Brexit checklist for producers & freight forwarders
The process for importing and exporting goods might change as a result of Brexit.
Even though there are still many unknowns and the final Brexit deal is not confirmed, the following is a list of areas where the process for importing and exporting goods might change as a result of Brexit. If you use a freight forwarder to move goods they will navigate these changes for you but it is worth considering yourself if/how these issues might affect your business.
Importing and exporting products can be a complicated process both in relation to the documentation and tariff codes and also in deciding on the best routes and carriers. One of the best ways to make sure you have the most appropriate logistics solution is to use a freight forwarder to move your goods. Freight forwarders should be well aware of the impact that Brexit will have and will navigate these changes for you, but it is worth considering yourself if/how these issues might affect your business.
JCIS have produced a document for Traders in relation to Brexit. It is intended to inform businesses and citizens and provide an understanding of various scenarios to make informed plans and preparations. The link to the full document can be found here.
It would be useful to identify what documentary requirements might apply for your products when exported to, or imported from EU countries as you might need to supply more information about these products after Brexit.
It is likely that UK tariff codes will apply to all the products you are moving out of Jersey and not just those that go outside the UK and EU. Tariff codes can be found by searching trade tariffs on GOV.UK website. Your tariff code allows you to fill in declarations and other paperwork and check if there’s duty to pay.
Under current arrangements, Jersey applies the EU’s Common Customs Tariff (“CCT”) to all goods imported from a place outside the European Union. Once any import duties have been paid on third country goods, and any other formalities complied with, those goods can move between member states (they are in “free circulation”) without further payments of import duty.
In the event of ‘no deal’, goods traded between Jersey and the EU will be subject to the same requirements as third country goods, including the payment of customs import duty. For further information please refer to the JCIS Trader notes.
Identifying the “origin” of products will be necessary for customs purposes of all products when exported to, or imported from EU countries. Identify the UK/EU/non-EU content (including all components and raw materials) and whether your goods may qualify as being of UK or EU origin.
Access further information on rules of origin from the Gov.uk website
If you work in a time-sensitive sector, consider how your customers maybe impacted by customs delays. Think also about where and how you will store inbound freight while it is waiting for clearance.
What level of risk of physical or documentary examination might apply for your goods imported from, or exported to EU countries?
Consider your operating model to take account of the cost of the increased time and information you are likely to need to process freight movements.
Consider cash-flow risks if VAT on EU imports becomes payable at the time of importation instead of via Intrastat. You might also consider protecting against foreign exchange fluctuations within your business.
Identify sales to EU clients who incorporate those goods into their products, for re-export to countries with Free Trade Agreements (FTAs). Check whether supplier declarations are provided.
Are your goods subject to export or import licensing controls? If so you need to understand how these might these change.
If the UK leaves the EU without agreeing a customs arrangement, the UK and Jersey will be classified as a third country in its relationship with the EU. As a result Jersey’s importers will need to follow the same procedures that they currently do when importing goods from a country outside the EU. In addition, Jersey will apply the UK’s tariff rates to goods imported into Jersey from the EU and it could be the these will be different from those applied by the EU.
However, regardless of Brexit, some changes are being made to the customs process to make sure that Jersey can continue to comply with both the UK and EU import requirement. This will mean that:
- A full import declaration will be required
- All goods will have to be included regardless of value, a change from the current requirements where only good above £135 need a declaration
- Documents & correspondence continue to be excluded from declaration requirements
- Customs import duties will have to be paid on all items
- No goods will be released from customs controls until an import declaration has been submitted, however it will be possible to submit the declaration before the goods arrive in Jersey
- For certain goods, safety and security declarations will be required for goods entering from the EU
For more information see Trader notes in preparation for Brexit