Over the last four years , I have tried as much as possible not to post about Brexit. However, from a purely practical point of view I have relented, in the hope I can inform in an apolitical way.
Unbiased (I keep biting my lip even when I only write those words), I am going to try and put some of facts down which will hopefully inform traders who have been buying from suppliers within the EU, on what they need to do. I would like write about exporting to the EU , but that is even less clear and to be honest my interest is in stuff coming from the EU.
So lets start with some facts. There are 11,000 containers of UK Government PPE at Felixstowe docks. Ships coming into both Felixstowe and Harwich have been subject to delays for some time now. The Customs IT systems are not fully tested yet. Every UK point of entry ie ports & airports invariably run different types of software for customs declarations . It is muted there will be all singing, all dancing single system by 2025 . No matter whether there is a deal or no deal on Jan1 2021 things will change big time. If you did not really understand the words ‘free movement of goods’ you will then .
What’s to do then ? If you import absolutely anything from the EU or intend to then the following 2 steps are essential.
- Apply for an EORE ( pronounced by HMRC as EOREE. Well at least someone has a sense of humour or irony) .
- Apply for deferred Custom Declarations and Vat payment
You have to do No 1 before you No 2 (that may chime with some- schoolboy humour). You can only apply for 2 if you have not been a naughty person with HMRC. If you are having difficulty loading the HMRC site to download this form, it maybe the browser, as it only works on certain browsers. But HMRC Help Line doesn’t seem to know that. It also doesn’t explain the forms you may or may not need. The one that you probably do is called C1202 as it is a direct debit mandate for HMRC. Without this you are unlikely to get approved . Here’s a good ‘un, you have to complete the form online but then you have to print and post it. This implies that they could have anywhere between 100-200,000 postal applications between now and Christmas, which they will then have to handle manually. Having just had two weeks locally of no postal service, the signs are pretty ominous.
If your application for deferred status is confirmed it allows you to do 2 things …
- From the Jan 1 to June 30th you can defer making your customs declarations. But you must keep a record of all your transactions during that period. I will itemise the data you need later.
- Whilst in the EU there was an agreement that all VAT transactions between states did not carry VAT on the invoice. This stops on Jan 1. From then on, there will be no VAT on an invoice from an EU supplier but you will have to record the VAT that would have been due on that same invoice in your VAT returns.
The Following list are the core items you will need to record for customs declarations :
Customs Procedure Code
Consignment no/ Invoice no
Without doubt I will have missed certain elements but these are the basics. If a deal is reached, I get the impression that declarations will still have to be made as to what they contain is another matter . One thing is for certain is that you will have to record the Vatable amount as that will certainly be due on July 1. I cannot speak for the Northern Ireland Protocol, as that is another layer of political customs speak. Nor do I have any knowledge of specialised products such as plants , food, oil, gas, aero engines, airplane parts, chemicals, drugs………All of which I assume comes into the definition of oven ready deals.
None of this helps with the importing from nations not in the EU but have free trade agreements with the EU. There are fifty plus such nations . We have made a couple of deals notably Japan, Switzerland , Norway and Iceland but there are a number of significant trading nations where we will no longer have a free trade deal such as Mexico, Vietnam and Turkey. And I am not so sure there is a lot of help available. There are grants for training on customs procedures and there are also grants if you want to set yourself up as a Customs Agent ! I think that in itself tells a story. There are also many HMRC webinars . Having recently sat through one , I would not raise your hopes of celestial enlightenment . Maybe others are better .
I lied. At the start I said I was going to be apolitical . I have been . Now I am not. The UK Government has been floundering about in very deep waters dealing with Covid. So has every other National Government. No matter what shade of political belief , no Government would have got it right. It is one of life’s undeterminables. And it will continue to be so. The Government has a duty to preserve and protect the lives of its citizens. Where there are definitive actions that could be taken they should take them.
Which brings me back to Brexit. I am a remain voter accepting of the UK decision to leave. What I cannot agree with is reckless political ideology that puts our nation in harms way or at very least increases the risk to both health and wealth. One of the underlying principles of paying off the huge debts that have been incurred (quite rightly) is the returning to some form of economic growth. Even (at least most ) political Brexiteers agreed that the first months of Brexit would be very hard on the economy, and that was pre-covid. Consequently , I get very wound up by superficial ads with actors, apparently in large warehouses, saying we are ready are you? When they, the Government are very evidently not. Moreover, how would you expect hundreds and thousands of businesses that have currently got to deal with more economic, financial and emotional hurdles to deal with than at any other time since the 2nd world war .
So please tell me UK Government why you have chosen not to doing anything about the one thing you did have control of ie Brexit Transition you chose to stick with political ideology . That is to say you kept your snouts well and truly stuck in a political bucket . Take back control , whatever that means but do so when you when can at least see the steering wheel. As a consequence we can look to at very least six months of even more supressed if not depressed growth rates. Ta very much .