From a customs point of view, this meant that for non-controlled goods, from January 1st to June 30th, it was possible to make a deferred import declaration up to 6 months after the actual import took place, with full border checks coming into force on the 1st of July.
There was no requirement for a Safety and Security declaration until July 1st, 2021.
From an SPS point of view, this meant that for products of animal origin (meat, fish, eggs, honey, dairy, cheese, some composite products etc) and some foods of non-animal origin (fruit and vegetables), some exempt product checks would commence on the 1st of April 2021. On top of this, all such goods would have to be presented at a Border Control Post (BCP) from 1st of July 2021 where physical examination could be carried out at the BCP.
UK Government Announcement | 11th March 2021
On 11th of March, the UK government announced a 6-month delay to these SPS and customs controls respectively.
As a result, the UK government has published a clear revised timetable for the introduction of controls as follows:
- Customs import declarations will still be required; but the option to use the deferred declaration scheme, including submitting supplementary declarations up to six months after the goods have been imported, has been extended to 1 January 2022
- Safety and Security Declarations for imports will not be required until 1 January 2022.
- Pre-notification requirements for Products of Animal Origin (POAO), certain Animal By-Products (ABP), and High-Risk Food Not of Animal Origin (HRFNAO) will not be required until 1 October 2021. Export Health Certificate requirements for POAO and certain ABP will come into force on the same date
- Physical SPS checks for POAO, certain ABP, and HRFNAO will not be required until 1 January 2022. At that point, the checks will take place at BCPs
- Physical SPS checks on high risk plants will take place at BCPs, rather than at the place of destination as now, from 1 January 2022
- Pre-notification requirements and documentary checks, including phytosanitary certificates, will be required for low risk plants and plant products and will be introduced from 1 January 2022
- From March 2022, checks at Border Control Posts will take place on live animals and low risk plants and plant products
What does this mean for Irish Exporters?
This is a positive development for Irish exporters. The delay in implementing border checks will allow Irish exporters to continue supplying their UK customers in a relatively benign trading environment.
BDO advises its clients to use this time to prepare for the UK Border Checks that will be introduced on a staggered basis from October this year. Good preparation will allow Irish exporters to be in a strong position to assure their UK partners of continuity of supply in 2022.
Please note that in terms of the simplified requirements for lodging Import Declarations and deferred payment of customs duties, it is important to understand that it is necessary to seek authorisation from HMRC for this relief. It is recommended that this application is made as soon as possible. It is also important to understand that a key condition to this authorisation is that your company is established in the UK - unless your agent has agreed to act on your behalf in this regard.
If you require any assistance dealing with customs or trade issues arising from Brexit, please contact [email protected].
This note is for information purposes only and should not be treated as Customs or SPS advice.
The above insights cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO to discuss these matters in the context of your particular circumstances. BDO, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this blog or for any decision based on it.