With just 10 days to go; prepare for a no-deal Brexit

With just 11 days left until the Brexit deadline, the Prime Minster’s hopes of a third attempt to get her deal through parliament may have been dealt a fatal blow by the speaker, which means that forwarders, carriers and shippers need to prepare swiftly for the worst-case scenario and a no-deal Brexit.

Our recommendation to our customers, and all shippers, is that they should continue preparing for such a scenario, regardless of whether Theresa May’s plan finally succeeds or is put to a last-minute public referendum before the March 29 deadline, because last week’s vote against a no-deal exit was advisory and would require new legislation.

NO-DEAL DAY ONE

TARIFF

The government has issued temporary tariffs, which has denoted 87% of goods at zero, if the UK does finally leave the European Union without a deal.

It appears that the new tariffs are being reduced or eliminated where there are no British producers to protect, with around 5,000 tariff lines that are zero and 470 with a tariff.

Follow this LINK to open our Excel spreadsheet* of all 470 tariff lines and check out your commodity codes to see if any duty rates apply. If it’s not shown the rate is zero.

NOTE – These tariffs apply to EU to UK flows (excluding NI)

EORI

If you have only been importing from the EU you must register for an EORI number now, or you be unable to arrange import transport, or clear your good through customs. The government can process 11,000 applications a day, but don’t delay, as there are close to 200k applications outstanding. GET AN EORI NUMBER – https://www.gov.uk/eori

CUSTOMS

Customs declarations will apply to ALL imports, even if no duty is due, and you will need a deferment account if you want to use the new Transitional Simplified Procedures (TSP).

MIQ Logistics can prepare and lodge your customs declaration and you can use our deferment number, if any payments are due HMRC.

Under Day 1 ‘Easements’ initiatives, HMRC will not require compliance with the usual EU criteria for a customs comprehensive guarantee (CCG) and traders will have until 30 June 2019 to submit a financial guarantee to HMRC to back their deferment account.

TSP

Traders must obtain an EORI and register to use Transitional Simplified Procedures, if they want to delay the lodging of full customs declarations. Use this LINK for TSP registration. https://www.gov.uk/guidance/register-for-simplified-import-procedures-if-the-uk-leaves-the-eu-without-a-deal

The next stage is to complete the direct debit mandate when supplied and you will need a Customs Comprehensive Guarantee (CCG) to set up a deferment account, however under Day 1 ‘Easements’ initiatives, traders will have until 30 June 2019 to submit a financial guarantee to HMRC to back their deferment account.

You will need to submit a TSP return for all imports by the 4th working day of second month.  We can handle this for you or assist you to manage in-house.

Most goods brought into the EU from a 3rd country must be pre-notified in an ENS, for safety and security risk analysis purposes, and will continue after Brexit. Even with TSP every import will require an ENS declaration before the goods arrive. ENS HAS BEEN POSTPONED FOR FIRST 6 MONTHS!

The TSP road movement process:
1. EU exporter raises an EAD (Export Accompanying Document)
2. Exporting Customs computer generates an MRN (Movement Reference Number)
3. Driver uses MRN number to check in at the export port (He will not enter without it)
4. Driver uses TSP approved UK EORI number to board the ferry/Eurotunnel
5. Frontier declaration submitted up to two hours before boarding ferry/Eurotunnel
6. Driver moves through port to inland destination
7. Duty/VAT settlement is made on 15th of calendar month
8. Final declaration made by 4th of following month

TSP will be reviewed 3 to 6 months after 29 March 2019 and a 12 months’ notice will be given when HMG decide to withdraw or amend it.

*With thanks to our Brexit expert Robert Hardy