Brexit Bites, 12 March 2021

Mar 11, 2021

This week’s Brexit Bites covers the postponement of health checks by the UK authorities on goods entering Britain from the EU, reported issues of NI businesses being unable to access the VAT VIES System as well as some answers from HMRC to frequently asked questions on the new trading rules.

UK postpones health checks on EU goods coming into Britain

UK Cabinet Minister Michael Gove announced yesterday that due to the COVID-19 pandemic, the UK government needed to revise the schedule for implementing certain import checks on goods entering Britain from the EU.  Many of the grace periods were just to expire on 1 April and by 1 July 2021. Customs import declarations will still be required but the option to submit supplementary declarations up to six months after the goods have been imported has been extended to 1 January 2022.

In a written statement to the UK Parliament, Mr Gove cited the challenges businesses have been facing adjusting to new requirements in tandem with dealing with the impacts of COVID-19 and said that businesses “had made a strong case that they needed more time to prepare.”

The revised timetable is as follows:

  • Pre-notification requirements for Products of Animal Origin (POAO), certain animal by-products (ABP), and High Risk Food Not Of Animal Origin (HRFNAO) will not be required until 1 October 2021. Export Health Certificate requirements for POAO and certain ABP will come into force on the same date.
  • Customs import declarations will still be required, but the option to use the deferred declaration scheme, including submitting supplementary declarations up to six months after the goods have been imported, has been extended to 1 January 2022.
  • Safety and Security Declarations for imports will not be required until 1 January 2022.
  • Physical SPS checks for POAO, certain ABP, and HRFNAO will not be required until 1 January 2022. At that point they will take place at Border Control Posts.
  • Physical SPS checks on high-risk plants will take place at Border Control Posts, rather than at the place of destination as now, from 1 January 2022.
  • Pre-notification requirements and documentary checks, including phytosanitary certificates will be required for low-risk plants and plant products, and will be introduced from 1 January 2022.
  • From March 2022, checks at Border Control Posts will take place on live animals and low risk plants and plant products.

EU countries back legal action against UK over post-Brexit grace period extension 

EU member countries this week backed the European Commission’s proposal to take legal action against the UK over its decision to unilaterally extend the grace periods for post-Brexit checks on certain goods going from Great Britain to Northern Ireland to allow supermarkets and their trusted suppliers more time to adjust supply chains.  

It’s reported that such legal action could be done via an infringement case, which could take the matter to the Court of Justice of the European Union, or trigger a dispute settlement process in the Withdrawal Agreement.  

Issues accessing the EU’s VIES system – NI traders   

HMRC are aware of problems some NI businesses operating under the NI Protocol and trading with the EU are having accessing the EU’s VAT Information Exchange System (VIES).   

If your business has not received a letter from HMRC and hasn’t notified HMRC that you are operating under the NI Protocol, you will need to take action to apply for an XI VAT number by completing and returning a G form. The XI VAT number is required to ensure the correct tax is paid when trading under the NI Protocol. There is no requirement for the business to be located in NI. The guidance and registration process can be found at GOV.UK

If you are a business with an XI VAT number, you should have access to VIES and we would encourage readers to check this.   

Trader Support Service - Supplementary Declarations 

Since mid-February, the Trader Support Service (TSS) has provided a digital platform to submit supplementary declarations for standard goods. From 15 March you will also be able to use TSS to submit supplementary declarations for controlled goods.  

For more information on Supplementary Declarations, click here

HMRC answers to frequently asked questions on the new trading rules 

HMRC have set out answers to some frequently asked questions from businesses this week including.  

Question: How do I check if goods are controlled or not? 

Answer: You can check our list of controlled goods to find out if the goods you’re importing into the UK are included. 

If you bring controlled goods into the UK from anywhere in the world (including the EU) you must follow the normal rules for making import declarations. You may also need to get special licenses or certificates for your goods. 

If you would like more information about the types of goods that are classed as controlled and what you need to do if you’re importing them into the UK, you can watch our short video that explains this. If you’re moving controlled goods out of the UK, you’ll need to follow the right procedures in place for the country you are sending the goods to. 

Question: ‌‌What is an EORI number for? 

Answer: You need an Economic Operators Registration and Identification (EORI) number to complete customs declarations or to apply for customs decisions, if you’re moving goods: 

  • between Great Britain (England, Scotland and Wales) or the Isle of Man and any other country in the world (including the EU) 

  • between Great Britain and Northern Ireland 

  • between Great Britain and the Channel Islands 

  • between Northern Ireland and countries outside the EU. 

If you have a customs intermediary (like a freight forwarder or a customs agent) to deal with your customs declarations for you, you may still need your own EORI number. 

If your businesses is based in GB, you must get an EORI number that starts with GB. If you already have an EORI number and it doesn’t start with GB, you must apply for a GB EORI number. It is free and only takes a few minutes to apply.  

You may also need an EORI number starting with XI if you move goods to or from Northern Ireland. 

You do not need an EORI number if you are trading services with other countries. 

You can find more information about EORI numbers and apply for a GB or XI EORI on GOV‌‌.UK. 

Question: Do Northern Ireland businesses sending goods to Great Britain need to make declarations? 

Answer: You do not need to declare most goods when they move from Northern Ireland to Great Britain. There’s more information about the rules for sending goods to Great Britain from Northern Ireland here

If you move goods between Northern Ireland and Great Britain, the Trader Support Service can: 

  • offer support and guidance 

  • complete any necessary declarations for you. 

Question: Do I need to make customs declarations for goods sent in parcels from Great Britain to Northern Ireland? 

Answer: HMRC have updated GOV.UK guidance setting out the extended temporary arrangements for express carriers and Royal Mail for sending goods in parcels to Northern Ireland from Great Britain. These continued temporary arrangements mean that for now you don’t need to do a customs declaration, except for prohibited, restricted and high value business to business goods. 

HMRC’s Live webinars 

HMRC are delivering daily webinars to assist businesses adjust to the new rules and keep business moving. 


  • Customs Import Declarations: An overview 

  • Exporting: what you need to do to keep your goods moving 

  • Importing: what you need to know about Staged Controls 

  • Trader responsibilities when using an intermediary. 

If you’d like to attend a webinar you can register here

Recording and slides available: Customs procedures at Irish borders

A recording of our webinar on March 10 with Cróna Clohisey, Institute Public Policy Lead who was joined in conversation with Raphael Ryan, Assistant Principal at Revenue, to discuss the customs procedures necessary to keep goods moving at Irish ports as well as the common pitfalls to avoid is available to view here

A pdf copy of the slides used in the presentation is available to download here.

Revenue suggested the following links may be useful for readers:

HMRC links

AIS - temporary unavailable Sunday 14 March

Revenue has informed us that a technical upgrade to AIS will take place on Sunday 14 March, between 10.00am and 12.00pm approximately.

During that time traders will be able to submit declarations or messages to the system but delays will occur with the following:

  • receiving an MRN for your declaration
  • receiving a routing message for your declaration
  • Revenue receiving your supporting documentation

All queued messages will be processed immediately when the system is restored.

If you require an MRN for your pre-lodged customs import declaration in order to complete your PBN but, due to AIS being unavailable, have not received same, then PBN Fallback will be available. The PBN fallback allows you to select the ‘My Vehicle is Empty’ option  when creating the PBN. 

Where you receive the MRNs after ferry check-in, then those MRNs and the PBN ID should be sent by email while the vessel is en route to:

Revenue apologises for any inconvenience caused.


Ireland: Temporary Import of horses 

Revenue have issued guidance in relation to the temporary admission procedure for importing horses from outside the EU. Find further information in Temporary import and export of horses