EU Border update. The Government is putting COVID recovery first, by introducing a delayed timescale for implementing border controls.

Last week the government announced a six-month delay to the introduction of full import border controls. This is due to the unprecedented challenges businesses have faced during the pandemic.

It means that full declarations will not be needed at the time you import non-controlled goods until 1‌‌ ‌January 2022.

If you are already making full declarations, you don’t need to change anything, but for those who are still getting to grips with the changes there is now longer to prepare.

Here’s what the latest announcement means for you, particularly if you are about to start importing, or started after 1 January 2021.

Delayed customs import declarations for EU goods brought into Great Britain:

• customs import declarations are still required, but the option to delay your declarations, including submitting supplementary declarations up to six months after the goods have been imported, has been extended to 1‌‌ ‌January 2022
• until the end of this year, many traders importing most goods from the EU will be able to delay submitting information and paying customs duties to HMRC for up to six months from the date their goods are imported into the UK.

Safety and security declarations:

• summary declarations, also known as the safety and security declarations will not be required on goods that you import from the EU until 1‌‌ ‌January 2022.

And if the goods you’re importing include products of plant or animal origin: 

• pre-notification requirements for Products of Animal Origin (POAO), certain animal by-products (ABP), and High-Risk Food Not of Animal Origin (HRFNAO) will not be required until 1‌‌ ‌October 2021. Export Health Certificate requirements for POAO and certain ABP will come into force on the same date
• physical SPS checks for Products of Animal Origin (POAO) certain animal by-products (ABP) and High-Risk Food Not of Animal Origin (HRFNAO) will not be required until 1‌‌ ‌January 2022. At that point they will take place at Border Control Posts
• pre-notification requirements and documentary checks, including phytosanitary certificates will be required for low-risk plants and plant products, and will be introduced from 1‌‌ ‌January 2022.

What this means for your business

If your business is not established in the UK, you must get someone established in the UK to deal with customs for you (and they must act indirectly).

If you import goods that were in EU free circulation into Great Britain (England, Scotland and Wales) between 1 January and 31 December 2021 and the goods are not controlled, you can:

• declare these goods by entering them in your own records without getting authorisation in advance
• delay sending HMRC the full information about your goods by up to 175 days on a supplementary declaration

You must also:

• account for the import VAT on your VAT Return (if you’re not VAT registered you must pay at the time you make the supplementary declaration)
• have authorisation to use simplified declarations before you can make a supplementary declaration (or use someone dealing with customs for you who has an authorisation)
• submit monthly Intrastat supplementary declarations for arrivals from the EU if you’re required to

If you decide to get someone else to deal with your customs declaration requirements for you and make all the necessary declarations on your behalf to move your goods, they’ll enter the goods in their records and make the supplementary declaration.

If you (or someone dealing with customs for you) are already authorised to use simplified declarations at the time the entry was made in the records you can still delay your supplementary declaration.

Free circulation

You must be moving goods from the EU into free circulation (declared and customs duties paid). This can be one of the following:

• directly from import
• from a customs special procedure (for example customs warehousing)
• from a temporary storage facility
• using transit – if the movement of the goods started in the EU

Transitional simplified procedures

The transitional simplified procedures which were announced for 31 January 2020 have been withdrawn. You will not be able to use them to import your goods from the EU.

You can’t use delayed declarations if:

• you trade in controlled goods such as tobacco or alcohol
• HMRC has told you to, because you have a poor compliance record or your business is considered high risk

In these circumstances you must submit full customs declarations for any trade with the EU.

Goods already imported using delayed declarations

The announcement does not extend the period between your entry in declarant’s records and making your supplementary declarations, so you will still need to submit your delayed supplementary declarations within 175 days of the goods arriving in GB. For example, if you have already imported goods in January using the delayed declaration option, you will still need to be ready to make your supplementary declarations in July.

Action that you need to take now:

• if you intend to delay your declarations, you must make a simplified declaration in your records to do this. This is called an entry in declarant’s records
• before your goods are imported, it’s important that you ensure the person responsible for moving your goods is told whether the goods will be declared using delayed declarations or using existing customs processes.

Customs declarations can be complicated, so many businesses decide to use a customs intermediary to deal with import and export declarations on their behalf. TPS Global Logistics are on the list of customs intermediaries that can help you.

Please contact us if you require assistance with you importing or exporting business. +44(0)1622 237 979 or email sales@tps-global.com