Jonathan English, Strategic Projects Executive, Bord Bia - The Irish Food Board
Bord Bia’s Customs Readiness Training:
Bord Bia is running its next Customs Readiness training in Dublin on Friday 25th October 2019. The second day will take place on Friday 08th November 2019. The course will run over two half days from 9am to 2pm. Participants must be available to attend all sessions in order to be accepted on to this programme. Spaces are limited to 12 companies per course. Participation is free of charge.
Brexit uncertainty continues
Following on from the request by Boris Johnson’s government to extend the Brexit deadline, the EU27 are yet to deliver a response on how much time they are willing to give the UK, if they will provide any time at all. It is likely that one of three scenarios will take place:
1) Scenario 1: No Extension and a Hard Brexit
Under this scenario the EU27 will not provide an extension for negotiating a deal, leading to the Withdrawal Agreement not passing in the UK Parliament which will bring a hard Brexit.
2) Scenario 2: Withdrawal Agreement is accepted and a soft Brexit.
Under this scenario the Withdrawal Agreement passes in the UK Parliament which will bring a transition period and the possibility of a future Free Trade Agreement between the EU and the UK.
3) Scenario 3: extension, deal does not pass, hard Brexit
Under this scenario the EU27 will provide an extension for negotiating a deal. However, the Withdrawal Agreement does not pass in the UK Parliament which will bring a hard Brexit at a later date.
While the possibility of the Agreement passing remains an optimistic option, two out of the three of these scenarios are hard Brexit options. Therefore, all businesses should continue their no deal Brexit preparedness.
On the 17th of October, Tánaiste stressed the importance of every business, including food and drink, to continue their no deal contingency planning.
In addition to this, representatives of the UK Government at the Ireland Industry Day on Wednesday the 23rd of October also highlighted the practicalities for businesses planning for a no deal scenario as it still remains a strong possibility. Mechanisms for customs and the movement of goods under the new agreement highlighted in last week’s Brexit update, still have to be decided on by the UK Government. What has been decided on by the UK Government is the measures put in place for facilitating flow in a no deal scenario.
Moving Goods from Ireland to GB in a no deal scenario
- HMRC have easements in place from Day 1 of a no deal.
- These include: Transitional Simplified Procedures (TSPs); Intermediaries’ liability; Guarantee relaxations; and Entry Summary Declarations for imports.
- Declarations should be lodged electronically in advance to facilitate flow.
- Businesses are required to have both EU and UK EORI numbers. If companies are VAT registered, they will be auto-enrolled for a UK EORI number.
Moving goods from Ireland via GB Landbridge to Europe in a no deal scenario
- For companies using the UK Landbridge, they need a Transit Accompanying Document (TAD). The TAD must be with consignment at all times during Transit.
- HMRC confirm these goods will be tracked during transit journey.
- Under the CTC, traders can apply for authorisation to use simplified transit procedures such as Authorised Consignor Status and Authorised Consignee Status.
- Authorised Consignor Status allows traders to declare goods to transit at their premises ratherthan an Office of Departure. Traders applying for this need to have a CCG.
- Authorised Consignee Status allows traders to end transit movements at their premises rather than an Office of Destination. Traders applying for this generally need a temporary storage facility.
Moving goods from Ireland to Northern Ireland in a no deal scenario
- For most movements of goods across the land, air and sea borders between Ireland and Northern Ireland, businesses will need to pay import VAT on goods arriving from Ireland if they end their journey in Northern Ireland or move through Northern Ireland on the way to Great Britain.
- Businesses that are UK VAT registered must account for import VAT on goods they move from Ireland to Northern Ireland on their normal VAT return.
- Businesses that are not UK VAT registered must account for import VAT on goods they move from Ireland to Northern Ireland.
- Businesses will also not need to get a customs agent or an EORI number or need to pay Customs Duty or make customs declarations.
*HMRC stressed with those in attendance that all of these easements and procedures are strictly unilateral.
Moving goods of Animal & Plant Origin
There are no definitive updates from DEFRA during the Ireland Industry Day that was already covered at the CELCAA meeting in Brussels on the 2nd of October.
- One notable update is that the UK Government has plans in place for the Belfast International Airport being a Border Inspection Post (BIP)/ Designated Point of Entry (DPE) by the UK Government. However concerns were raised by companies in attendance if goods only need to travel a few miles across the border, it adds more time if goods have to travel to Belfast initially.
- Products of animal origin from the EU can enter the UK through any port on day 1 as the UK are not introducing any new controls.
- For both products of animal origin and high-risk food and feed not of animal origin, consignments that are transiting the EU to the UK from a third country will be controlled at the UK border so they will need to enter a BIP or DPE.
- TRACES – UK will not have access so they will have IPFASS to maintain security on plants and animals
- New procedures for notification will be introduced to maintain the UK’s biosecurity, minimise delays at borders and support the UK’s future import controls.
- The UK is not initiating any changes to the current categories of goods that require notification or imposing any additional inspections for goods from the EU.
- New controls will be introduced at the UK border on high-risk food and feed transiting the EU to the UK.
- Categories of goods from EU are not changing, DEFRA cannot stress this enough.
- Export Health Certificate - Obtain CITES permit before shipment of CITES compliant specimens or products and enter UK via designated Point of Entry.
- Liaising with service providers to ensure they are going to the right BIP is important
- Plant and plant products: The UK importer must pre-notify the UK authorities about the goods being imported across the UK-EU border using the PEACH system (for goods entering in England and Wales). They will need to provide scanned copies of the PC and import documents.
- Organic Products: The UK will accept organic food and feed from the EU without a Certificate of Inspection (COI) until 1 January 2021.
Notable information for businesses
The UK Government has announced a draft regulation on TRQs. Once quotas have reached capacity, higher tariffs will apply.
All food and drink businesses should consider administrative costs for completing customs declarations. HMRC believe businesses will spend £3.8bn a year on import declarations and £3.9bn for export declarations.
Upcoming UK Brexit Events that Bord Bia will be attending
25th October – FDF Workshop: Brexit Readiness – Deal or No Deal in London
31st October Current legal default for the UK to leave the EU.
1st November New European Commission starts its term in office.