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Upcoming changes to food imports in the UK

Following the introduction of additional port health checks in January, there are more HMRC considerations coming soon for food imports in the UK.

(If you need a recap on all the customs clearance regulations introduced in January 2022, you can download a Brexit pack here.)

If you are not prepared for the new regulations or taxes, then you could lose money on delays at the border, or by not being able to pass on costs.

Here is some information for you on the upcoming HMRC requirements for food imports into the UK:

April 2022 – Plastic Packaging Tax

From 1st April 2022, you may be liable for plastic packaging tax (PPT) on your food imports, regardless of the country of origin.

PPT is applicable if your company imports over 10 tonnes of finished plastic packaging components over any 12-month period. 

The tax is not accounted for when calculating import duty during the customs clearance process, but is a separate declaration made by your accountant.

Because the tax is £200 per tonne of finished plastic packaging components, and is only applicable to the importer, it is essential that this is factored into your prices now to avoid a shortfall when your accountant declares the PPT on your return.

What is a “finished plastic packaging component”?

An article is considered to be a finished plastic packaging component once it has completed all substantial modifications, which will apply to most of your shipping packaging for food imports.

A substantial modification is a process that changes the shape, structure, weight, or thickness of the article.

Examples of substantial modifications include, but are not limited to:

Layering/Laminating – Where 2 or more layers are bonded together as a new article.

Extrusion – Where the raw plastic is pressed to form a new shape.

Forming – Where plastic is heated and the shape is altered.

Moulding – Where plastic is put into a mould to form a new shape. 

Not all processes are classed as substantial modifications, though. The following are not considered to be substantial modifications:

Cutting – Where a larger piece is divided into multiple pieces.

Blowing – Where an article has a predetermined shape that is filled when hot air is applied.

Labelling or sealing – where a film or label is applied to the article.

From July 2022 – Additional port health regulations on food imports from the EU

Since January, your food imports from the EU have required pre-notification to the Animal and Plant Health Agency (APHA) on the Import of Products, Animals, Food and Feed System (IPAFFS), in addition to import customs clearance.

There will be a phased rollout of additional checks coming from July:

July 2022 – Products of animal origin

From July, your food import documents will need to have the Unique Notification Number (UNN) – that the IPAFFS system generates – displayed on your health certificate. An original health certificate will also need to travel with the shipment (a photocopy will no longer be accepted).

Your shipments will also need to have copies of all other paperwork travelling with the load in case of inspection at a Border Control Post (BCP).

September 2022 – Dairy imports

From September, dairy imports will follow the same process as the products of animal origin, as outlined above.

November 2022 – All other food imports

From November 2022, fish, composite products, and any other port health controlled goods will follow the same process as products of animal origin and dairy products, as outlined above.

Food imports from Northern Ireland

The above changes in importing food from the EU will not (currently) apply to shipments arriving to mainland U.K. from Northern Ireland as the Northern Ireland Protocol is still under review between the UK and the EU.

Do you need advice on HMRC processes for food imports in the UK?

UK Customs Solutions and the rest of the Customs Support Group provide end to end customs services in the EU and U.K.

If you would like help with customs clearance on food imports, please contact one of our experts for assistance.

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