Operate after Brexit

Changes from January 2022

Trade with the EU - changes from January 2022

HM Government's temporary easements for businesses moving goods from, to and through Great Britain are ending. Find guidance and new regulations you need to be aware of from 1 January 2022.

What's changing?

Import easements are ending from 1 January 2022

From 1 January 2021, Great Britain ceased to be part of the EU Single Market and Customs Union.

For businesses that move goods from, to or through Great Britain, this has meant following HM Government’s new Border Operating Model – a blueprint setting out the new customs formalities and other regulatory requirements.

The following guidance features highlights from the 150-page Border Operating Model document, which you are recommended to check for guidance on goods specific to you, either as exporter or importer.

HMRC has also written to VAT-registered traders pointing to guidance on Border Operating Model changes.

Read HMRC's written guidance

To allow businesses to prepare for Border Operating Model changes, HM Government has phased in these new border control processes. A series of temporary easements were introduced, including allowing GB importers to defer making customs declarations on goods being brought into GB from the EU.

Government easements on import processes are now ending, as of 1 January 2022 (with the exception of goods entering GB from the island of Ireland – to allow for ongoing negotiations over the Northern Ireland Protocol).

If you are an exporter that imports components of your goods from the EU, read the following ‘Imports from EU’ section as this will be most relevant to you.

Imports from EU checklist (1 January 2022)

Changes from 1 January 2022

Customs declarations due

As an importer of goods from the EU, you can no longer delay making customs declarations into HMRC’s systems (CHIEF or CDS).

The default import declaration you need to make is called the ‘full frontier declaration’– or FFD in short. You need to make this declaration if you imported goods from the EU during 2021.

Your FFD contains all the required customs information in one declaration, allowing you to complete all your customs declarations processes in one go and removing the need for a supplementary declaration to be completed after the goods move.

If you are the importer, it is your responsibility to ensure the information about your goods, such as the commodity code (see HM Government guidance), is declared correctly on your declaration.

If using a customs broker, be sure to send clear and precise information in your written instruction.

Customs declarations: simplified procedures

As importers, you have another option called simplified declaration procedures which allows you or your intermediaries to clear goods for import using streamlined processes.

  • This allows you to submit or record only essential information relating to the goods movements at the point of entry into GB
  • You provide the remaining customs data required via a supplementary declaration (SDI) by the fourth working day of the month following when the goods arrive in GB

Apply for authorisation

Customs declarations: Pay duties owed

Your FFD also accounts for the taxes and duties you need to pay at the point of import, before your goods are cleared for entry into GB. If you imported during 2021, there may be duties outstanding which you need to pay.

Importers who have a duty deferment account (DDA) can postpone duty and tax payments associated with the FFD until the 15th day of the month following the goods movement.

A DDA provides the cashflow benefit of deferring customs duty, import VAT and excise duty for an average of 30 days.

Find out more and how to apply 

Rules of origin – pay lower or zero tariffs

The EU-UK Trade and Cooperation Agreement (TCA) allows importers to benefit from zero tariffs (or customs duties) on goods.

However, your EU supplier/exporter needs to provide you with evidence that the goods originate in either the UK or EU for the zero tariffs to apply.

As a GB importer, you can claim tariff preference on import if you have one of the following:

  • A statement on origin – this must be made out by your supplier/exporter to confirm that the product originates in the EU
  • Importer’s knowledge – this option allows you, the importer, to claim tariff preference based on your own knowledge of where the goods you are importing originate from

Check to see if your goods meet the TCA’s rules of origin

Customs declarations: GVMS and 'pre-lodgement model'

Certain GB border locations are implementing the 'pre-lodgement model', whereby customs declarations need to be submitted before departure and validated on HM Government’s new border control IT system, the Goods Vehicle Movement Service (GVMS), in advance of the goods being taken onboard vessels in the EU.

Detailed technical requirements at certain ports have been summarised in an easy to view format by the Institute of Export & International Trade.

Hauliers will:

  • Need to confirm pre-lodged declarations for the goods they are carrying into GB, using GVMS, to generate a Goods Movement Reference (GMR) number
  • Not be allowed to board any ferry heading to a GB port adopting the pre-lodgement model if they do not possess a GMR

Other ports will be adopting a temporary storage model whereby customs formalities are completed for the goods entering GB while they are in storage at that port for a maximum time of 90 days.

