Things are changing quickly at the moment. It’s hard to keep up but we’ll do our best to keep you informed. This is the first update of 2021 - they will be issued regularly as things develop. Please note that we concentrate on GB and EU and do not generally comment on XI flows except to point you towards the excellent training and guidance material provided by the Trader Support Service.
RULES OF ORIGIN
The TCA (UK/EU trade agreement) was pretty clear. If goods are GB origin then import to EU can be nil duty and similarly if EU origin shipped to GB. A preferential origin statement is required. See document 5 in our download section for detailed guidance: https://www.eori.uk/downloads
The ‘grey’ area impacts Ireland more than most: if goods are say FR origin, exported to GB, stored in a GB distribution centre and eventually shipped (unaltered) to IE they are NOT eligible for GB preferential (nil) duty. Duty is often payable on EU goods arriving in IE but not on GB goods. We realise how crazy this sounds and have been working behind the scenes to mitigate the impact.
Revenue Commissioners have issued an update ‘promoting’ the use of RGR (returned goods duty relief). To view the full text click HERE
CPC is 6110F01 if the goods were initially a permanent EU export and are now being re-imported or 6123F01 if the initial EU export was temporary.
Note: ‘returned goods’ does NOT mean ‘returned to sender’ but rather that the goods are being returned to the customs territory that they initially came from. The goods must be in their original state having not been processed whilst in GB.
Proof of initial EU export is required. The MRN number for the export declaration will normally suffice, although additional evidence may be required in some cases.
We have a Rules of Origin specialist joining our Team on the 1st March, further details will be in the next update.
PAYING DUTY IN IRELAND - TOP UP YOUR TAN!
Where import duties are due, the importer or the importer’s agent pays the duties through their Trader Account Number (TAN). Funds need to be in the account to meet the amount of duty to be paid. The standard method for topping up a TAN is to lodge funds using a Single Debit instruction via ROS (Revenue Online). This creates a credit in the TAN which will be reduced by the duty payable on the import declaration. It is not possible to ring-fence funds for a specific import entry. Credit will be deducted as import declarations are processed and cleared.
The inability to allocate funds to a specific import entry causes issues when using an agent TAN account, such as ours. If you import to IE (and your goods attract duty, i.e. not GB origin or EU origin on RGR) partial ring-fencing is possible providing you have your own TAN account. The funds loaded to your TAN can only be used on import entries in your name. Please top-up your TAN and authorise us to quote this account for entries done on your behalf. There is a set form for this which can be found HERE. You will need our EORI number which is : IE3715307RH and our full company name is EORI (Ireland) Limited.
Information on topping up your TAN can be found HERE
IRELAND: ENS SAFETY & SECURITY
You may be aware there has been a relaxation in place for some time. ENS declarations can be replaced by a dummy MRN number on the PBN. This was introduced by the Revenue Commissioners to allow traders time to adjust to the new systems. We understand that this easement is being removed from the end of February 2021. Make sure you are ready and able to submit ENS declarations in IE and contact us if you cannot.
GB - NI: UK TRADER SCHEME
If you bring goods into Northern Ireland from Great Britain you may be required to pay EU customs duty. If you know the goods are not ‘at risk’ of moving to the EU, then you can apply for authorisation under the UK Trader Scheme and will not normally be required to pay EU duty. There is no auto-enrolment, you need to apply for this authorisation and can do so HERE.
Act quickly as there are easements in place if you apply BEFORE the end of February 2021.
TRADER SUPPORT SERVICE
For the latest information and updates please visit: https://www.nicustomstradeacademy.co.uk/resources/tss-user-guides/ where you will find detailed guidance on ENS Safety and Security Declarations, Supplementary Declarations, Transit and much more…
We hope you have found this first update useful. We are pretty sure the next one will be along soon!
The Customs Clearance Consortium
+44 (0) 333 012 4819