The Brexit transition period will finish at the end of December 2020. There will be no extension to it. It is therefore vital that companies check now that they understand what this means to their business and that they are ready for the implications. Your Export Department’s Jim Fanshawe share some tips with Construction Worx Lite readers.
Regardless of whether or not there is a Free Trade Agreement with the EU there will be an increased workload, mainly administration, for importers and exporters alike. There are many ways the end of the transition period could impact your business, including Incoterms, employees, contracts, FX strategy, product approvals. However, for now let’s just focus on some of the key considerations around customs and the movement of goods.
For both importers and exporters…
- Check you have and know your EORI number and that it appears on all relevant paperwork. If you don’t yet have an EORI number register here – https://www.gov.uk/eori
- Check your Incoterms®. (https://2go.iccwbo.org/)
a. In particular are you selling to EU customers on DDP terms. If so, you may need an EORI number in the EU. This is because you are responsible for the import entry in the destination country as well as any due import duties and taxes in destination country.
b. Or for importers are you buying from the EU in Ex-Works (EU named place) terms? This is because you are responsible for the export entry in the seller’s country.
- GB goods to the EU will be treated as third party country exports
- How are you going to handle your export entries
- Internally – Are you sure you can handle this and have trained staff to do it?
- Broker – Talk to them to make sure you can provide the information they require.
- Freight Forwarder – Talk to them to make sure you can provide the information they require.
- Check what duty payments may be applicable in the case of no trade deal. If you sell DDP you will be liable to pay these, if not DDP then your importer pays but you still need to know as it impacts the in-market price of your goods
- Check with your importer in the EU that they have done what they need to make the import declaration and have all necessary import licenses (if required).
- Check if any additional licenses or certification is now required for your goods.
- i.e. strategic export controls – goods that currently move licence free may now require licences, particularly dual-use items.
- Is your wooden packaging (e.g. pallets) ISPM15 compliant.
- Check your paperwork. Commercial invoices will be required for EU destined goods. This means named consignee, named destination and commodity codes in particular amongst other things.
- I doubt CEA members will require Export Health Certificates but check just in case!
- How will you make your Safety and Security Declarations?
- Does anyone in the business understand Rules Of Origin and their implications? (If there is a trade deal this will be essential).
- VAT implications – Are you collating and keeping sufficient evidence of export to zero rate VAT?
- Continue to submit Intrastat information
- Use the Simplified Customs Declaration or entry in business records upfront for speedier customs entries. Supplementary declaration is then required within 4 weeks.
- Exporters can consider using Single Export Declaration which combines customs, safety and security data and is submitted before goods are exported.
- If it is for temporary movement of goods do you know how to use the ATA carnet system?
- How are the goods getting to the final destination? Consider (with your freight forwarder) using Transit. For example if goods are travelling through France before getting to final destination Transit could be a good option.
- Discuss the SFS (Smart Freight Service) that is being developed for RORO freight with your freight forwarder.
Your Export Department is a CEA Service Provider. Jim is happy to assist CEA members (mention you are a member when contacting him) and other exporters with all matters Export and Import.
Contact Jim Fanshawe Your Export Department Ltd. firstname.lastname@example.org