Update on Border Target Operating Model – goods moving from the island of Ireland to Great Britain

The government ​​published the final version of its Border Target Operating Model (TOM) earlier this year, confirming that from 31‌‌‌ ‌‌January 2024, certain goods will be subject to full customs controls when moved directly from Irish ports to Great Britain (GB).

Where goods are imported directly from Ireland into GB, ​​not moving from or through Northern Ireland (NI), import processes will need to be undertaken.  Goods moving from NI to GB through Irish ports, will also be subject to complete import processes, if they are:

  • Non-qualifying NI goods
  • excise goods, such as alcohol, tobacco and energy products  
  • goods which do not move directly to an Irish port once they have left NI, for example, goods held in storage in Ireland  

For these goods, importers must follow the requirements as set out in the TOM.

When these goods move, importers will need to make import customs declarations at the point of entry and delayed declarations will no longer be possible.  Ports will be required to control goods moving from Ireland to GB, so that unless customs clearance is given, they will not be released.  

Prepare to move goods from 31‌‌‌‌‌‌ ‌‌January 2024 – steps to take  

Businesses moving goods to GB from Ireland or NI, must ensure familiarity with the new process from 31‌‌‌ ‌‌January 2024, as follows:

  • Movement of qualifying NI goods should be confirmed to the haulier and/or carrier
  • A GB Economic Operator Registration and Identification (EORI) number must be obtained 
  • The Customs Declaration Service (CDS) must be used, so access should be obtained, either by the importer, or its customs broker
  • If using Entry into Declarants Records (EIDR) an authorisation to use simplified declarations for imports must be applied for  
  • If goods are being moved from Ireland through Roll-on Roll-off (Ro-Ro) ports in GB, the customs declaration must be made before the goods depart Ireland, and Goods Vehicle Movement Service (GVMS) processes must be followed 
  • Hauliers moving goods on behalf of importers must register for GVMS, in order to provide a Movement Reference Number (MRN) from the declaration, to the person moving the goods, in order to generate a Goods Movement Reference (GMR).  Hauliers must provide a GMR for all lorries and trailers moving directly from Ireland 
  • At an inventory-linked port, or other location, the haulier or intermediary moving the goods will need to follow standard processes, to ensure goods are presented to customs, declared and cleared, before release to GB free circulation
  • Where a full import declaration, or simplified frontier declaration, is made through CDS, for goods moving from Ireland to GB, including excise goods, there will no longer be a requirement to ​’arrive’ the declaration by the end of the next working day, after arrival in GB.  For goods entered to excise duty suspension, the entry to the Excise Movement and Control Systems (EMCS), must be made by the time they arrive in GB
  • If moving goods from NI to GB via Ireland​, including qualifying NI goods,​ there will be certain Irish customs requirements to exit the Irish port.  Irish customs guidance should be consulted 

Qualifying NI goods

Qualifying NI goods are those goods which are in free circulation in NI, that is, not under a customs procedure, or in an authorised temporary storage facility, before being moved to GB.  Goods processed in NI are still qualifying NI goods, where the components were in UK free circulation. 

The TOM confirmed that import declarations will not be needed for qualifying NI goods moving directly from NI, or indirectly through Ireland, to GB, meeting the government’s commitment to unfettered access.  There are limited exceptions where import declarations are required, for example, the requirement to provide these for excise goods​, which will be set out in guidance shortly.

When moving qualifying NI goods​​​ through Ireland to GB,​ for which import declarations are not required through Ro-Ro ports, hauliers will still need to complete a GMR and indicate that these goods are being moved on the GMR.  

Hauliers and drivers will need to provide commercial evidence, when asked to confirm that goods are qualifying NI ​​goods.  This might include, for example, dispatch notes, invoices, or consignment notes.  A travel document will also be required to be accessed, issued in the UK, setting out the destination of the goods, to show that the goods have merely passed through Ireland.

At inventory-linked ports, or other locations, similar processes will be used to allow qualifying NI goods to be released from inventories, or local systems, without an electronic declaration requirement.  

For further information, or to discuss your specific circumstances, please contact us via the below contact form:

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