Busy week in Brexitland…. Some of the new processes mentioned below concern only the english importer. We have given our assessment and will forward more detail as and when received.
Whilst the deadline for requesting an extension is officially 30th June, the real date was 12th June (at least from the UK’s side). That has passed and UK have formally confirmed [to the EU] that they will NOT be requesting an extension and will not agree to one should the EU request. So, that’s it. 31st December is set in stone. If any part of your Brexit preparations relied on some form of extension, you need to re-visit immediately.
SOFT LAUNCH for UK Import
UK have announced a phased approach. This phased approach relates to UK imports only (whether that be from mainland EU or IRL). The headline details of which are:
– From 1st January 2021 standard UK imports will have access to a process known as CFSP EIDR (Customs Freight Simplified Procedures, Entry In Declarants Records). To all intents and purposes this will look like TSP. Certain goods are excluded and WILL require frontier declarations (excise goods for example). The full list will probably resemble the TSP controlled goods list by launch. Under CFSP EIDR you have up to six months to present the import entry, but you MUST keep records of arrivals. We understand that this easement will be available to all without the need to apply for it.
– From 1st April 2021 SPS* will require health certification and pre-notification (IPAFFS), but very few physical checks will take place.
SPS controls will be relaxed initially, except for example live animals and high risk plants (probably those covered by the plant passport scheme). This was the case with TSP.
– S&S (Safety and Security) declarations will NOT be required on UK imports until 1st July 2021
– From 1st July 2021 CFSP EIDR will be turned off, unless you have applied for full ongoing approval. Frontier declarations will be required in all cases from 1st July.
– full SPS checks will be in place. Documents, TRACES NT, IPAFFS and goods will need to enter via a BCP (Border Control Post, formerly known as a BIP). It is not clear yet whether all SPS will need to visit a BCP, equally we do not yet know where the BCP’s will be. Some will be inland.
*SPS = Sanitary and phyto-sanitary (products of animal origin, plants, vegetables, fruit and produce). Fish could also require additional control in the form of catch certificates although we have recently received details of a process called APEO and will be in touch with seafood shippers shortly.
DUTY JUST GOT EASIER (INITIALLY)
One of the invisible benefits of TSP was that duty (if any) became a transaction between HMRC and the importer directly. The logistics provider, freight forwarder or broker did not need to secure payment. This would be particularly useful when incoterms are DAP or similar. CFSP EIDR appears to do the same. Remember it has an end date (30th June 2021) but at least for the first six months, UK imports can be handled by consignor (the logistics provider) having to worry about the duty liability.