*UPDATED – 31/07/19

Brexit has become an ongoing saga that remains confusing at the best of times and infuriating at the worst. Developments come and go, and news and information can become irrelevant before it even becomes known. We are keeping our finger on the pulse to make sure we remain at the forefront of developments and have positioned ourselves to be able to tackle a “bad-deal” or “no-deal” Brexit. On this page we hope to shed some light on how this would impact our customers.

*due to the nature of how information regarding the UK’s exit from the EU is being released, and  its tendency to change at the drop of a hat, we cannot be help liable for any inaccuracies regarding the below.

WHAT WE KNOW SO FAR

As an importer or exporter of goods to and/or from other EU member countries, the one key benefit that has a direct impact on your supply chain management will be our current free access to the EU single Market. It effectively allows you to trade and transport goods within the EU with no tariffs or duties to pay. Should we leave the single market, then more bureaucracy and the implementation of tariffs may be put in place, slowing down the speed at which you can move your goods and increasing the costs to do so.

Unfortunately, this is no longer so clear cut. A further extension has been agreed with the EU, with a new date of leaving by (imperative word being “by”) 31/10/2019. It’s not as short as Theresa May had wished for, nor as long as the majority of the EU members had wished for. This date does not mean that we will leave on 31/10/2019 however. If a deal can be agreed within the UK that is then accepted by the EU, we may leave sooner. So it is very much a case of “watching this space”, so keep an eye on our linkedin account or make regular returns to our website.

*UPDATE 31/07/19

Boris Johnson now being Prime Minister, he has indicated a much stronger position on leaving the EU with no deal in place. He has guaranteed that we will leave on 31/10/19 regardless, but has stated that he believes a new deal is very achievable in this time scale and that a no-deal is “1,000,000 to 1 against”

Providing that a delay has already been implemented twice, you could argue both ways. A further delay would be highly undesirable for all parties involved as it only prolongs uncertainty, however, with a precedent for delay and extensions already set, its not impossible.

As it stands and as we always advise it is best to work with the information that is available and not to rely on speculation alone (which is becoming increasingly difficult not to with the current state of Brexit), so anywhere between now and the 31/10/2019 we could leave the EU with a deal in place.

*UPDATE 31/07/19

With Boris Johnson’s firm stance that no further delays will be implemented, it seems highly unlikely that the date to leave 31/10/19 will change again

The current position is a confused one at best. There is currently no majority behind a way of moving forward with Brexit within the UK, hence the need for the now implemented extension. The following days, weeks and months will likely be filled with news of debates and compromise to find an agreeable solution. What shape that will ultimately take is anyone’s guess, with some signs pointing towards a possible softer version of May’s current offering as comprises are made, but anything from an impasse forcing a no-deal or a 2nd referendum, to a possible different Prime Minister with May being ousted or a different government through a snap general election. Nothing is currently a certainty so we will update our channels when the relevant information becomes available.

*UPDATE 31/07/19

We now have a new PM, Boris Johnson, who wishes to agree a new deal with the EU, but will happily have the UK leave without a deal if no common agreement is made by 31/10/19

The majority of the current UK parliament is taking every step it can to stop a no deal, so it seems unlikely and is getting less likely with each day that passes. It does not make it impossible however, as anything between now and the new date of 31/10/2019 could drastically shift the tides in one direction or the other and until a deal is agreed we will always advise to prepare a contingency plan for the possible no-deal outcome, now standing at the possible date of 31/10/2019.

*UPDATE 31/07/19

Now with Boris Johnson as the new PM, the likelihood of a no-deal outcome has greatly increased. Despite Johnson’s insistence that a deal being agreed is the more probable outcome, it’s his unwavering stance on leaving with no deal and the short time left to have a new one agreed that makes a no-deal visible on the horizon.

It is important to have a clear understanding of what the first day of a “no-deal” Brexit would look like. HMRC has published multiple documents outlining such things. You can find these items here  – Partnership Pack

It can be quite hard to digest and filter all the documents into what is relevant for yourself. Thankfully the Government have also released a tool to help locate any such documents more easily. You may still return with what feels like an overwhelming amount of information, but we highly recommend finding time to go through as much as you can. The tool can be found here – Prepare your business for leaving the EU

We have consolidated the information to make it as digestible as possible, and have listed below the key points you will want to consider if EU members play a key part in your supply chain management. It is not a “one glove fits all” situation however, which is why we recommend you still use the tools provided by the government to be as best prepared as you can or alternatively, if you have any specific scenarios or concerns that are not covered here, to contact us.

NO DEAL BREXIT CHECKLIST

Before importing goods from a member of the EU you will need to have a UK Economic Operator Registration and Identification (EORI) number. You will need an EORI number to continue to import goods after 31st October 2019. If you are currently importing goods from outside the EU you should already be EORI registered. It’s a very simple process and is the first step you should take to minimise disruption should we leave the EU with no deal in place. Follow the link to the GOV website to get registered – EORI Registration

You will be subject to customs clearance in the same way that businesses currently do when importing goods from outside the EU. This means that you will need to make an import declaration for goods entering the UK from the EU.

You should consider how you will submit import declarations and it is up to you whether you chose to make declarations yourself or have Banks & Lloyd complete these on your behalf. Keep in mind that Banks & Lloyd process customs clearance all in house, simplifying the entire process, and should you wish to discuss this further then do not hesitate to contact us. If you do choose to do it yourself, you will need the right software and the necessary authorisations from the HMRC.

