4th December 2018

Application for Training and IT Grants now OPEN

The UK Government has now released full details of the Training and IT grants along with details of how to apply. 

Businesses are urged to apply as soon as possible in order not to miss out on the funding.   

Apply here

Full details of the scheme are below - our training courses will be eligible for the training grants either as public courses or in-house training.  Demand will be high so please book early to avoid disappointment. Book here .

How to make an application:

When you apply, you’ll be asked for your:

  • registered company name and number
  • business’s contact details
  • business’s VAT number (if this applies)
  • Unique Taxpayer Reference (UTR)
  • business’s most recent utility bill

Depending on which grant you’re applying for, you’ll also need to provide some information about what you’ll use the funding for.

Training grant

You’ll be asked for:

  • a quote for the cost of the training
  • the CV of the trainer if the training will be delivered internally


IT improvements grant

You’ll be asked for:

  • details of the software you intend to buy
  • quotes for the cost of:

  • buying and installing the software
  • buying and installing related hardware
  • training employees to use the software

If your application is successful you’ll receive a grant offer letter.

After you’ve paid for the training or IT improvements, you’ll need to submit your proof of payment to receive the funding.

The grant will be paid to you within 30 days of your valid claim for reimbursement being accepted. It’ll be paid by Bacs (Bankers Automated Clearing System) to a UK bank account in the name of the person who applied.


You can apply for 2 grants to help your business complete customs declarations, in preparation for the UK leaving the EU.

You can apply to get funding for:

  • training that helps your employees to complete customs declarations and processes
  • IT improvements to help your business complete customs declarations more efficiently

To apply for the training grant, your business must either:

  • complete customs declarations for yourself or someone else (or intend to in the future)
  • import from, or export to the EU and complete customs declarations (or intend to complete customs declarations in the future)

The training must give your employees skills to:

  • complete customs declarations and processes
  • help other businesses with import and export processes

The training does not have to lead to a formal qualification.

If you want to arrange the training internally, you can use the funding for the cost of delivering the training, like related stationery, room hire and catering.

If the training will be delivered by an in-house trainer, you can also use the funding to cover the (reasonable) day rate of the trainer.


You cannot use the funding:

  • towards the existing costs of current training
  • for other unrelated training

The grant will give you up to 50% of the cost of training for your employees, up to a limit of £750 for each employee on a course.

You can get up to 60% of training costs, up to a limit of £1,050 for each employee, if your business:

  • employs fewer than 250 people
  • has an annual turnover of less than €50 million

You can get up to 70% of training costs, up to a limit of £1,050 for each employee, if your business:

  • employs fewer than 50 people
  • has an annual turnover (or annual balance sheet total) of less than €10 million


To apply for the IT improvements grant, your business must:

  • currently complete customs declarations for importers and exporters
  • have 250 employees or fewer
  • have an annual turnover of less than €50 million

You must use the funding to buy software that will help your business to complete customs declarations more efficiently.

It must be a ready-made solution - you cannot use the funding to commission bespoke software.

You can also use the funding to:

  • buy hardware that’s needed for the software to run
  • install and configure the software and hardware
  • buy the first year licence
  • train employees to use the software

You cannot use the funding for unrelated networking costs.

The grant will give you up to €200,000 (the maximum amount of state aid available).


22nd August 2018

Training Grants Available from December 2018

The UK Government is offering up to £750 per delegate towards training from December 2018.

The grant will give you up to 50% of the cost of training for your employees, up to a limit of £750 for each employee on a course

The training must give your employees skills to:

  • complete customs declarations and processes
  • help other businesses with import/export processes

To apply for the training grant, your business must either:

  • complete customs declarations for yourself or someone else (or intend to in the future)
  • import from, or export to the EU and complete customs declarations (or intend to complete customs declarations in the future)

As soon as the link to the application website is live we will publish it here.  Don't miss out on grants for our public and in-house training courses - prepare your wish list now,  save the dates in your diary and get ready to apply  for the grant and a place on our courses.


24th August 2018

VAT and importing goods in the event of a 'no-deal' scenario

The UK Government has published a paper giving guidance on new VAT procedures for goods being imported to the UK from EU countries and from the rest of the world.  These procedures will apply in the event of a 'no-deal' scenario taking place on 29th March 2019.

