January Brexit Changes

Author - Max Tweddle

Date published:

Changes to EU – UK trade coming in January 2022

There are 5 key areas in which there will be changes to EU-UK trade. Businesses need to be prepared for them from the 1st of January 2022 onwards.

Following the transition period after the UK’s departure from the European Union, the UK government is introducing import controls on goods moving from the EU to Great Britain. The changes being implemented will bring EU imports in line with the imports into GB from the rest of the world.

Full details of the changes can be found in the Border Operating Model (BOM), which now includes details for goods being imported to Great Britain from the island of Ireland.

January 2022 Onwards

1. Customs Declaration Changes

Changes to the timescales to submit import customs declarations and what will be required from 01/01/2022:

  • From 1st January 2022 it will no longer be possible to delay Customs declarations as was granted by the easements in 2021
    • Unless the goods are being imported from the Republic of Ireland – as announced on 15/12/21 the easements in place for imports into GB from the island of Ireland will remain in place until further notice.
    • Further detail is available here.
  • GB Importers receiving goods from the EU will have to submit a Customs import declaration to HMRC prior to their goods being allowed to be loaded to the cross-channel transport modality (ferry, channel tunnel or aeroplane) that will deliver the goods to the GB frontier.
  • Many businesses that trade outside of the EU use a customs intermediary to submit declarations to HMRC.
  • Information required for completing a Customs declaration include
    • GB EORI number for the importing business
    • Commodity Code of each product in the consignment
    • Customs procedure code
    • Origin of goods
  • The commodity code information on the tariff will show if import duty or VAT is applicable for the product and will also identify if there are any tariff quotas applicable to the goods when imported into the UK. List of tariffs applicable to UK importers is available here.
  • The UK has a free trade agreement with the EU, meaning that it is possible to import certain goods from the EU with zero rated duty.  The origin of the goods determines whether this is possible or not.
  • The North East England Chamber of Commerce can assist you with customs declarations through its compliance focused ChamberCustoms Brokerage service for UK import and UK export declarations including for GB-NI movements. For more information, visit this link.

2. Goods Vehicle Movement System

The Goods Movement Vehicle System (GVMS) will become a requirement for all GB non-inventory linked ports to create a Goods Movement Reference (GMR) from 01/01/2022:

  • The GVMS GMR links the truck to the consignment of goods that it is carrying.
  • All hauliers responsible for the carriage of goods across the channel via non-inventory linked GB ports should be registered to use the system
  • Non-UK based hauliers need to be registered to use the GVMS system. To be able to register they must have a GB EORI number. To register on the system a government gateway ID is also required
  • GVMS entries to create GMRs are required for import and export movements through non-inventory linked ports, the current list as published by HMRC is available here
  • Consignments will only be able to board their intended cross channel transport once the GMR has been generated.
  • In order for the GVMS entry to be created and generate the GMR, the details of the road transport must be known, the ferry operator, or if it will travel through the Channel Tunnel. Details from the GB customs entry will also be required such as the Declaration Unique Consignment Reference (DUCR) or Movement Reference Number (MRN).
  • A link to the GVMS registration page can be found here.

3. Origin Declaration

Under the EU-UK Trade and Cooperation Agreement (TCA) zero rated duty is available on certain commodity codes as detailed in the UK tariff for goods of UK or EU origin. The easements that have been in place during 2021 to support origin statements are being removed from 01/01/2022:

  • From 01/01/2021 under the TCA, proof of origin for goods was not required in the form of a supplier declaration at the time of export to make an origin statement on the commercial invoice.
  • The grace period allowed exporters using origin statements until 01/01/2022 to get the legally required supporting evidence from suppliers to cover exports made during 2021.
  • This changes from 1st January 2022, supplier declarations must be held by the exporter prior to the origin statement being made on the commercial invoice for exports in 2022.
  • The supplier declarations held by exporters do not need to be sent to overseas customers, they are only for official customs audits.
  • There has not been an easement period for importers declaring preference during 2021
    • Exporter preference statement or importers knowledge has been used
    • Importers bear the burden if they claim preferential duty rates
  • From January 2022, all European suppliers must have a Registered Exporter (REX) authorisation. It is necessary for the REX number to be shown on the Commercial Invoice for eligible goods to enter the UK with zero rated duty.
  • UK exporters do not need to hold a REX, the GB EORI number is used instead.
  • Any eligible goods arriving at the UK Customs border without the REX number stated on the Commercial invoice will not be able to benefit from the zero-rated duty.

4. Import of Products, Animals, Foods, and Feed System (IPAFFS)

From 1st January 2022 it will be necessary for pre-notifications to be sent to the Department for Environment, Food and Rural Affairs (DEFRA) and the Animal and Plant Health Agency (APHA) via the IPAFFS system for goods being imported into Great Britain from the EU (with the exception of the Republic of Ireland).

  • To send the pre-notifications from January 2022 onwards, UK importers of Products Of Animal Origin (POAO), Animal By-Product (ABP), High Risk Food not of Animal Origin (HRFNOAO), plant and plant based products, composite products and germinal products must register with the web-based service called Import of Products, Animals, Food, and Feed System (IPAFFS):
    • To register for IPAFFS the importer must have a GB address
    • Businesses do not need to be approved to set up an IPAFFS account
  • Pre-notification via IPAFFS must be submitted per consignment and not per truck
  • Submission must be made at least 4 hours in advance of the goods arriving in GB
  • Imports into GB from the EU (excluding direct imports from the Republic of Ireland) only need to use IPAFFS and do not need to use TRACES.

5. Commodity Codes

On 1st January 2022, the UK trade tariff will be updated in line with the changes made by the World Customs Organisation (WCO) to the Harmonised System Nomenclature for 2022.

  • The update to the UK trade tariff will create approximately 5500 changes to commodity codes
  • Details published on the changes to date by HMRC are available here
  • All businesses submitted customs
  • If there is any uncertainty in which commodity code should be used for a product you can apply to HMRC for an Advanced Tariff Ruling, applications must be made prior to shipment
  • Details made available to date show that the 2022 amendments show an increase in the requirement for supporting documentation and an increase in the number of commodities classed as dual use.

If you have any specific queries relating to your business, HMRC can be contacted directly with queries regarding imports, exports and GVMS. Details of which can be found here.

If you would like any further details, or support on how to manage any of these changes, please contact [email protected]  

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