Whilst there may be a deal in the offing, the prospect of a no deal remains very real. Ironically it now comes down to the House of Commons. They have rejected no deal countless times but are now faced with the prospect of voting for the new deal or risk a no deal exit. That said there is still the possibility of a second referendum…and so the merry-go-round continues..
The panic that this has created puts pressure on all of us. Try as we might we simply cannot respond to everybody individually. We are getting 500+ messages a day (through various channels) whilst at the same time being engaged in vital meetings with Customs, installing new software, moving offices and training new recruits so we can handle 3000+ Customs declarations a day from day one (in case of no deal).
In an attempt to answer most of your questions we have decided to list the more common ones asked by traders:-
1. Pallets
As it stands all exports from UK to EU must be on ISPM15 heat treated pallets. The pallet must bear the IPPC stamp. Just because it is a ‘euro’ pallet means nothing. Currently pallets from EU to UK do NOT need to be heat treated but if EU insist on ISPM15 then UK have threatened do the same (in order to create the pool in the UK). For now, if you are sending pallets to UK (that might go on to Ireland), send on ISPM15 pallets. If we have to transfer to our limited stock of ISPM15 the charge is normally £20 per pallet. If you are sending goods for export make sure you are using ISPM15 compliant pallets.
2. TSP (Transitional Simplified Procedure)
If you are a UK established importer you most probably qualify for TSP. If you do not currently have TSP, hold tight as HMRC have recently confirmed that they are auto-enrolling all qualifying companies. If you are not established in the UK, even if you have a UK VAT and EORI number, you do not currently qualify for TSP. This may change but right now it is for UK established only. Agents, freight forwarders and Customs brokers cannot obtain TSP (as they are not importers). If you are not UK established we can still handle your UK import clearances if you complete and return our standing authority if you have not already done so. We cannot act on your behalf without this document. Then, please complete IMPORT section each time you have a consignment destined for the UK.
3. What information do we need for the import or export declaration (UK and Ireland only)?
We’ve given you options. Use the templates available by emailing me or via the GET DOCUMENTS button on: https://www.mybrexit.uk/what-do-i-need-to-do or complete the web form at: https://www.mybrexit.uk/Customs_Entry. The choice is yours. All three methods will get the information to us. Our favourite is the GET DOCUMENTS option!
4. Dummy run.
Some of you have asked if we can do a dummy run for imports or exports. Not really. But if you would like to use one of the methods above we can use your data as part of our training and it will also allow us to create templates. We will not be sending you anything in return as the systems are not live linked as yet. Please do send us data for a ‘real’ import or export so we can at least test our systems with your data.
5. We supply on a DDP basis. What do I need?
DDP is often the least friendly incoterm (guide available from me). If you are importing to UK on DDP you will need UK VAT and EORI registration. We cannot clear the goods without this information. If you do not currently have UK VAT and EORI registration then please visit: https://www.mybrexit.uk/VAT_EORI If you are exporting on a DDP basis you may need VAT and EORI registration in the destination country. NI to ROI for example, on DDP, you will need VAT and EORI in ROI. In most cases you do not need a company but you will need registration.
6. My goods are zero rated for VAT – can I just have a UK EORI.
Technically yes but it is not good practice. Customs have confirmed that we can act as a direct representative if you have a UK VAT number (assuming in this scenario that the entry is being presented in the UK). If you do not have a UK VAT number (but just a UK EORI) we are forced to act as an indirect representative. We will do initially but we will not act on an indirect basis in the long term. Get a VAT number!
7. What is Oakland’s TSP number?
We get asked this a lot. No idea why! We do not have TSP as we are not an importer, see above. We do have an EORI number, via our contract. Even if we had TSP I would not give out the reference number and neither should you. You only need to give your EORI number to those that ask. Only give your full 32 character TSP number to the agent you have chosen to look after your TSP returns.
8. Do I require a health certificate?
If you are importing products of animal origin to UK then no, you do not need a health certificate. There has been some conflicting information recently concerning the need to create a IV66 form and update IPAFFS but this does not relate to imports from the EU. Imports from the EU do not require health cert or IPAFFS. Exports from UK do! See separate section on this.