Pre-notification of sanitary and phytosanitary imports

If you are importing sanitary and phytosanitary goods, including live animals and animal by-products, the Animal and Plant Health Agency (APHA) or Department for Environment, Food & Rural Affairs (DEFRA) need to be pre-notified from 1 January 2022:

Certification, physical checks and entry via an official Border Control Post (BCP) port on agri-food imports from the EU commence on 1 July.

Imports from EU checklist (1 July 2022)

Changes from 1 July 2022

Safety and security declarations (ENS – Entry Summary declarations)

From 1 July 2022, ENS declarations will be required for importing all commercial goods from EU into GB. It is the haulier’s responsibility (or carrier responsible for movement) to obtain the ENS and as the importer, you need to ensure they have the information from you to complete the ENS.

Check if you need to make an ENS declaration and be aware of the deadlines for ENS completion

Export Health Certificates (for animal-origin goods)

Export Health Certificates (EHCs) will be required for agri-food imports from 1 July 2022. As an importer, you should check that:

  • You are aware of the different deadlines which apply from July to November depending on the type of agri-food goods. The Institute of Export & International Trade has published a visual timeline of key import changes.
  • The appropriate EHC has been obtained for your goods prior to shipment
  • A physical copy travels with your agri-food load
  • That your load is travelling through a Border Control Post

Phytosanitary Certificates (plants and plant products)

Phytosanitary Certificates and physical checks at Border Control Posts will be introduced for plants and plant products in phases from July 2022.

Importers need to:

  • Register as an importer on IPAFFS
  • Existing importers should continue to use appropriate IT system until DEFRA confirms switch to IPAFFS
  • Ensure your haulier is arriving in GB via a Border Control Post
  • Ensure your haulier is travelling with the original Phytosanitary Certificate/s on arrival in GB

Find out more

Imports from Ireland checklist (1 January 2022)

Changes from 1 January 2022 – temporary easements

GB importers of standard (non-controlled) goods from the island of Ireland

  • Requirement for import declarations continues to be delayed
  • GVMS is not needed for goods moving through GB pre-lodgement ports
  • No pre-notification required by GB importer for sanitary and phytosanitary (SPS) goods unless deemed high-risk
  • INSTRATAT (the EU system for collecting data on intra-EU goods movements) arrivals need to be submitted for GB imports from Ireland (where value threshold has been met)

Exports to EU checklist (1 January 2022)

Changes from 1 January 2022

Goods Vehicle Movement Service (GVMS)

Certain GB border locations are using HM Government’s new border control IT system, the Goods Vehicle Movement Service (GVMS).

Detailed technical requirements at certain ports have been summarised in an easy to view format by the Institute of Export & International Trade.

From 1 January 2022, GB exporters sending goods to the EU (including Ireland):

  • Hauliers to check the port through which your goods will leave GB – either GVMS or Inventory Linked
  • For goods moving through pre-lodgement (GVMS) ports, standard information is needed for GVMS to create GMR (goods movement reference) for goods to board the vessel
  • Check detailed customs procedures to be taken

Rules of origin for exporters

The EU-UK Trade and Cooperation Agreement (TCA) allows importers to benefit from zero tariffs (or customs duties) on goods:

  • Throughout 2021, GB exporters have had access to an easement allowing them to export goods to the EU under preferential trade arrangements. Under these arrangements exporters were not required to hold supplier declarations (as evidence that goods being used in manufacture are eligible for preferential duty rates to apply) at the time of export.
  • From 1 January 2022, this easement no longer applies. As the GB exporter, you must provide the EU importer with a statement on origin to indicate that the goods being exported meet the TCA’s rules of origin and are eligible for preferential duty rates to apply.

Exports to EU checklist (15 January 2022)

Changes from 15 January 2022

Sanitary and phytosanitary exports: Export Health Certificates required

While not related to UK Border Operating Model, this requirement comes with new EU legislation for suppliers of products of animal origin, composite food products and plant products, resulting in change for health certification for certain products:

If you export products of animal origin (POAO) and composite food products, here are actions to take:

  • Apply for an Export Health Certificate (EHC)
  • Find the appropriate EHC for your product
  • Read the terms and conditions of the EHC to identify whether goods the meet criteria for export to the EU
  • For certain POAO, GB-based suppliers/exporters need to be registered as an ‘approved establishment’ in the EU. Details of businesses already approved and how to register can be found on Food Standards Scotland.
  • Apply for EHC and nominate official for inspection
  • Your customer, the EU importer, should pre-notify EU authorities at the relevant EU Border Control Post prior to goods arriving via TRACES
  • Certified EHC travels with goods, and goods enter EU via relevant Border Control Post for checks

If you are exporting plant products:

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