This might also be of interest to you: Download our free Post Brexit Guidelines!

In addition, the impact of Russia’s invasion of Ukraine on supply chains and rising energy costs were factors in the decision to delay the measure, it said. Also to be suspended is the requirement for security declarations when importing goods into the United Kingdom.

The customs controls, which originally were to have taken effect July 1, 2022, include:

• The requirement for further Sanitary and Phytosanitary (SPS) checks on EU imports currently at destination to be moved to Border Control Post (BCP).
• The requirement for safety and security declarations on EU imports.
• The requirement for further health certification and SPS checks for EU imports.
• Prohibitions and restrictions on the import of chilled meats from the EU.

The ministerial statement goes on to say that “businesses can now stop their preparations for July and a target operating model will be published in the autumn setting out the new import controls at borders, now planned for the end of 2023.”

It is important to note in this context that import controls already in place since January 1, 2022 will remain in place.

Always keep track of current Brexit developments with a competent partner at your side. Contact your local Gerlach office now – we will be happy to support you with your customs matters.

This might also be of interest to you: Download our free Post Brexit Guidelines!

Large changes have been made by HMRC to the information that is declared, and the way a declaration is built and our teams are working hard to make this introduction as easy as possible for both our colleagues and clients. We are helping to build the future of Customs in the UK. More information to come.

Registration for GVMS is mandatory

GVMS went live on January 1, 2022. It is a new border IT system that links declaration references to the haulier, allowing it to present a single reference, the goods movement reference (GMR), at the border as proof of pre-lodged declarations.

This might also be of interest to you: Download our free Post Brexit Guidelines!

Some hauliers have faced delays bringing goods into Britain due to issues with the new border IT system – the Goods Vehicle Movement Service (GVMS) – that was introduced at the start of this year.

All transport companies moving goods through ports that use the Goods Vehicle Movement Service (GVMS) must register for the GVMS (Goods Vehicle Movement Service) and obtain a Goods Movement Reference (GMR) number to move goods within the UK. On the GOV.UK Website you find the full list of ports using the GVMS system: https://www.gov.uk/guidance/list-of-ports-using-the-goods-vehicle-movement-service

For food importers to UK – pre notification via IPAFFS system needed.

IPAFFS is a web-based service for the application for, and issuing of, Common Health Entry Documents (CHEDs) for imports from outside the EU and EEA of live animals, their products and germplasm. IPAFFS is the system used for notifying GB authorities of movements of live animals, their products and germplasm into to GB from countries outside the EU and EEA.

The notification needs to be done one working day before arrival of the goods.

For further details please check the GOV.UK Website: https://www.gov.uk/guidance/import-of-products-animals-food-and-feed-system

We will continue our efforts to update to support companies with customs matters. It is important to keep ourselves up to date on the newest regulations and assess those implications on time. For further assistance on UK side, please reach out to the Gerlach UK team.

You can no longer delay the submission of import customs declarations, as was possible under the Staged Customs Controls that applied in 2021. Most customers will have to declare their goods and pay the corresponding duties at the time of import. (see link: https://www.gov.uk/government/news/less-than-a-month-until-full-customs-controls-are-introduced)

We can expect increased Customs Checks/controls at the border starting 1. January 2022

2. GVMS usage is mandatory starting 1.1.2022:

The goods vehicle movement service (GVMS) is a UK Government IT platform for moving goods into or out of Northern Ireland and Great Britain (England, Scotland and Wales).

From 1. January 2022, every transporter is obliged to register on this platform if they transports goods from the EU to the UK under the common transit procedure (= transit document) or in transit.

Without registration in the above (Goods Vehicle Movement Service) GVMS, a carrier will NOT be able to transit the goods via any port (incl. Folkestone) in the UK using this service from January 2022. Customs will reject the vehicle upon arrival in the UK at the latest.

All ports using GVMS for goods control will then require pre-deposited declarant references which will be merged into a single Goods Movement Reference (GMR). We already know a similar procedure today with the creation of the border pass.

Transporters who have not yet registered are urgently requested to do so immediately. For this a UK EORI number is required in advance. After registration  will be received a movement reference (under www.gov.uk the steps are explained). 

3. All products of animal origin (POAO) – for example meat, honey, milk or egg products will require an IPAFFS pre-notification.

These are three of many aspects that we think are important to consider. To understand all details and get the full picture of requirements please check the gov.uk Website. A document we highly recommend to look at is the The Border Operating Model.

