BREXIT UPDATES as of 28/03/2019

HM Government have issued the following guidance relative to a D1ND Brexit, which we are distributing for information

DEFRA

The date the UK leaves the EU in a No-Deal scenario has changed to 12 April. All previous guidance for EU and third country imports, including when to use TRACES and IPAFFS, remains applicable for the new No-Deal EU exit date. Please check GOV.UK at https://www.gov.uk/guidance/importing-animals-animal-products-and-high-risk-food-and-feed-not-of-animal-origin-after-eu-exit for the latest updates.

The Department thanks those businesses which have already registered for the Import of Products, Animals, Food and Feed System (IPAFFS) to import from third countries on EU exit Day 1. If affected traders haven’t registered already, we would suggest that you do so now to ensure you are able to notify of third country consignments coming into the UK from 11pm on 12 April. There is guidance on registration and raising notifications available https://www.gov.uk/guidance/import-of-products-animals-food-and-feed-system-ipaffs-guidance.

Please note our team will be conducting planned improvements to IPAFFS from 12pm Thursday 28 March to 8am Monday 1 April. You will experience a limited service while these further improvements are made, so we recommend not accessing the system during this time.

This email is part of a regular communication to prepare you for a Day 1 No-Deal scenario as a UK importer of animals, animal products and high-risk food and feed. We will continue to keep you informed but if you do have any non-technical questions you can email the team at BFPEUExit.ImportsExports@defra.gov.uk. 

Export Control Organisation

Further to the earlier bulletin released earlier this week, please note, as stated in the relevant Open General Licence (export of dual use items to EU member states), it will come into force at 11pm on 12 April 2019 if the UK leaves the EU without a deal.  The full text of the information can be viewed at https://www.gov.uk/government/publications/open-general-export-licence-export-of-dual-use-items-to-eu-member-states

For general export control queries please contact our Helpline on 020 7215 4594 or exportcontrol.help@trade.gov.uk

VAT/HMRC

HMRC have issued further information relative to the VAT changes that will apply to parcels valued at under £135.00, further information can be found at  https://www.gov.uk/government/publications/communications-pack-import-vat-on-parcels-in-the-event-of-a-no-deal-eu-exit.

If the UK leaves the EU without a deal on 12 April 2019, the UK import VAT rules will change for goods sold to UK buyers that are sent in parcels worth £135 or less.   When the value for all goods in the parcel is £135 or less, sellers outside the UK must pay the UK import VAT for any parcels sent to UK buyers after 11pm GMT on 12 April. Sellers outside the UK include those in the EU, outside the EU, and the Channel Islands. This will include any goods worth £15 or less as they will no longer be eligible for the existing tax relief.

HMRC’s new, online parcel registration service is open and overseas businesses can register now and get their parcels reference so they are ready in case of no deal.

More information can be found at  GOV.UK.

Department for Transport

Good news, DfT have confirmed that the European Council has agreed the contingency proposal which will allow UK hauliers transport goods between the UK and the EU (and Norway) using UK operator licences for the rest of 2019 (without the need for ECMT permits).

There will be some new limitations on cross-border EU trade (Member State to Member State) and cabotage (for the first few months of a “no deal” the limit is 2 trips within 7 days after an unloaded international journey, for the following 3 month only 1 trip will be allowed within 7 days).

This will be from the Brexit date, which is currently set for 11pm on the 12th April.  ECMT permits will be required for deliveries/collections to 3rd countries but will not be required for a truck transiting through a 3rd country. e.g.  transiting Switzerland for Italy.   In cases where extra cross-border operations over and above what the new EU rules allow, ECMT permits may be used. Operators do need to be aware that ECMT is itself restricted and complex, so caution will be required.

The above is in reference to hauliers access to European markets , it does not negate the requirement for Customs procedures for the goods both in the UK and EU.