In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The most recent Trader Support Service Bulletin is available, and HMRC has now appointed its technical delivery partner for the Single Trade Window. A consultation has been launched on introducing a voluntary standard for customs intermediaries, and HMRC is seeking more information on the role of the accountant and/or chief financial officer in business decisions on whether to use the Common Transit Convention. HMRC is also writing to businesses that complete export declarations, and it is also confirmed that the long-awaited duty reimbursement scheme will open for claims from the end of this month. The Institute was also in attendance at last week’s UK Domestic Advisory Group (“DAG”) meeting and raised questions on the Windsor Framework.
UK DAG meeting
The Institute is a member of the UK DAG, and was in attendance at last week’s meeting which gave group members the opportunity to put questions to Pedro Serrano, the EU’s Ambassador to the UK, Sir Oliver Heald, Leader and Co-chair of the UK-EU Parliamentary Partnership Assembly, and representatives from the UK Government.
The Institute asked the Ambassador if he was able to share any insights from the EU in respect of how the Windsor Framework (“WF”) is being implemented, from the perspective of potential discrepancies between the UK and EU publications on the framework, and if the EU is satisfied that the new goods movements red and green lane processes will be ready from September 2023.
The Ambassador responded that the ongoing relationship between the UK and EU remains positive and all possible work is being doing to implement the WF in the agreed manner. The UK Government also responded to this question and said that the Government is very committed to implementing the WF, and more information and guidance will follow as soon as possible, in addition to the guidance published last week. The UK is working very closely with the EU on that information and guidance.
Duty reimbursement scheme
After much lobbying by the Institute, including our letter earlier this year, it is now confirmed that from 30 June 2023, the UK Government will launch the reimbursement scheme for EU duty paid on “at risk” goods which can be shown to not have entered the EU. More information on how the scheme will work was also provided at a meeting on the Windsor Framework several weeks ago, attended by Chartered Accountants Ireland – see our stories here and here.
The scheme will be backdated to 1 January 2021, and will also apply to red lane goods movements which should originally have been green lane, under the WF revised trade operating model. The Customs (Northern Ireland: Repayment and Remission) (EU Exit) (Amendment) Regulations 2023 underpin the scheme. It is not yet clear if HMRC will pay interest on overpayments received under the scheme.
Single Trade Window
Deloitte, working with IBM, has been announced as HMRC’s chosen technical delivery partner to build and maintain the platform on which the Single Trade Window (“STW”) will be hosted.
The STW aims to simplify traders’ interactions with the border. The World Customs Organisation (“WCO”) defines such Single Windows as ‘a facility that allows parties involved in trade and transport to lodge standardised information and documents with a single-entry point to fulfil all import, export, and transit related regulatory requirements’. The STW, at its core, ensures a single-entry point for border data, which results in reduced duplication for users. HMRC aims to work closely with Deloitte and IBM to ensure stakeholders’ views continue to be fed into the design of the UK STW.
Consultation on introducing a voluntary standard for customs intermediaries
As announced at the 2023 Spring Budget, a consultation has now been launched on the proposal to introduce a voluntary standard for customs intermediaries, with the aim of improving the quality of service across the sector. This consultation closes on 30 August 2023 and This will seek views on:
- the objectives of a voluntary standard, and what format it could take;
- how a voluntary standard could be designed and implemented;
- the potential content of a voluntary standard; and
- training and educational offerings for the intermediary sector, which would support the introduction of a voluntary standard.
This consultation will be of interest to customs intermediaries, traders (particularly those who use or are considering using a customs intermediary), and any other members of the border industry with an interest in and/or understanding of the customs intermediary sector.
HMRC will be holding webinars regarding this consultation where policy officials will explain further the scope of the consultation and the consultation process. If you would like to attend one of these webinars, please contact HMRC by emailing customsintermediariesconsultation@hmrc.gov.uk.
The Common Transit Convention and the role of the accountant/chief financial offer
HMRC has sent the below request on the role of the accountant/chief financial officer in the context of the Common Transit Convention (“CTC”).
“We would like to understand better the role of the accountant and/or chief financial officer in business decisions on whether to use the CTC or not, when importing and exporting goods to the European Union and other European countries, so that we can shape future guidance and communication products to key decision makers.
Who we are?
We are from the Transit Policy Team in the Customs Policy and Strategy Directorate in HMRC. The CTC is a European wide Convention that the UK acceded to in our own right on Exiting the EU. It allows signatories to the Convention to move goods easily across multiple customs territories until the goods arrive at their final destination, where Customs Duties and VAT are paid. This means that the Duty and VAT are suspended until the final destination, offering cash flow benefits to businesses.
What we do?
We are working on improving our support and guidance on the CTC to help businesses decide if it may be useful to them. And in the Chancellor’s Spring Statement we announced a package of Transit simplifications for businesses, particularly those using the CTC Trusted Trader scheme which allows businesses to start and end Transit movements at their own premises rather than going to a government office at the port. More information on these measures can be found here.
We’d love to talk to you, if you would be interested then please contact us at transitpolicymailbox@hmrc.gov.uk.”
Moving to the Customs Declarations Service for exports
HMRC is currently writing to businesses that complete export declarations to make them aware of the key dates for transitioning from the current CHIEF system to the Customs Declarations Service (“CDS”) by the end of November 2023. Traders should therefore check that HMRC has the correct email address to ensure that they are informed at the right time.
From 1 December 2023, all export declarations must be made through the CDS. However, traders should not try to move export declarations to the CDS before September 2023, unless contacted by HMRC.
Currently, specific types of export declarations cannot be made through the CDS and must still be submitted using CHIEF. HMRC is writing to businesses making these declarations to inform them of when they can start using the CDS.
The current timetable for full transition of export declarations is as follows:
- from May 2023, HMRC has been contacting traders submitting the highest number of export declarations but only through the Goods Vehicle Movement Service, and has advised them to start making export declarations through the CDS.
- from July 2023, HMRC will contact all remaining export declarants to make sure they are ready to make export declarations through the CDS by setting out the actions they need to take and signposting to relevant guidance.
- from September 2023, the CDS is expected to be open for making declarations for all export routes.
Next steps
Traders that have not already done so should carry out the following steps to prepare for making export declarations through the CDS:
Contact HMRC with any questions.
Miscellaneous updated guidance etc.
The latest guidance updates, and publications relevant to EU exit are as follows:-
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