Deferred Customs Entries

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

As of 1st January 2021, HMRC are allowing businesses to defer entry of their Customs declarations on goods imported or exported for up to 6 months. In essence this will maintain the security of the supply chain during what promises to be a period of upheaval for businesses which trade with EU partners.

As a business, the most important consideration is whether the deferring of the declarations works for your commercial business. You will still be required to input all the relevant information from your records into your commercial systems at the time of the transaction, even if you don’t send this to your freight forwarder immediately. However, it does allow you to continue importing business critical goods without incurring potential delays while setting up the new process.

If you are interested in this option, there are a number of factors to bear in mind.

EORI

Any UK company importing goods from the EU should have a GB EORI number.

Know your goods

Make sure you are fully aware of your customs obligations in relation to your goods. For example, what is their tariff code? Do your goods attract customs duty? Do they require any other certification, such as an import licence, health certification or certificates of conformity? Does your import declaration require any additional support documentation?

Controlled goods

The deferred declaration process is not applicable in the case of controlled goods, so businesses which import or export these must follow the normal rules for making import declarations.

Controlled goods include:

• Alcohol products
• Tobacco products
• Fish
• Fertiliser
• Plants
• Animals
• Explosives

VAT requirements

Is your business registered for UK VAT? Do you need to be registered for UK VAT? If you wish to use Postponed VAT Accounting, then a UK VAT registration is a necessity to allow this facilitation. All business should retain within their commercial records the import transaction information to ensure accurate duty and VAT is being paid.

Commercial records

Before importing the goods, it’s important to ensure that your business records are of a sufficient standard to document and maintain all the relevant information. In addition to the standard import transaction information held, companies will be expected to record the date and time of arrival of the goods within their commercial premises.

Timescale

Should you wish to defer making an Import Declaration – you have up to 6 months to submit the Supplementary Declaration to HMRC. Of course, no business would want to be in the position of having to make all their declarations at the same time, so it’s worth putting in place a process for the declarations to be made within a business acceptable timeline.

Monies will be taken from the Deferment Account when the supplementary declaration / deferred declaration has been submitted.

Who will be making the declarations?

Customs Freight Agents can make the declarations to Customs on your behalf. Does your business have a preferred Customs Freight Agent? If you have engaged the services of a Customs Freight Agent, have you checked whether they can or will make Deferred Customs Declarations for your business? Have you asked them if you can utilise their Deferment Account, and is there a cost associated with doing so?

Alternatively, if you intend to make your own Customs Declarations, there are several important considerations. Do you have personnel with the necessary experience and specialist knowledge to carry this out on behalf of the business? Do you have the necessary software to complete these Declarations and communicate with HMRC?

If so, your business will require a Deferment Account, which must be set up and authorised by HMRC prior to your first deferred declaration being presented.

And finally….

The legislative requirements surrounding customs declarations are subject to change at the moment. For the most up-to-date information please visit: https://www.gov.uk/prepare-to-import-to-great-britain-from-january-2021.

As ever, we are here to help. If you’d like to discuss these changes, and how they may affect your business, please get in touch.

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

The Free Trade Agreement and your Business

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

As the end of the Brexit transition period looms ever closer, we’re all eagerly waiting to find out whether the UK government and their EU counterparts can reach a Free Trade Agreement.

Any such agreement would allow ‘free’ trade between the EU and the UK. It would mean that, if we have a full Free Trade Agreement covering all the relevant sectors, the rate of duty would be 0%, allowing the movement of goods without the payment of any additional duty. So far so good, but there are still several changes in the pipeline that you need to consider, regardless of whether an agreement is reached or not.

Declarations

There seems to be a common misunderstanding that a Free Trade Agreement would remove the need for any additional paperwork. This is certainly not the case! Businesses must still adhere to all the standard administrative regulations from trade bodies such as HMRC, HSE and DEFRA. Anyone exporting goods from the UK will still be required to complete export declarations in the UK, and ensure that goods are formally imported into the EU with an import declaration, and vice versa.