9. Do I need a transit document for EU to UK?
No. We just need a copy of the commercial invoice and a copy of the export declaration raised in your country. You do not need transit unless you are going through UK to Ireland (or from Ireland through UK to mainland EU), which brings me to…
10. Transit from EU to EU through UK.
If you have goods subject to health or phyto controls you do not generally need certification to import to UK. However, if you are in transit through UK, you WILL need health or phyto as appropriate.
11. I bring goods to UK for retailer and some might go to Ireland.
When goods come in to UK there may be duty to pay. If goods are then sent to Ireland you may have wasted paying that duty. Worst still you might need to pay duty again in Ireland!. The way to avoid this is for all goods to go in to bonded warehouse until the final destination is known. Sounds simple. It is not! If you put 100% of your stock in to bond you will incur higher storage charges and import entry charges for each exit from the bond. This could quite easily be more than the duty you might have wasted for the stock which eventually ended up going to Ireland (even though it was imported to UK). Don’t forget we have chilled and frozen storage facilities in Dublin. If you know what stock is for Ireland, send it to Ireland (without clearing it in the UK first). Don’t forget, you will need a transit document for those goods and a health certificate. If you ship directly from mainland EU to Ireland (without passing through UK), you need nothing extra.
12. I am exporting from UK, is that difficult?
Yes! If normal goods then we can raise the export declaration for you with minimal disruption. Make sure your customer knows he will need to arrange an import in his country, unless you are selling on DDP terms in which case you have to arrange everything. If you are exporting products of animal origin, you will require an export health certificate. His can take up to three days. Speak to your local vet and make sure you have arrangements in place. We can’t help you with export Customs documentation until you have the health certificate arranged. UK Government guidance available.
13. Some of my products are fish based. Do I need anything different?
Yes! You will need a catch certificate for importing to UK. We are awaiting clarity as to whether this covers such things as a tin of tuna (or even salmon ravioli) and will keep you posted.
14. Can we look after imports and exports for you?
Yes in most cases we can, in UK and Ireland. If duty is payable we might ask or a deposit payment in advance to cover the duty. If you need export transit we might ask for a bond from you to cover the transaction. (does not include Consortium members).
15. We have applied for UK VAT registration but it has not yet come through.
There are some delays at HMRC. We have applied for hundreds of UK registrations and most go through pretty quickly (about 4 weeks). Some seem to get stuck in the system from one reason or another. We have seen cases where HMRC send an email requesting additional info but we have no record of it. In some cases we have to re-apply as the original times-out. If you are waiting for your UK VAT registration be assured that we are chasing it. In some cases we have obtained UK EORI numbers only for those that are delayed and we can act as your import agent if you need assistance until your VAT number comes through.
16. Do I need a deferment account for TSP.
Yes but not yet. Your first TSP entry must be lodged by the end of April 2020 and you will need a deferment to pay any duty that might be due. We would suggest that you do not apply for a deferment until the Brexit exit conditions are known.
17. I hear there have been amendments to the UK no deal import tariff?
Yes, there have been some changes. We have an xl file that shows what the rate was in Mar19 and what the new one is. We have highlighted in this document any changes. You should also refer to: https://www.gov.uk/government/news/temporary-tariff-regime-updated
18. Who needs to do what and when?
A very common question. We have updated our graphic, which you can request.
19. We need training can you help?
Yes! We are part of the Government funded training programme. In many cases you can get full funding to cover our training fees. What do we cover in our training? See this : https://www.mybrexit.uk/training and how do you get the funding? Follow this link: Apply for grants if your business completes customs declarations
20. Still need help?
Come along to one of the events that we are speaking at. The next one is 24th October in Lutterworth. To sign up, follow this link: https://bit.ly/2MD67IN
The following documentation to support the above information is available by emailing me: robert.hardy@oakland-international.com: ICCs Incoterms 2020, The Brexit Process – Who Does What & When, HM Government’s Farmers And Food Producers and our Proposal For Customs Representation/Standing Authority To Act As Customs Representative.
* Information is correct, to the best of our knowledge and belief, at the time of publishing but we take no responsibility in the event of incorrect or misleading information. This service is provided free of charge and without liability or obligation.
Robert Hardy, Commercial Director, Oakland International/Oakland Invicta