Anything to declare? You might do soon

Irish businesses need to be proactive and get ready for simplified changes in customs procedures between Northern Ireland and the Republic of Ireland after March 29. That is the key message from BDO, which is running weekly information sessions until the end of March so clients and businesses can familiarise themselves with the basics of changes in customs transactions post-Brexit.

Carol Lynch, partner with BDO Customs and International Trade Services, asks one important question of companies to determine their need for knowledge in this area: Do you move goods across Ireland, Northern Ireland and the United Kingdom?

“If the answer is yes, then you need to be prepared for changes post-Brexit,” she said. “The training will consist of a three hour session explaining how to import and export goods, how to deal with customs and how to engage with clearance agents. By the end of the session, you will have an action plan in place for what your business will need to do and level of comfort that you will be in a good starting place in the event of a hard/no-deal Brexit by March 29^th.”

BDO is advising clients that Ireland is now in a high-risk situation for trade with a serious risk of a no-deal Brexit occurring on March 29^th. This would mean trading with the UK on WTO terms – effectively the same as trading with the US.

“While this may still be avoided through political negotiations, businesses unfortunately have no choice but to have a contingency plan in place in that event,” said Lynch.

According to Lynch, dramatic changes in customs procedures will come into play in the case of a ‘no-deal’ Brexit at 23.01pm on March 29. These include: the requirement of customs declarations; the requirement of veterinary checks and the application of duty rates.

Referring to authorised economic operators, Lynch indicated that 95 per cent of goods will pass through a border without additional checks. The next 3 per cent would be held by Revenue pending checks on the paperwork. The remaining 2 per cent would then be subject to full physical inspections, either because they are assessed as risky, or just due to random control.

Commenting on HM Revenue and Customs’ temporary decision to reduce the amount of information required from companies to simplify the customs procedure, Carol says that this is highly significant for Irish exporters to Britain.

“The simplified procedure would allow Irish exporters who are established in the UK to import goods, defer making a full declaration and defer customs duties until the month following import. This would simplify a lot of requirements for Irish exporters to Britain.”

“With such a short time frame left you must at this point ensure you have the requisite customs authorisations in place to allow your business to continue to import and export from what will shortly be a non-EU country,” she said. “We are also advising businesses to stockpile critical items for manufacturing and sale, avoid shipping or moving goods the week of the 29^th, and apply immediately for a customs registration (EORI).”

“Then you need to establish whether you need to obtain a ‘deferred payment account’ and, if so, put in place a guarantee provision with your bank to cover the duties that are going to be suspended. A deferred payment authorisation will allow you to import goods into Ireland from the UK and defer the payment of customs duties to the month following import.”

“If you export to the UK you should also now request a deferred payment authorisation from HMRC.”

Lynch said you must ensure your tariff classifications are correct in order to determine the right duty rates which must be paid. She added that a clearance agent will be necessary to lodge customs declarations on your behalf. A clearance agent will act on your behalf to enter your import and export documents into the customs system.

“As a first step to engaging a clearance agent, we would recommend talking with your freight forwarder or haulier,” said Lynch. “It’s also important to talk to your suppliers and customers to confirm who is acting as the importer and/or exporter of record for your purchases and sale as they are responsible for the payment of the import duties along with customs compliance”.

“If you trade in agricultural goods, and particularly if those goods are of animal origin, then additional veterinary checks and certs will be required along with additional time frames for notifying customs of imports.”

BDO is currently running a session every week until the end of March to help companies familiarise themselves with the basics of customs in a post-Brexit environment. If you move goods across Ireland, Northern Ireland and the UK, and you would like to avail of this training, please contact [email protected]

Article written by Siobhán Maguire, The Sunday Business Post, February 2019.