In order for HMRC to process import / export declarations, detailed and comprehensive documentation must be submitted to them, so it’s vital that you factor in the additional time and cost of consolidating all of this information, as well as process time with HMRC and other Government bodies.

Contracts

With this increased volume of official documents required across the supply chain, it’s imperative that businesses pay close attention to the terms and conditions of contracts, particularly in relation to risk and the liability for making declarations and paying any relevant duties.

EORI numbers

It’s also worth noting that businesses may require both EU and UK Economic Operators Registration and Identification (EORI) numbers in order to make import / export declarations. If you have already held or been allocated one of these, you can apply to HMRC online. It’s a straightforward process which typically takes HMRC around 3 days to approve.

Trade Tariffs

Finally, businesses should also be aware of both the UK and the EU trade tariffs for their goods, regardless of whether there is a Free Trade Agreement in place or not. Depending on the terms of sale previously agreed with the customer, the liability for paying any additional duties may well lie with them.

If you’d like to discuss these changes, and how they may affect your business, we’d be happy to have a chat. You can get in touch with us at: info@bethancc.com.

Smooth Sailing – Customs Planning Advice for Port Authorities

Exporting support Bethan Customs Consultancy

As things stand, it’s full steam ahead for the end of the Brexit transition period on 31st December 2020. This will have significant implications for port authorities in relation to the customs procedures and documentation required for goods being imported and exported.

Customs entries

Previously free circulation goods were allowed to move within the EU with no tax or duties payable. However, all EU states will now be classed as a third country, and vice versa. As such, port users should be aware that customs entries will be required for all cargo, and may be required to show that the goods comply with EU standards.

Port authorities should also consider whether they have the correct approvals in place to allow commercial businesses / customers to import and export goods through the port?

It’s also worth checking whether port users have the relevant Economic Operators Registration and Identification (EORI) numbers. EORI should be held by all UK and EU businesses looking to import and export goods, from / to each other. Previously EORI numbers issued in the UK would have been accepted in the EU. However, post 31.12.2020, there will be GB EORI and EU EORI numbers. Therefore, all businesses within the supply chain should ensure they have the appropriate EORI.

Temporary storage facilities

All goods being shipped to the EU will require a pre-shipment security declaration before departure, potentially delaying vessels loading/departing. Consideration should be given to whether goods will need to be temporarily stored within the port site.

Any such storage facility must be approved by Border Force, meeting their specific criteria for security purposes, and allowing goods to be examined and customs cleared with minimal disruption.

Import and export documentation

While draft legislation in relation to exports is in place in the UK, the EU’s full expectations will be revealed in the final trade agreement.

So it’s vital to be prepared for changes to UK requirements. The likelihood is that port users will need to liaise more with HMRC in order to progress the clearance of goods. More documents will be required when importing and exporting goods going forward – for example, goods being exported to the EU will require documentation proving that they meet EU standards.

Port approvals

Businesses which currently hold approvals within the EU for importing and exporting may find that these no longer apply in the UK. There is still some uncertainty regarding how the situation will be resolved, but there is the potential that these approvals could be invalid once the transition period ends. Going forward, the onus will be on businesses to ensure their approvals remain valid.

Access to Government agencies

Something else to bear in mind – Government agencies are more likely to be visible within port areas post 31st December 2020, including HMRC, Border Force, Police, Trading Standards, Food Standards, Fishery authorities.

If you’d like to discuss these changes, and how they may affect your business, we’d be happy to have a chat. You can get in touch with us at: info@bethancc.com.

Fancy Joining Our Team?

Compliance Executive…

We currently have an exciting opportunity for a Compliance Executive to join our highly experienced and passionate team.

We are looking for a self-motivated individual with excellent knowledge of customs legislation and a full understanding of supply chain procedures.

If you have the following experience, we would love to hear from you:
– Several years experience within a similar role
– A positive “can do” attitude
– Excellent communication skills
– Excellent knowledge of Microsoft Excel, Word and Power Point

For more information or to apply, please send a covering letter along with your CV to:  nicola.alexander@bethancc.com

Closing Date: Friday 23 October 2020