Brexit Update – July 2020 As you are perhaps already aware, there was no transition extension request prior to the end of June. This means that in line with the Withdrawal Agreement the transition period will now end on 31 December 2020. During this transition period everything remains the same for businesses that import goods from or export goods to the UK. Negotiations on the future relationship that will operate after the end of the transition period between the UK and EU are ongoing, but regardless of the outcome customs formalities will apply from 1 January 2021.
Trade/Business Engagement Revenue has begun the process of re-engaging with trade and business. Revenue is aware that the Covid-19 pandemic has placed extra pressures on many businesses. However, it is important that businesses get ready now for Brexit and the fact that from 1 January 2021 customs formalities will apply to the movement of goods from, to and through the UK, excluding Northern Ireland.
Phase 1 of our engagement will see letters issued to over 60,000 businesses that traded with the UK since 2019 and have not yet registered for EORI. The letter will focus on the registration process and the other steps businesses need to take in order to be ready for the new trading environment on 1 January 2021. Businesses should receive these letters in mid-July.
Phase 2 of our engagement, planned for the beginning of September, will engage directly with businesses that traded with the UK in 2019 and 2020. It will aim to provide businesses with advice on steps they need to take to be ready for 1 January 2021.
Other aspects of the trade and businesses engagement programme for 2020 will include:
- keeping the Brexit portal (www.revenue.ie/brexit) content updated as new information becomes available
- a suite of videos on customs topics, including EORI registration, transit, simplified transit and other relevant topics will be added to the website
- Information seminars during the latter half of 2020, the format of which will depend on Covid-19 restrictions.
- Liaising with logistics and haulage companies, and other supply chain actors to inform them of the new requirements for moving through our ports and airports at the end of transition.
- Collaboration with other Government Department, Government Agencies and trade representative bodies to ensure all relevant businesses are aware of the new arrangements at the end of the transition period.
Revenue’s Continuing Message to Businesses Irrespective of the outcome of the trade negotiations, customs declarations will be a requirement when the transition period ends. During the transition period, businesses should seek to get fully Brexit ready. Many businesses have already taken the first step which is to register with Revenue for an Economic Operators Registration Identifications (EORI) number.
Key action areas suggested for business are reflected in the table below:
Action Supply Chain
What a business needs to do Know where their goods originate, their value for customs purposes, tariff classification and invoicing currency. Businesses that make use of any EU VAT simplification measures (such as triangulation or self-billing) should be aware that these measures will no longer be available where part of the transaction occurs in the UK. Businesses that incur VAT on purchases made in the UK should be aware that the European VAT Refund (EVR) system will no longer be available to reclaim VAT expended in the UK.
Action Customs compliance
What a business needs to do Decide on who will submit customs declarations for imports; do it inhouse or engage a customs agent. Ensure in-house customs software is up to date and able to connect to Revenue’s new Automated Import System (AIS), available from November. In addition to export declarations, need to know who will be responsible for import declarations on the UK side, i.e. Delivery Duty Paid (DDP)
Action Impact on Logistics
What a business needs to do Importer needs to know what new information the logistics provider will need and when.
What a business needs to do Some imports and exports require a certificate or licence, contact the relevant regulatory authority or regulator to put the necessary measures in place.
Action Payment of Import Duties
What a business needs to do Consider the cashflow implications of any import charges including customs duty, VAT and/or excise. Register for Revenue Online Services (ROS) - required to lodge funds into Customs and Excise/TAN Account to pay import charges
What a business needs to do Movements of excise goods into the EU (including Ireland) from the UK (excluding NI) will be third country imports from 1 January 2021. The EU Excise Movement Control System (EMCS) will no longer be available to economic operators based in the UK, excluding Northern Ireland, for movements into the EU (including Ireland). Customs formalities will have to be completed for excisable goods – otherwise businesses will be unable to import such goods from the UK (excluding NI). For movements of excisable products from Northern Ireland to Ireland, existing procedures under EU law will remain in place.
What a business needs to do Avail of the Brexit advice/financial supports available from other State Bodies and Agencies.
Action Customs Authorisations and Simplifications
What a business needs to do These may make interaction with Revenue easier in the future EU-UK trading environment. An application for any of these authorisations or simplifications is made electronically on the Customs Decision System (CDS). In each case, an application must be made simultaneously for a financial/comprehensive guarantee.