If the UK leaves the EU without a deal on 31 October 2019, trade between the UK and EU would revert to World Trade Organisation (WTO) terms. This means the movement of goods between the UK and EU would be subject to customs duty and controls.
Here are the top 5 steps Northern Irish businesses that trade with the EU should take to prepare for a ‘no deal’ Brexit from a UK customs and tariffs perspective. Note these do not apply if you only import directly from the Republic of Ireland – the UK government has announced it will not apply customs duties or controls to goods crossing the land border.
First, you should apply to HMRC for an Economic Operator Registration and Identification (EORI) number if you don’t already have one. An EORI number is needed to import from and export to the EU after Brexit.
Secondly, apply to HMRC to use transitional simplified procedures (TSP) when importing. TSP allows your business to defer payment of customs duty and submission of import declarations when you import goods into the UK after Brexit. Under TSP, this can be done in the following calendar month rather than when the goods cross the border.
Thirdly, consider how you will submit customs declarations. These must be submitted to HMRC for each consignment imported to or exported from the UK. You will either need to use a customs agent to make these declarations, or acquire the special software and training needed to do this yourself.
Fourthly, determine your commodity codes and the tariffs payable on your imports and exports. The classification of your products will determine what tariffs are paid when you import goods into the UK, or your goods are imported into the EU. The tariffs payable on import into the EU are determined under the EU’s Tariff. The UK government has announced a temporary import tariff that will apply when goods are imported into the UK following a ‘no deal’ Brexit. This eliminates or reduces duties on many goods.
Fifthly, consider whether any customs special procedures or reliefs could help your business – these could eliminate or mitigate the tariffs you face. These include transit relief (for goods moving from the EU to the UK and then back to the EU), customs warehousing (to avoid double taxation on goods bound for the EU), processing relief (for manufacturing in the UK using EU components, where the finished product is exported to the EU) and temporary admission.
You should also consider the changes to the VAT treatment of your cross-border trade, whether you need to comply with any licensing requirements, and which party in your supply chain will deal with customs formalities and bear any duties.