Brexit’s Impact on Imports
HMRC has now published its first draft of the Border Operating Model (BOM), setting out the UK’s approach to the EU border from 1 January 2021. Controls on the movement of goods will be phased in over three stages until 1 July 2021, in order to recognise the disruption to business caused by the Covid-19 pandemic and giving businesses the time to prepare. The three phases will be introduced on 1 January 2021, 1 April 2021 and 1 July 2021, slowly bringing in checks on certain categories of goods and deferring completion of customs declarations and payment of tariffs through to full customs declaration submission and payment from 1 July 2021.
Customs declarations
Importers and exporters will be required to complete customs declarations, with some locations requiring pre-lodgement of the declaration prior to movement of goods.
Customs duties
Payment will be due as applicable under the new Global Tariff, with deferment a possibility.
VAT
Import VAT will be due, although postponed import VAT accounting should be available.
Safety and Security declarations
The UK Government will collect more information on goods moving into the UK from the EU.
There are other HMRC schemes that may be applicable which defer or suspend the need to pay duty and import VAT on goods. Specifically, Import Processing, Inward Processing and Temporary Admission reliefs are valuable as they can help to manage cashflow pressures.
Consider also the benefits of the proposed introduction of Freeports. The latest Government paper on Freeports, was published on 7 October and intends to ‘turbo-charge post-Brexit trade’ by ‘creating jobs, driving investment and regenerating communities’. There will be a bidding process for sea, air and rail ports before the year end and the first Freeports are on track to open by end of 2021.
Proposed Freeport policy will create a flexible new customs model, improving on existing customs arrangements, where imports of goods into a Freeport will be tariff free, before processing, followed by local sale, or tariff free export. The proposed package of tax reliefs intends to help drive jobs, growth and innovation.
Actions
- Ensure you have a UK EORI number
- Review exposure to import tariffs and import VAT
- Consider how customs import declarations will be submitted
- Understand what commodity codes will be required for customs declarations
- Consider whether to apply for a duty deferment account and Customs Freight simplified procedures
- Consider whether you can apply for Inward Processing relief, Outward Processing relief or Temporary Admission relief
- Consider alternative sourcing strategies – e.g. partnering with other
- manufacturers, if using the same products or based in the same location to minimise the cost impact of stock holding
- Consider having an overseas investment base to minimise the number of times goods cross borders
- Consider the impact of potential delays as a result of border checks
- Consider the use of bonded warehousing to delay VAT payments
- With import customs declarations, consider if you will do these yourself, or whether it is more efficient to hire a Customs Agent
- Review contracts and incoterms (International Commercial Terms)
- Consider the Freeports proposal
- If you import live animals, plant or food products, review whether inspection fees may be payable.