We highly recommend trading companies to start the preparation, especially for transport companies being prepared on GVMS usage.

For more information around how to obtain a Government Gateway Account, get a GB EORI and register for GVMS please see:

GVMS Registrations Webinar available on YouTube Link here

GVMS Registration journey (specific for Non UK haulier) available on YouTube Link here.

The Trade and Cooperation Agreement (TCA) provides for zero tariffs and zero quotas for all goods originating in the UK and the EU that comply with the relevant rules of origin.

However, as the UK has left the Single Market and the Customs Union, customs forms and additional licences, proofs or certificates may be required since January. HM Revenue and Customs (HMRC) estimates that there will be 270 million customs declarations in 2021 (in previous years there were around 55 million customs declarations a year).

5 key points about customs:

1. customs formalities (= declarations) and controls (= border controls) are required since 1 January 2021. To ensure a smooth transport to the UK, it is necessary to declare the goods both in the EU and in the UK. Export and import declaration is required
2. the agreement provides for zero duties and zero quotas for all goods that comply with the relevant rules of origin.
3. import VAT will continue to be levied.
4. additional licences, proofs, certificates are required depending on the goods.
5. an entry or exit summary declaration must be made.

Logistics:

British and European forwarders can continue to cross the English Channel without restrictions. However, in future British companies will only be allowed to unload one load in the EU and pick up a new one. Previously, up to three stops were allowed. The IT systems for border clearance had not been tested until recently, and it is currently apparent that many truck drivers do not have the correct papers with them. As a result, there are more and more long traffic jams at the borders. The British government wants to introduce its border controls only gradually until July.

Automotive:

Imports will remain duty-free, which will protect supply chains and car manufacturers’ sales. Rules of origin are particularly important for the future of the British car industry. Only finished products made up of at least 60 per cent British and European parts will be duty-free. Britain had also wanted to include Japanese parts, as Nissan is the largest manufacturer in the country and the preliminary products for e-cars largely come from Japan. The EU rejected this, but in future e-cars made in Britain will be subject to reduced tariffs.

Level Playing Field:

British and European companies can sue in each other’s courts if they suspect illegal state aid. Governments on both sides can also impose sanctions unilaterally, such as punitive tariffs. London has managed to keep this issue out of the European Court of Justice. The EU has enforced a sanctions mechanism. The same applies to minimum standards in labour and environmental law. If one side suspects a breach of fair competition, it can impose sanctions, which in turn can be challenged before an arbitration court.

Understandably most companies had other priorities in the last months, while struggling with fundamental challenges as a result of the pandemic, preparation for Brexit was not high on their agenda.

From my personal conversation I had the impression that not all companies well prepared for Brexit. Some of them even believed that there will be an extension of the transition period. We started mid this year to communicate to all our customers and highlight the importance of preparations needed and our advice was always: Prepare for the worst, hope for the best.

This is also interesting for you: The Gerlach Brexit Special

2. What are key information that the UK government has shared on their side on Customs regulations and processes?

The UK Government has announced that it will implement full border controls on imports coming into UK from the EU and has taken the decision to introduce the new border controls in three stages up until 1 July 2021.

For example, from 1 January, businesses importing “standard goods” – these range from things such as clothing to electronics – will need to fill out custom declarations and pay any necessary tariffs. However, traders have six months to fill out customs declarations and tariffs can be deferred until this time.

Also important to know is that a new IT platform will support a ‘pre-lodgement’ model, known as the Goods Vehicle Movement Service (GVMS), where goods arriving at the border will be required to have submitted a customs declaration in advance. GVMS will be introduced from January only for transit movements – meaning that e.g. EU hauliers may need to submit their Transit Movement Reference Numbers (MRNs) and vehicle/trailer registrations via the GVMS before checking in at their port of departure. From July 2021, the GVMS will be in place for all imports and exports at border locations which have chosen to introduce it.

3. What do you see personally coming in January 2021?

Bringing two observations together – not all companies are well prepared, and even today two weeks before the end of the transition period – no information available about the outcome of negotiations between UK and the EU, I can foresee chaotic situation, long waiting times and traffic jams at the borders.

It is key that companies take all necessary steps to prepare and I would like to emphasize one thing again: For all companies trading with UK today it needs to be clear that from January from customs perspective – either deal or no deal – UK is becoming a third country, and thus customs clearance formalities apply.