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Policy & Compliance


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procedures will need to be undertaken to complete the export. UK guidance advises that our authorities are unlikely to


introduce additional checks on inbound goods. Having read the guidance, the UK authorities will require hauliers, etc, to have evidence that a customs declaration for imports has been submitted or that the goods are being imported under Transitional Simplified Procedures (see page 16). On exports, a full customs declaration will have to be


submitted via CHIEF to the NES, which incorporates the export safety and security declaration. The European Commission has issued guidance notes on


customs-related matters in the event of a no-deal Brexit. It is clear that in a no-deal scenario the UK will be regarded as a third country for customs, VAT and excise purposes – there will be no special waivers for UK goods entering the EU. Effectively this will mean that both a customs and safety and security declaration will be required for UK goods entering the EU. In addition, UK EORI numbers will not be recognised in the


EU and vice versa. The EU has clearly stated that UK AEO authorisations will not be recognised in the EU (see page 9 for further detail). In addition to the purely Customs changes, there are new procedures for health checks on export consignments containing animal products. Fish-catch certificates will also have to be provided. The UK has waived the need for a safety and security


declaration to be completed for inbound consignments, but the relevant statutory instrument states that one will be required one year after 31 October 2019. For UK-destined consignments from outside the EU, these declarations will no longer be made to the country of the carrier’s first call within the EU but to the UK, a considerable increase in HMRC’s workload: approximately 80% of all maritime movements arrive


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somewhere else in Europe before berthing at a UK port. Whilst mainly of concern for importers and exporters,


forwarders should be aware that in a no-deal scenario there will be impacts on the rules of origin. UK-originating content will not be accepted as being EU content within goods or similar products under the EU’s Common Commercial Policy.


Government actions Over the coming weeks leading up to Brexit, government will be communicating to businesses in the UK either directly or via Trade Associations to inform them of actions they should take to prepare to leave the EU without a deal on 31 October. Current Government advice is that all traders should:


1. Check the guidance the government has published about the changes that will affect them at www.gov.uk/government/collections/trading-with-the-eu-if- the-uk-leaves-without-a-deal


2. Stay up to date with important new information by signing up to HMRC’s EU Exit alert service at www.gov.uk/email- signup/?topic=/government/brexit BIFA will continue to make Members aware of developments


in government policy via its website and we would suggest that the above website addresses are monitored on a regular basis by Members who are significantly impacted by Brexit. Putting aside the problems of dealing with a government


that has failed to fully comprehend at least the short-term impacts of the biggest economic change since 1993, the biggest problems facing our sector will be trying to adapt to new routines such as Transitional Simplified Procedures, and collect and process the vast amount of additional data that will be required for trade with the EU if the UK leaves the EU without a deal – or will it?


October 2019


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