The British Government has today announced the introduction of the UK Global Tariff which will come into effect on 01 January 2021.
This tariff schedule will set out the Most Favoured Nation (MFN) or WTO duty rates that will be levied on goods entering the UK from third countries (including Ireland if there is no trade deal agreed between the EU and the UK over the coming months).
The new tariff schedule replaces last year’s provisional Tariff where almost all imports were set at a 0% duty rate.
In their press release today, the UK Government stated that the new UK Global Tariff will make it easier and cheaper for businesses importing goods into the UK from third countries. However, it is important to understand that this is not necessarily the case for Irish businesses importing goods into the UK, particularly in the food and beverage sector.
Amongst the changes made in the UK global tariff are significant simplifications to how tariffs are to be applied, a lower duty regime in comparison to the EU Common External Tariff Schedule and Pounds Sterling (£) will now replace Euro (€). ‘Nuisance tariffs’, i.e. tariffs less than 2% are also set to be abolished.
This trade update summarises how UK exports in sectors key to the Irish economy will be affected by the UK Global Tariff Schedule.
Food Sector
Earlier today, the British Government announced it will levy tariffs on many food imports coming into the United Kingdom.
Of particular interest to Irish food exporters and the broader Irish economy is the UK Government’s intention to impose protectionist tariffs on beef, fish, butter and poultry, amongst other products.
The tariffs on goods such as beef, butter and poultry products entering the United Kingdom are comparable in quantum to the Tariffs laid down in the European Union’s Common External Tariff.
Consequently, in the absence of a trade deal between the European Union and the United Kingdom, Irish Exporters will no longer have such favourable access to the lucrative British food market and will now be forced to compete with larger scale, lower cost, but also lower quality competition from around the world.
For products of Tariff Chapters 17, 18, 19 and 21 (e.g. biscuits, chocolate, bread, pizzas, quiches, sandwiches etc.) the UK Government has confirmed that they will simplify the application of the UK global tariff by no longer applying the Meursing table. This is a positive development as exporters to UK no longer be required to pay for having their goods analysed to determine levels of starch/glucose, sucrose/isoglucose/invert sugar, milk fat and milk protein respectively. Instead these goods will have duties levied at a single simplified rate specified in the UK Global Tariff.
Pharma / Chemical Sector
For a UK based entity Importers perspective:
- Organic Solvents of Chapter 29 – Many key solvents used in the production of Pharmaceuticals will see the Tariff reduce from the EU duty rate of 5.5% to a new UK duty rate of 4%
- Key Chemicals & API (Active Pharmaceutical Ingredients) classified in Chapter 29 - Key chemicals used to produce APIs or the importation of API itself, will see a typical Tariff reduction from the EU duty rate of 6.5% to the new UK duty rate of 6.0%
- Finished pharmaceutical products in Chapter 30 – Finished pharmaceuticals in dosage/retail form & bulk continue to maintain the EU duty rate of 0%.
- Articles of plastic (Chapter 39) used in the production of medical devices will see a typical tariff reduction from the EU duty rate of 6.5% to a new UK duty rate of 6.0%
- Medical Devices (Chapter 90) for use or demonstrational & educational purposes will continue to attract the duty rate of 0%
From a UK Importers perspective, if current supply chains are from outside the EU, a reduction in typical duty spend can be expected as the new UK tariffs are less than or equal to the EU level in all instances.
However, where the present supply chains are from within the EU, there will be a significant additional cost to business as these tariffs (reduced or not) are not currently a consideration and now must be accounted for.
Aviation Sector
From a duty perspective, today’s UK tariff announcement represents some positives for the aviation industry.
From the 1st of January 2021, aircraft of all weights that are imported from a third country, including the Republic of Ireland and the EU, will no longer be subject to customs duty. Along with this, helicopters of all weights have now been reduced from duty rates of 7.5% & 2.7% to 0% respectively.
In relation to aircraft parts, the duty rates of a number of products classified under tariff headings 8803 and 8805 respectively, have been reduced to 0%. It’s worth noting however, that with the high volume of materials that can be incorporated into aircraft, we would advise reviewing the full list of your own parts and verifying this against the new UK Tariff.
Along with this, the UK will no longer be a member of the European Union Aviation Safety Agency (EASA), so it is important to understand your certificate requirements when importing to or exporting from the UK.
Industrial/Manufacturing Sector
It would appear that apart from articles related to the automotive industry, the duties being levied by the UK on machinery and other industrial goods have been set at 0%.
In its press release, the British Government signalled their intention to protect the UK automotive industry by means of continued imposition of tariffs.
The reduction of customs duty appears initially to be beneficial, however, other customs formalities will now be applicable where they were previously not. Importing into the UK from the EU will now require an import declaration and VAT requirements.
If you have any questions related to the above, please contact Carol Lynch, Partner, BDO Customs & International Trade at [email protected]