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Brexit Preparation

BREXIT Preparation advice

Businesses are being advised to prepare for Brexit, and whilst the government are still working towards a Deal, it is pertinent that businesses should be planning for a No Deal scenario.  BATF and the affiliated divisions are working on ways to help you to understand what this entails by simplifying and signposting you to relevant guidance.

Please note this is not an exhaustive list of what may apply to your specific product/business but is meant to act as guidance.  Further industry specific guidance can be found in the Brexit Preparation Advice Pack tab.  Prepare your business for Brexit 

This document sets out in one place what will change if the UK leaves the EU without a deal and outlines what the Government is doing to get ready for Brexit. No-Deal Readiness Report


Register for an EORI number.

To interact with UK Customs systems to import or export goods businesses will need an Economic Operator Registration Identification (EORI) number.  

HMRC has stepped up efforts to ensure businesses are ready to trade post-Brexit by automatically enrolling companies in the Economic Operator Registration and Identification system. More than 88,000 VAT-registered companies across the UK have now automatically been allocated EORI numbers.  If you are automatically enrolled you will receive a letter informing you of this.

•             If a business is not VAT-registered, it will still need to register for an EORI number.   Information on how to register can be found here 

 •             Getting an EORI number is one of the steps that businesses need to action urgently to be    prepared for leaving the EU

 •             After getting an EORI number, businesses will need to decide whether to complete customs declarations themselves, or employ a customs agent to do this. As part of the £2.1bn announced on 31 July, they are doubling the support made available for customs agents to train new staff or invest in better IT so businesses can get the support they need to complete customs declarations. If employing a customs agent, businesses will need to supply their EORI number.

 •             Traders also need to decide whether to apply for Transitional Simplified Procedures to make it easier to import goods from the EU. Find out how to register here

 •             If businesses have been issued a UK EORI number by HMRC and then apply online, they will receive a message to say that they already have one

 •             HMRC advises businesses to contact HMRC if they are unsure. HMRC will be able to confirm whether a number has been assigned

EORI mythbuster 

 Exporting and export tariffs

Get your business ready to export

In the event of a no deal Brexit, exports to the EU will attract tariffs.  For the complete list of WTO tariff rates in the event of a no deal scenario, BJGI members should contact: rebecca.gough@batf.uk.com  or visit the WTO website

Importing and import tariffs

Get your business ready to import

If the UK leaves the EU without a deal, you may need to pay different rates of customs duty (tariffs) on imports into the UK from the EU and the rest of the world. These rates will only be applied if the UK leaves with no deal.

The temporary rates would be in place for up to 12 months. The government will then introduce a permanent tariff regime following a public consultation.

Depending on where the goods come from, the tariff rate will either be a preferential rate or a non-preferential rate, which is also called a ‘Most Favoured Nation’ (MFN) rate.

Read more here 

Import goods using transitional simplified procedures in a no deal Brexit

Make it easier to import goods from the EU in a no deal Brexit, by delaying your declaration and paying import duties and VAT. Learn more about Transitional simplified procedures (TSP)

Free Trade Agreements

The UK, as an EU member, participates in around 40 trade agreements.  Trade agreements that the UK is part of as an EU member state will no longer apply if there’s a no-deal Brexit.  The UK government is working on new agreements to replace EU trade agreements after Brexit. Read the latest guidance here: UK trade agreements with non-EU countries in a no-deal Brexit.

HM Government Guidance

There are a series of guides for businesses that trade with the EU in the event of a no deal Brexit. These cover:

·         Specific consumer goods guidance. 

In a no deal scenario the UK would fall outside of the EU regulatory frameworks. You will need to take action to continue selling many manufactured goods in the EU, and may need to act to continue selling in the UK too.

o    Placing manufactured goods on the UK market after Brexit

·       Placing manufactured goods on the EU market after Brexit

·         Updates have been made to the customs processes you’ll need to follow if you move goods between Ireland and Northern Ireland; information about moving controlled and licensed goods, transitional simplified procedures and moving goods under transit have been added. Customs procedures for moving goods between Ireland and Northern Ireland in a no-deal Brexit 

 

·         Understand how to continue to access preferences where the UK has agreed trade continuity arrangements with partner countries, or through the UK’s Generalised Scheme of Preferences (GSP).  Proof of origin: trade continuity agreements and GSP 

 

IP and the EU Settlement Scheme:

·         Apply to the EU Settlement Scheme (settled and pre-settled status)

VAT

If the UK leaves the EU without a deal, the government’s aim will be to keep VAT procedures as close as possible to what they are now. This will provide continuity and certainty for businesses. However, if the UK leaves the EU with no agreement, then there will be some specific changes to the VAT rules and procedures that apply to transactions between the UK and EU member states. The government has taken decisions and actions where necessary in order to mitigate the impacts of these changes for businesses.