In this circumstance VAT would become payable on imports to the UK from the EU just as it is now for imports to the UK from outside the EU.     The Government has sought to ease the cash flow burden this will place on companies that have previously only imported from the EU by permitting the import VAT to be accounted for on the company's VAT return be that quarterly or monthly.     This system is to be called 'postponed accounting for import VAT'. 

In addition the UK Government will extend this new procedure to imports to the UK from outside the EU.  

Full details of the procedure to be followed will be given later.   Full details can be found here

23rd August 2018

Sending goods to or receiving goods from the EU in the event of a 'no deal'

The UK Government has today published a paper giving guidance on what exporters and importers will need to do to allow their goods to move to or from the EU in the event of a 'no deal' scenario taking place on 29th March 2019.   Companies need to start investigating and costing their options now.   This includes discussing the options and their likely impacts with their suppliers, customers, and freight/logistics providers to minimise supply chain disruption.   Contracts may need to be changed to ensure they cover the new arrangements, altered INCOterms and changed responsibilities.

​All exporters and importers will be required to have an Economic Operator Registration and Identification Number (EORI) this is free to obtain from HMRC.   Companies should apply here . EORIs are usually issued in three working days but it would be better not to leave it to the last minute!

For all goods being exported to any of the 27 EU Members States and for all goods being received from any of the 27 EU Member States a customs declaration (customs entry) will need to be submitted via the HMRC Customs Declaration System (CDS).    CDS is replacing the current HMRC CHIEF computer system.  CDS is live and different types of entry are being progressively migrated from CHIEF to CDS between now and the end of December 2018.

Companies can obtain links to CDS (commercial software and authorisations from HMRC are required) so that they can lodge their own data into CDS or they can contract with companies such as freight agents, customs brokers, logistics providers etc. who will enter the data for them.   Either option is likely to incur a cost.

In addition to the CDS declaration for imports a safety and security declaration will be required.  There are two types of Safety and Security Declarations: an Exit Summary Declaration (EXS) and an Entry Summary Declaration (ENS).    These are usually lodged by the carrier (haulier, shipping line, airline etc.).     The EXS is part of the export declaration via CDS.  

On arrival in the UK or in the EU goods will be required to pay import duty and VAT.  The amount of import duty or VAT will be determined by the tariff code that is appropriate to the goods.   In the event of a 'no deal' scenario the UK will have its own new tariff listing with its own duty and VAT rates.   The 27 EU member states will retain the tariff listing they use today.

UK Companies may wish to consider using special customs procedures to delay payment, or reduce to amount of import duty and VAT payable as the goods cross the border for example:

Duty Deferment Account - delays payment of import duty and VAT for an average of 30 days after import

Customs Warehousing - duty and VAT is suspended whilst the goods are in the warehouse, if the goods are re-exported duty and VAT is not payable, if the goods are eventually imported to the UK duty and VAT would then become payable.

Inward or Outward Processing - duty and VAT is suspended whilst the goods are subject to processing in the UK, if the finished goods are re-exported or placed in another customs procedure duty and VAT is not payable, if the goods are eventually imported to the UK duty and VAT would then become payable

Temporary Admission - some goods may be imported with duty and VAT suspended for particular uses e.g. testing, trade fairs etc. providing they are re-exported in a given time frame, unchanged.

Specific Use - duty and VAT is not payable even if the goods remain in the UK so long as the goods are used in the prescribed manner

​Authorised Economic Operator Status (AEO) - financial and procedural benefits are available for companies who can qualify for this status

​We are able to offer training and advice on all the above issues and procedures and how they may impact and/or benefit a company.

The Government paper can be found here 


Export Control in a 'no deal' scenario post Brexit

Currently any company that wishes to export an item outside of the the EU should have an export control process, the aim of which is to assess whether or not the combination of the type of item, the specific customer, the specific intended use and the final destination mean that an export licence is required.    Except for a small list of items this process has not been required for exports from the UK to EU countries or vice versa.

In a 'no deal' scenario post Brexit this process would need to be applied to movements of goods from the UK to the EU and from the EU to the UK.  Current regulations would continue to apply post Brexit, the only difference being that the rules would now be contained in UK law as opposed to EU regulations. 

Therefore there would not be any changes in the rules for the export of military items from the UK but these rules would now apply to shipments of military items to EU countries and export licences would be needed for shipments to the EU.

