BREXIT Update No. 6

BREXIT Update No. 6

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20/02/2019

TSP TRANSITIONAL SIMPLIFIED PROCEDURE

This will allow you to enter the UK with little more than your EORI number as the initial import declaration. It really couldn’t be simpler. For those of you (importers) where we were handling your CFSP, we have already lodged your TSP application. We expect to hear back in the next 10 days and will let you know. Unfortunately TSP is NOT currently available to freight forwarders or non-UK registered companies. We think this is a mistake and have presented our case to HMRC and senior parliamentarians as such. We await their response and will continue to push. Go to www.mybrexit.uk/tsp for further details and what restrictions apply.

WHAT IF I CAN’T HAVE TSP?

If you don’t have TSP then a pre-lodged port entry is required. The entry must be transmitted to HMRC to obtain an MRN (movement reference number). The vehicle will not be allowed to board in Calais, for example, without the MRN. Once the vehicle is in the UK, we have 24hours to ‘arrive’ the entry and finalise the import. The goods can continue as normal. This creates problems: (a) it takes time to prepare entry and likely to be all at peak periods, (b) communicating the MRN to the driver could be a challenge, (c) ‘arriving’ the entry will irrevocably charge the deferment account used for payment of import duty, if you do not have your own deferment account it might mean the agent requiring payment in advance of releasing the MRN.

ENS – ENTRY SUMMARY DECLARATION

Also known as the Safety & Security declaration. HMRC have just announced that this process will be postponed for 6 months to allow industry time to prepare. That’s another bullet dodged, for now at least. So, if you have TSP you need nothing at import border other than your EORI number on a piece of paper! It really is that simple. Note that UK exports will still require an ENS at the EU port of arrival. The HMRC relaxation relates to UK imports only.

WHAT DOES MY SUPPLIER NEED TO DO?

With UK imports looking pretty slick, what exactly does your EU supplier need to do? Assuming goods are of EU origin, very little. Your EU supplier will need to raise an export declaration (EAD) to inform his Customs that goods are being exported from the EU and are VAT zero rated as a consequence. The EAD is raised by the exporter (or his agent) and finishes at the EU port of exit. The UK do NOT require a transit document (T2) for goods clearing in the UK unless they are being cleared inland. Note: TSP is considered as border clearance NOT inland clearance. So, exporter needs only raise an EAD. No need for a commercial invoice if using TSP. UK do not require phytosanitary or health certificates for most EU goods.

DB SCHENKER SEMINAR – 10:00am GMT 21st Feb 2019

We have been asked by DB Schenker to present a Brexit seminar on their behalf and we are delighted by the opportunity. It is an honour to be associated with such a strong European logistics brand. We’ve put together some of our best slides and information so far, including border processes, who does what, when, export procedures and much more. Why do we mention it here? DBS are live streaming the event and you might what to tune in. Details here : https://www.dbschenker.com/uk-en/brexit/db-schenker-brexit-forum

AEO AUTHORISED ECONOMIC OPERATOR

We get a lot of calls about AEO. We are fans of AEO ourselves but, right now, it won’t put any fires out! Problem seems to be that the big four consultancies are still pushing AEO as a means of avoiding problems at the border and this is just not relevant at the moment. You can’t go quicker than TSP! The EU said, only yesterday, that they will no longer recognise UK AEO status and in a recent 10 point action plan issued by HMRC, AEO was a footnote. Don’t get us wrong, AEO is very much part of future life but it’s not a solution for D1ND (HMRC acronym for day one no deal!).

UK IMPORT DUTY RATES

The perennial question. We hear that NO DEAL import rates are due to be released in days. Liam Fox wants zero, Michael Gove wants some tariffs on foods, to protect UK farming and production. There are a number of options : (a) no tariff, (b) TRQ, tariff quota to control the amount allowed in at zero, (c) full tariff, (d) lower than today tariff. We suspect large parts will be (a) and certain selected foods will be (b)(d) with some high risk items being (c). We will watch closely. Have your commodity codes reading for when the news hits!

UK EXPORTS

We will cover this more completely in the next update but we want you to know that UK exports is basically a two phase process: the export declaration (EAD), which covers goods to point of export. This can be done online using the NES system or we can take care of this for you. The second part of the process is not so simple. Unlike with UK imports, a transit document is required. This document requires a transit guarantee to cover the duty and VAT liability at destination. The guarantee needs to cover all outstanding transit documents. This bond can very quickly top the £1m level and is generally causing the industry some concerns. We have flagged this to HMRC and parliamentarians and have even drafted an ESP (Export Simplified Procedure) process that could remove the cost burden on UK exporters. Will keep you posted.

Robert Hardy, Commercial Director, Oakland International

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