18 September 2019: Available easements

Having attended a number of Border Delivery Group seminars and Government “Task and Finish” meetings, below is a list of the easements that have been extended for the current Brexit date of 31 October 2019. In a ‘No Deal’ scenario, these easements will help goods move smoothly through the border and reduce impact on your supply chains.

Re-acceded to the Community Common Transit Convention (CCTC)

  • No double duty on 3rd country goods destined for the UK but transiting EU
  • Covers EU goods destined for Ireland but transiting the UK.
  • This is very important for all our exports, as for all exports moving beyond the first EU country of landing. i.e, lands in Calais, France but is destined for Spain the UK will be required to complete a transit document under the rules of the Common Transit Convention.

European Conference of Minister of Transport (ECMT) permits

  • EU limits the UK to 1,224 per year (demand is approx. 38,800) EU confirmed it will recognise UK community licences for a period of 9 months post the original Brexit day of 29 March ’19.
  • On 5 Sept ‘19 it was confirmed that this easement has now been extended a further 9 months from the new Brexit day of 31 Oct ‘19, meaning July ‘20.

A separate EU safety and security declaration required for imports (in addition to the import customs declaration)

  • It is required 2 hours before the ferry departs/1 hour before the train departs.
  • The data set required was originally 44, now down to 22.
  • The UK secured a 6 month easement from the original Brexit date, which would have taken us up to Oct 2019. This easement has now rolled forward and extended to 12 months, so it will now not be required until 31 Oct ’20.

Transitional Simplified Procedure (TSP) for imports only from the EU to the UK

  • This easement has now been extended and the final declaration under TSP will now not be required until 5 May ‘20 – 6 months from 31 Oct ’19.
  • Only available for non-controlled imports, where the importer keeps an Entry in Declarants Record (EIDR) at the importer of records UK registered office.
  • Controlled goods are covered by TSP but require a Simplified Frontier Declaration (SFD) at the port of arrival.
  • The importer of record has to register for TSP to enable them to use it. Registering themselves will provide them with a TSP registration number.

Government secured capacity for medicines and vaccines

  • The UK Government is in the ITT process to secure approved suppliers to provide additional capacity if required for vital medicines and vaccines. Status of the ITT process is: they are in a 10 Cooling period before announcing who the suppliers are that will switch on this extra capacity as and when required.
  • We have been informed that the Cooling off period will close on 23 September 2019, so an announcement will follow shortly after this date.

​​​​​​Temporary Tariff Regime (TTR) in the event of a no deal Brexit

  • 87% of imports by value would be eligible for zero-tariff access.
  • The Government is still working in this area to increase the 87%, so their advice is to keep a close watch for the next 10 working days as there may be further additional tariffs that fall to zero.
  • It should be noted that goods which are shown as zero now through this easement will not be reversed to have duty applicable until the TTR finishes in 12 months.
  • This Temporary Tariff Regime (TTR) would apply equally to all imports from all countries where the UK does not have free trade arrangements in place, including the EU.

​​​​​​​​​​​​​​Accounting for import VAT in a no deal Brexit – postponed VAT accounting will return

  • If your business is registered for VAT in the UK you’ll be able to account for import VAT on your VAT Return. This means you will not have to pay when the goods arrive at the UK border. This easement applies for all goods arriving in the UK (EU and 3rd country arriving goods)

EORI registration – automatic EORI registration has been completed

  • ​​​​​​​All VAT-registered UK firms not already signed up to the Customs system will have received an EORI number.
  • If you are non-VAT registered you will be required to apply for an EORI number manually.

Goods moving between Ireland and Northern Ireland

  • For most movements of goods across the land, air and sea borders between Ireland and Northern Ireland, you will:

    • need to pay import VAT on goods arriving from Ireland
    • not need to get a customs agent or an EORI number
    • not need to pay Customs Duty or make customs declarations
    • the only exceptions will be for goods liable to Excise Duty (alcohol, tobacco and certain oils)

​​​​​​​​​​​​We hope this acts as a good summary of the easements that have been put in place to help facilitate flow in a ‘No Deal’ scenario.