods worth more than £250,000 to the EU, or import more than £1.5m worth of goods from the EU within a calendar year.
HMRC have confirmed that Intrastat declarations will still be needed for the full year of 2021, while the same data will be made available to them via customs declarations also. This is to ensure they are able to provide accurate data to inform the UK Balance of Payments and National Accounts, and measure GDP.
The current process for ATA Carnets with convention countries outside the EU will also apply to relevant imports and exports with the EU from the end of the transition period onwards.
This means that from January 2021, ATA Carnets provide one of the options available to both businesses and individuals when temporarily moving goods between the UK and EU countries. To learn more about how the use of carnets can simplify customs procedures, contact us here.
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