The end of January sees several customs changes that will have a significant impact on Irish exporters to the UK. Brian McNamara discusses what you need to know to avoid delays and charges
After several delays, HMRC will finally introduce full UK import checks on goods coming from the island of Ireland. On the same day, the UK Department for Environment, Food & Rural Affairs (DEFRA) import controls will also begin for certain food and plant products coming from the European Union.
Below are three important points businesses moving goods to the UK should be aware of in relation to these changes:
1. UK import declaration and goods movement reference
The biggest change from 31 January is that UK customs filings must be done prior to departure of the goods. Up to this point, there has been an easement in place allowing the import declaration to be carried out after the event.
From Wednesday next, if the UK import declaration has not been submitted, the goods simply won’t get on the ferry in Dublin or Rosslare.
Further, truck drivers will need to scan a goods movement reference (GMR) document when checking in with the ferry company. The import declarations for all goods on the truck need to go into the GMR.
Exporters should talk to all parties in their supply chain (freight companies, clearance agents and UK suppliers) and get comfort that all necessary documents will be in place to ensure their goods keep moving.
2. DEFRA controls
The 31 January also sees the introduction of health controls on the import of certain foods of animal origin (FOAO), plants and plant products from the EU.
While the EU insisted on such checks on UK imports straight away on 1 January 2021, the UK government elected to delay the introduction of a similar regime.
These DEFRA import requirements include the advance notification of the consignment on the UK’s IPAFFS system, and the submission of an export health certificate for certain goods.
DEFRA has classified all FOAO, plants and plant products as either low, medium or high risk. The exact requirements each category of goods is subject to will depend on their risk classification.
Exporters in the agri-food and plant industries should get a clear picture of the risk category of their goods and ensure all necessary steps are taken.
As with the general UK import controls, if the correct submissions are not made, the goods won’t move.
3. Repairs/goods moving for processing
Ireland is a smaller market than the UK. In some industries there isn’t the same level of capability locally, so it’s not unusual for goods to go to the UK for repair or further processing.
A common misconception concerning customs is that, if goods are not being bought/sold, people think there is no import duty due on them – machinery moving to the UK temporarily for repair, for example.
This is not the case, however. Once goods cross a customs frontier, an import declaration is required, and the goods are potentially liable to import duty.
It is possible to gain relief from import duties on goods entering the UK temporarily by using Customs Special Procedures such as Inward Processing or Temporary Admission.
However, businesses should be aware that it can take time to properly put these procedures in place. Taking short cuts could lead to the goods getting stuck and/or incurring import duty and VAT.
So to an extent, the full impact of Brexit will only now be felt by Irish companies moving goods to the UK. To stay on top of this, businesses should make sure that all the correct documents are in place to keep their goods moving, minimise import duty and stay customs compliant.
Brian McNamara is MD at SwiftFile Customs.
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