This note summarises the main VAT issues that will affect UK businesses trading with the EU in goods and services if the UK leaves the EU without an agreement. Although no changes will be made before then, this note highlights the VAT changes that businesses will need to prepare for when importing goods from the EU, exporting goods to the EU, supplying services to the EU, and interacting with EU VAT IT systems such as the VAT Mini One Stop Shop (MOSS).  

You can also read the full UK withdrawal guide that is available on the European Commission website here.  

Trading CITES-listed specimens through UK ports and airports if there’s a no-deal Brexit:  

Designated land, sea and airports for trading or moving CITES-listed endangered animals, plants, or their parts and derivatives after Brexit. Change made:- added a requirement to use the CHIEF system to import specimens through the Eurotunnel. 

For the latest guidance on trading and moving endangered species protected by CITES if there is no withdrawal deal please see the following link

Merchandise in Baggage

There has been an update to the notice with regards to merchandise in Baggage, this relates in terms of transporting samples to and from the EU: Bringing merchandise from or to the UK in baggage or a small motor vehicle in a no-deal Brexit  

Please note other useful links:

Getting help from third parties
https://www.gov.uk/guidance/appoint-someone-to-deal-with-customs-on-your-behalf

Deciding which customs procedures to use
https://www.gov.uk/guidance/customs-procedures-if-the-uk-leaves-the-eu-without-a-deal?step-by-step-nav=db1149f5-f60a-4d02-be0c-9c9db2828665

Common Transit Convention (CTC)
https://www.gov.uk/guidance/what-you-need-to-move-goods-between-or-through-common-transit-countries-including-the-eu

National Export System (NES)
https://www.gov.uk/guidance/export-declarations-and-the-national-export-system-export-procedures

Grants for businesses that complete customs declarations
https://www.gov.uk/guidance/grants-for-businesses-that-complete-customs-declarations

Help and support for traders when the UK leaves the EU
https://www.gov.uk/guidance/help-and-support-for-traders-if-the-uk-leaves-the-eu-with-no-deal

HMRC Customer Forum
https://online.hmrc.gov.uk/webchatprod/community/forums/list.page

Information videos for traders in a no-deal Brexit
Videos about trading with the EU in a no-deal Brexit; webinar about transitional simplified procedures has been added.

 

HMRC impact assessment for the movement of goods if the UK leaves the EU without a deal

HMRC’s third edition of HMRC’s impact assessment for the movement of goods if the UK leaves the EU without a deal.

 

Statutory Instruments relating to Brexit

SI 2019/1307 – The Cross-border Trade (Public Notices) (EU Exit) Regulations 2019 has been added.

 

Sources:

www.gov.uk

www.hmrc.gov.uk

www.gov.uk/brexit 

Important Advice from the Edinburgh Assay Office for Importers and Exporters in the Event of a No-Deal Brexit

Life After Brexit
In the last few months we’ve dealt with a huge increase in enquiries on the possible impacts of Brexit from both importers and exporters.  While it will only be possible to give definitive advice when our post- Brexit regulatory and trading relationship with the EU has finally crystallised, we realise that businesses need to be able to plan.  For this reason, we hope that the following explanation of the likely impacts for the known possible scenarios, as we see them, will help. At the time of providing this advice, the final relationship between the UK and the EU is not yet known.  For this reason, this advice aims to set out best practice around the possible scenarios that may or may not transpire.  This advice pertains to hallmarks only.  Separate advice should be sought on customs arrangements.