In the same way the movement of dual-use items to the EU would also now need an export licence.  Any existing UK export licences would no longer be valid for exporting dual-use items from EU member states and in the same way existing export licences issued by the 27 EU countries would no longer be valid for exporting dual-use items from the UK.   In both cases new licences would be required to be issued by the country of export.

The European Firearms Pass would no longer be available for UK persons taking their personal firearms to the EU.
However, the exemption that currently applies to the temporary export of firearms as personal effects to the rest of the world would be extended to exports to the EU.   Anyone seeking to take firearms as personal effects to an EU country would need to ensure that the destination country would also permit the re-export of the firearm.

Goods usable for torture or capital punishment would also need a licence for export to the EU or their export may be prohibited and UK companies will be forbidden from any involvement in providing brokering, training or advertising services in the EU for particular items.

For dual-use items  most exporters would be able to register to use a new Open General Export Licence designed specifically for exports to EU countries. This licence would remove the need to apply for individual licences and could be used immediately following a straightforward registration process.   This licence and the registration process would be available prior to 29th March 2019.  

Companies requiring individual licences for exports to the EU will also be able to apply prior to 29th March 2019.

We are able to offer practical training and advice on export control.

The UK Government paper can be found here


The impact of a 'no deal' scenario on Excise goods

In the event of a 'no deal' scenario on 29th March 2019 the Excise Movement Control System (EMCS) would no longer be used to control suspended movements of excise goods between the EU and the UK.

However, the EMCS would continue to be used to control the movement of duty suspended excise goods within the UK, including movements to and from UK ports, airports and the Channel tunnel.

This will mean that immediately on Importation to the UK, businesses moving excise goods within the EU, including in duty suspension, will have to place those goods into UK excise duty suspension, otherwise duty will become payable. A business will need to declare the goods on EMCS for onward movement via a Registered Consignor. 

For excise duty purposes, goods are not regarded as imported if they are immediately placed under a Special customs procedure such as customs warehousing, temporary import, inward processing etc. Businesses will need to pay excise duty when these goods are released for free circulation within the UK, unless they are immediately placed in excise duty suspension.

When exporting duty suspended excise goods to the EU, a business will need to continue to use EMCS to record the duty suspended movement from a UK warehouse or premises to the port of export.    Further information can be found here


Anti-dumping etc. in the event of a 'no deal'

​The UK Government has today published a paper detailing how the UK will operate anti-dumping, countervailling and other trade defense measures both in the event of a 'no deal' scenario and once we have left the EU with a deal.

​A new organisation to be known as the UK Trade Remedies Authority (TRA) will be operative by the time the UK leaves the EU.  The TRA will oversee and operate these trade remedies specifically for the UK and in the UK's interests.    

Should a withdrawal deal be agreed with the EU, EU trade defense measures will continue to apply to UK imports until the end of the implementation period in December 2020 and the UK will remain subject to any new EU measures introduced during the implementation period.    At the end of the implementation period the UK will apply its own measures via the TRA and will no longer be subject to the EU measures.

In the event of a 'no deal' all EU measures will cease to apply to UK imports from 29th March 2019.  The UK will however, will apply its own anti-dumping etc. measures from 11pm on 29th March 2019.   It is currently expected that 42 of the 96 currently existing EU measures will be replicated in UK law (see previous news item for link to the list of measures).    Companies will need to apply to the TRA if they wish new measures to be applied.   Full details of the application process can be found here

1st August 2018

Trade Defense Measures (Anti-dumping etc.) Post Brexit

A list of anti-dumping / countervailling measures that will either be maintained or terminated by the UK post Brexit has been published by the UK Government.    This list will either come into effect on 29th March 2019 in the event of a 'no deal' scenario or at the end of the implementation period (December 2020) if an agreement is reached.   Of the 96 EU measures currently in place only 42 will be continued by the UK post Brexit unless industry can make a case that a particular product does meet the criteria before 24th August 2018.   All the other measures such as the anti-dumping duty increase for bicycles from China will be terminated with immediate effect on the day we leave the EU.    The full list can be viewed here  a link is also included with information for companies wishing to make representations regarding keeping a trade defense measure that is listed for termination.