Under current rules for goods moving between EU countries there are no customs duties and no routine intervention during the movement of goods.

For goods entering the EU’s Customs Territory from the rest of the world an import declaration is required and any customs duties must be paid.

However, in the event of a “no deal Brexit”, goods imported into the UK from the EU will be subject to the same requirements that apply to any other non-EU member, including payment of duty.

Ahead of the current exit date of March 2019, the UK Trade Tariff, detailing the import duty rates and rules that will be applicable to each type of goods, will be made available free on GOV.UK.

UPDATE – 13/03/19

The HMRC as released documents outlining how Tariffs and Duties will look in the event of a no deal BREXIT. Given the vast amount of commodities in question, we cannot list every single one, and will only give examples. If you have a specific commodity, you can check the GOV.CO.UK website or simply get in touch with ourselves directly. 

*due to the nature of how information regarding the UK’s exit from the EU is being released, and  its tendency to change at the drop of a hat, we cannot be help liable for any inaccuracies regarding the below.
  • The new tariffs will apply as of the 11pm GMT 29/03/2019, regardless of whether your goods have already started their journey to the UK. If they are not in the UK before this date, then the new rules will apply on arrival.
  • Duties, if applicable, must be declared and paid on arrival. *unless following TSP (Transitional Simplified Procedures). The TSP process only relates to Road Freight at the specific Road Freight ports (Dover, etc)
  • Many of the new Duty rates will be 0% but there remain many commodities which will be or remain subject to Duty. Please check with our office in relation to the commodities which apply to your business: Some examples are as follows:
    • Certain Ceramic Tiles – 5%
    • Other Ceramic Tiles – 0%
    • Slate – 0%
    • Stone – 0%
  • It is currently our understanding that, with exception of GSP, GSP+ or LDC nations, duty rates will be applied on a global basis. For instance, the duty rate for a commodity may be 5% and that would then apply to imports from Brazil as well as from Spain.
  • Some 87% of the commodities will be re-set to 0% with only 13% of commodities remaining subject to Duty.
  • We believe arrangements regarding Anti-Dumping Duty will remain in some cases, not in others.

UPDATE – 29/03/19 

Rolled-over free trade deals from the EU are incomplete and not ready for a no deal. This comes to light as the HMRC has also released some information to help clarify the UK’s position on current EU trade agreements and how they would be affected in the event of a no deal departure. There are free trade or reduced duty rate agreements with a number of countries under Freed Trade, Economic Partnership and Association Agreements. Although negotiations are ongoing, for some countries alternative free trade or customs arrangements will not be signed and finalised in time by the UK before our no deal departure date. In this scenario current EU trade arrangements which the UK has access to would cease with immediate effect and duty/tariff rates would revert to WTO terms as indicated in the Temporary Customs Tariff provided by the HMRC. When looking at the list, you want to locate the rate in the “most-favoured-nation (MFN)” column, however the list is extensive and can be quite hard to digest, so please do not hesitate to direct any questions to ourselves using the form at the bottom of this page.

The countries affected are:

  • Algeria
  • Andean (Colombia, Peru and Ecuador)
  • Cameroon
  • Canada
  • Central America (Panama, Guatemala, Costa Rica, El Salvador, Honduras, Nicaragua)
  • Ivory Coast
  • Egypt
  • Georgia
  • Ghana
  • Japan
  • Jordan
  • Kenya
  • Kosovo
  • Lebanon
  • Mexico
  • Moldova
  • Morocco
  • Southern Africa Customs Union and Mozambique (Botswana, Eswatini, Lesotho, Mozambique, Namibia, South Africa)
  • South Korea
  • Tunisia
  • Ukraine
  • Western Balkans ( Albania, Bosnia and Herzegovina, Montenegro, North Macedonia, Serbia)

There are also  a number of countries in a Customs Union or Economic Area Agreement with the EU which will also not be renegotiated by the UK in time. Again, trade with these countries will take place on  WTO terms. These are:

  • Andorra and San Marino
  • EEA (Norway, Iceland and Liechtenstein)
  • Turkey

HMRC has also announced however that the UK will continue to participate in the GSP scheme. Therefore all imports/exports under GSP regulations will continue as they do currently, on production of the valid GSP certificate.

Please follow this link for ever updating information on TSP – Link Here

The government has announced that in a “no deal Brexit” scenario it will introduce postponed accounting for import VAT on goods brought into the UK. This means that UK VAT registered businesses will be able to account for import VAT on their VAT return, rather than paying import VAT on or soon after the time the goods arrive in the UK. This will apply for both imports from the EU and non-EU countries.

It is unknown what the level of disruption at major UK ports will be, but we expect immediate short-term disruption whilst the UK adjusts to life outside of the EU, in the event of a “no-deal Brexit”.

It is recommended that our customers ensure they have the appropriate steps in place to cope with potential severe delays to their goods entering the UK, and have the correct stock levels to deal with any delays.

With Banks & Lloyd being a member of BIFA (British International Freight Association) we have access to an insight on how the Transport and Logistics Industry, the key factors that keep your supply chain moving, is forecast to look from the Brexit negotiations and how this will impact us all, and what we can do to prepare and plan around it.

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Questions and Queries on Brexit… 

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