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Brexit day 1: HMRC details 'easements' for traders

HMRC have published details of measures to assist traders in the event of there being no deal in place come Brexit.  Described as ‘day 1 easements,’ the measures are part of an update of broader advice regarding the UK’s departure from the European Union on the 29th March.  The documents can be seen via the links below but here is a brief summary of points that might be of interest for international traders and agents.

EU Ro-Ro Traffic

Traders will be able to lodge declarations in advance of goods arrival and confirm arrival with HMRC by the end of the following working day.  For most traffic there will be no stopping for checks, drivers will simply need to produce a declaration reference number in order to proceed.  The exceptions will be where intelligence has flagged a transport as ‘high risk’.

Transitional Simplified Procedures (TSP)

The full declaration of EU to UK Ro-Ro goods can be further delayed through the use of TSP.  This will work in a similar way to the current CFSP system.  A basic simplified declaration (SFD) is lodged before arrival, with the full declaration due by the 4th working day of the following month.

CFSP Liabilities for Agents and Intermediaries

Because agents may be reluctant to take on the liability of new traders, HMRC are allowing intermediaries to use their own CFSP authorisation as a direct representative with the trader remaining liable for duty and VAT.  This will apply for all goods intended for release to free circulation, at all ports and all transport methods (not just Ro-Ro).

Duty Deferment

In order to use simplified procedures, traders must have a deferment account to pay for any duty or VAT levied.  Normally this account must be backed by a Customs Comprehensive Guarantee (CCG), but this will not be required until 30th June 2019, in order to give new traders time to prepare.

Things to Note

Those currently only with trading between EU and UK will need an EORI number ready in order to continue after Brexit.  Applications for an EORI can be made via the website.
Most of these ‘day 1 easement’ measures will be monitored, and eventually withdrawn.  They represent temporary measures to allow frictionless trade.  HMRC have said in most cases 12 month notice will be given to traders before they end.
This is only a brief overview – please see the links below for further details.
Partnership Pack
Simplified Import Procedures
Ro-Ro Port Guidance

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