Termination of the measures will mean that importers to the UK will only pay the standard amount of import duty for their imports which will in many cases represent a significant reduction in costs.  

23rd July 2018

​Change from CHIEF to CDS

CDS is now set to go live on 12th August 2018 with a selected group of importers, freight agents and software providers.   Further importers will be added to CDS between August and November and exporters will be added by end December.  The intention is that all importers and exporters will have migrated by the end of 2018.   CHIEF will continue to run as a backup for some months.

If you are an importer or exporter and you have not yet had a detailed conversation with your freight agent, customs broker or logistics provider about the additional information required from you by CDS, the new codes and any software changes that will be required now is the time to do so!   Standing instructions will have to change.   It might also be useful to discuss what training has been given to staff and if your third parties envisage any contractual or fee changes.

​16th July 2018

The Customs Bill

The real name for this Bill is the Taxation (Cross Border Trade) Bill which is an enabling bill, meaning that it does not contain all the operational details just the headline procedures.    It out the new UK customs law that will replace the Union Customs Code (UCC) post Brexit. The Bill has completed the Parliamentary phase and is now with the House of Lords where it can be considered but not amended.   It will then return to Parliament and the expectation is that it will receive Royal Ascent in September.   All the operational detail will be contained in Statutory Instruments which are expected to be published in the Autumn.

12th July 2018

The White Paper

Known as 'The Future Relationship between the United Kingdom and the European Union' this UK Government White Paper sets out the government's view of how the UK will interact with the EU post Brexit.   It should not be confused with the EU Withdrawal Act that officially removes the European Communities Act 1972 from the statute book and converts the body of existing EU law into UK law.   

The White Paper contemplates two options for the future relationship 1. the 'No Deal' scenario and 2. a principled and practical Brexit.   These two options replace the previous suggestions and are now the only two under discussion.    The second option takes the form of an Association Agreement proposing a free trade area between the UK and the EU and includes a Facilitated Customs Arrangement.   The FTA and the FCA between them would ensure no tariffs were applied between the UK and the EU and no customs declarations were required either.  You can read the full document at https://www.gov.uk/government/publications/the-future-relationship-between-the-united-kingdom-and-the-european-union

14th June 2018

Mergers, Acquisitions and Export Control

The UK government has strengthened its ability to scrutinise mergers and takeovers that may raise national security concerns, through new rules that came into force from 11 June 2018.

The new rules apply to companies that are the target of a merger or acquisition and that trade in and/or export military, dual-use, computing hardware and quantum technology that are most likely to have implications for UK security.

The new rules allow ministers to intervene for public interest reasons when the target business’s UK turnover is more than £1 million thereby qualifying it for investigation by the Competition and Markets Authority.

The changes have been made to the Enterprise Act 2002.


12th June 2018

Boost for Global AEO Scheme

Singapore Customs and Australian Border Force (ABF) signed a Mutual Recognition Arrangement (MRA) of Authorised Economic Operator (AEO) programmes on 31 May 2018. Through this arrangement, Singapore companies certified as having lower risks will enjoy faster Customs clearance with reduced documentary and cargo inspections with respect to their goods exported to Australia. Likewise, Australian companies that are certified by Australian Border Force will enjoy similar facilitation for their goods exported to Singapore.

The Australia-Singapore MRA recognises the compatibility of the supply chain security measures implemented by companies certified under Singapore Customs’ Secure Trade Partnership (STP) programme and the trusted companies of the ABF’s Australian Trusted Trader programme, which are based on the WCO SAFE Framework of Standards.

6th June 2018

How to get you product exempted from USA steel and aluminium additional tariffs

The tariffs imposed under Section 232 of the US Trade Expansion Act of 1962 include provision for individual companies to seek an exemption for their products. This process is being led by the US Commerce Department.  UK Government departments DIT and BEIS have been supporting UK firms to appeal for exemptions under this process and will continue to do so.