 The Current Situation
There are currently 2 separate ways in which hallmarks applied in one country can be recognised as being equivalent in another country: European Court of Justice (ECJ) ruling The ECJ has ruled that EU member states must recognise each other’s marks subject to providing an equivalent level of protection and being intelligible to consumers.  The effect of this ECJ ruling is that most EU countries, with a requirement for compulsory hallmarking, will accept UK hallmarks as being equivalent to their own.  The UK also accepts many EU member state hallmarks. The Common Control Mark (CCM) applied by signatories to the Vienna Convention on the Control of Precious Metal Articles Often referred to as simply a convention mark, the CCM can only be applied by a signatory country, within their own national boundary.  In other words, the Convention is an agreement between Governments who have ratified the terms of the treaty.  The Convention has prescribed technical rules on testing and marking.  Whenever a signatory country applies the CCM it means they have followed these common technical rules.  It also means that all other signatory countries will accept the articles directly onto their market.
 

What might change after Brexit?  
No Deal Exit In a scenario where the UK left the EU without any deal then all the UK’s obligations to recognise EU marks would cease and similarly all obligations by our EU neighbours to recognise UK hallmarks would also cease.  In this case we anticipate that any product already on the market before the date of Brexit would be legal as it entered the market pre-Brexit and would already be in free circulation. Any new stock entering the UK market would require a hallmark recognised in the UK and in the case of stock exported to other EU countries, it would require a mark recognised by those countries. The CCM or Convention mark will continue to be recognised in the UK and it will continue to be recognised in those countries who are also members of the Convention.  

Managed Deal Exit
In a scenario where the UK negotiated a managed exit from the EU with an EU customs union, it may be the case that that relationship will continue to be subject to the ECJ ruling which currently provides the basis for recognition of domestic marks.  In a managed exit there are also likely to be cut offs agreed over a set period, if there are going to be changes to the current situation.  Until the exact nature of any future deal is known the exact effect cannot be determined.  

Delayed Exit
In the case of an extension to the UK’s membership the current recognition to UK marks by our EU neighbours and the recognition of the EU marks currently recognised in the UK would continue.

What action can importers and exporters consider taking now?
The CCM mark applied by a UK Assay Office is currently accepted in all EU member states because it is a UK hallmark.  You can start applying a CCM mark to your goods now with no impact on your current import or export requirements. 

Post-Brexit, it will continue to be accepted by those EU member States who are also signatories to the Convention.

Which countries are covered by the CCM?
The Current list of signatory Member States of the Convention is as follows: Austria, Croatia, Cyprus, Czech Republic, Denmark, Finland, Hungary, Ireland, Israel, Latvia, Lithuania, Netherlands, Norway, Poland, Portugal, Slovak Republic, Slovenia, Sweden, Switzerland, and the UK.   The following countries have undergone assessment, have been invited to join but are in the process of ratifying the treaty: Serbia, and Italy.  

The CCM mark can be applied to new articles along with UK Assay Office marks or as an addition to articles already bearing UK hallmarks. If you are importing from any of the above countries, we recommend that post Brexit you request a convention mark on your goods, or you submit them to a UK Assay Office for hallmarking before placing them on the market.   If you are exporting to any of the above countries, we recommend that you apply a convention mark to your goods, post Brexit.   It is also important to remember that the UK exemption weights of 7.78grams for silver, 1gram for gold/palladium and 0.5grams for platinum, may not apply in other countries. For example, in the Republic of Ireland there are no exemption weights. This means that any stock destined for southern Ireland must bear a CCM. Exemption weights for the other signatory states are available on from your Assay Office request.
 
What about the EU countries that are not members of the Convention?
Belgium, Luxemburg and Germany do not require any hallmark as a pre-market authorisation. In France a hallmark is a legal requirement. Importers must register with the Bureau de central. In Spain a hallmark is a legal requirement. Importers must register with an assay office in Spain.
 

If you have any further enquiries please contact us.

      Source: Edinburgh Assay Office on 8th October 2019.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Important Note:

The information contained in this document is provided in utmost good faith and has been based on the best information currently available at the time of writing, but is to be relied upon at the user's own risk. No representations or warranties are made with regard to the completeness or accuracy and no liability will be accepted by the British Allied Trades Federation for damages of any nature whatsoever resulting from the use of or reliance on the information.

The sources of the specific information can be found within the document.

The views expressed in this document are solely those of the author and do not necessarily represent those of the British Allied Trades Federation.