This is the process:

  • all exclusion requests must be in electronic form and submitted to the Federal rule making portal here  
  • only companies with business activities in the US can apply. This means UK firms without a presence in the US cannot apply directly to Commerce for a product exemption and firms will need to work with the end users of their products in the US to apply for a product exemption
  • approved product exemptions will only apply to the US firm applying, ie even if the producer is the same each end user must apply separately
  • all the information is on the regulations.gov website along with the guide and application form
  • the data required for application is detailed and must demonstrate that the product is not readily available in the US
  • each request will be posted online for 30 days for comment
  • processing of exclusion requests normally will not exceed 90 days, including adjudication of objections submitted on exclusion requests


1st June 2018

Free Trade Agreements Post Brexit

A potential issue with the UK continuing to use EU Free Trade Agreements during the proposed Brexit implementation period has been raised.  This concerns the possible reaction of the non-EU signatories e.g. South Korea for the EU-South Korea FTA.  Currently any UK origin content in an item would be considered to be EU content and would therefore contribute to the item attaining EU origin status according to the rules in the FTA.   Once the UK has left the EU this UK content would no longer contribute to the EU origin of an item.  Depending on the rules for each tariff code within each FTA this could mean an item no longer has sufficient EU content to be considered to be of EU origin and would therefore not qualify for import duty discounts under the FTA.  Companies are strongly advised to look at the origin build up of their products in order to prepare and plan for change.

22nd May 2018

The Customs  Union

There has been much debate regarding the UK being a member of 'a' or 'the' customs union with the EU. Once the UK has left the EU and has become a 'third country' being a member of any kind of customs union with the EU and not being a member of a customs union makes almost no difference to the 'need to inspect' the goods at the arrival port as can clearly be seen from the slide here.   Whilst as a 'third country' the UK will be free to make its own rules about goods inspections the rules currently in place in the EU will continue for the EU27.


3rd May 2018

Fulfilment House Due Diligence Scheme


From 1 April 2018 all businesses that fulfil goods for, or on behalf of, someone outside the European Union (EU) that are offered for sale in the United Kingdom (UK) must apply to register for FHDDS online.

The scheme helps HM Revenue and Customs (HMRC) to make sure that VAT and customs duty is accounted for on imported goods sold to consumers through fulfilment businesses in the UK. From April 2019, all registered businesses will need to comply with new record-keeping and due diligence standards.

​You must check if your business meets all of the following criteria:

  • the goods you store were imported from a country outside the EU
  • the goods are owned by, or stored on behalf of, someone established outside the EU
  • the goods are being offered for sale and have not been sold in the UK before

If you meet the criteria you need to Register by 30th June - there are fines for late registration

Register here 


6th April 2018

Change to Duty Repayment Claims Procedure

HMRC has clarified the position for duty repayment claims.

Prior to May 2016 the law permitted the submission of incomplete applications for duty repayment and allowed them to be 'protected' for an agreed amount of time to enable the outstanding information to be submitted.  This facility was also allowed  where the application was based on the outcome of a future event, such as a pending court judgement.  Existing claims which were protected before 1 May 2016 under will be processed on their own facts.

From May 2016 the facility to submit incomplete applications was no longer available.  Under the UCC HMRC are required to :

  • check whether an application for repayment or remission is complete within 30 days
  • take a decision on accepted applications within 120 days of the date of acceptance of application

The time limits to submit applications for repayment or remission under the UCC provisions are within:

  • 3 years from notification of the debt for applications under Article 117 (debt not legally due), Article 119 (error by customs authorities) and Article 120 (special situation)
  • 1 year from notification of the debt for applications under Article 118 (Rejected Imports)
  • 3 months from the date the customs entry was accepted on the Customs Handling of Import and Export Freight system (CHIEF) for applications made under Article 174 (invalidation of declaration)

The time limits are suspended where an appeal has been lodged against the notification of the customs debt. The suspension starts from the date on which the appeal is lodged and lasts for the duration of the appeal proceedings.   

 

3rd April 2018

The UK Government has today confirmed the introduction of one of the toughest bans on trade in ivory of all ages.   Trade will be banned in all ivory items except those with the following exemptions:

  • Items with only a small amount of ivory in them. Such items must be comprised of less than 10% ivory by volume and have been made prior to 1947.
  • Musical instruments. These must have an ivory content of less than 20% and have been made prior to 1975 (when Asian elephants were added to CITES).
  • Rarest and most important items of their type. Such items must be at least 100 years old and their rarity and importance will be assessed by specialist institutions such as the UK’s most prestigious museums before exemption permits are issued. In addition, there will be a specific exemption for portrait miniatures painted on thin slivers of ivory and which are at least 100 years old.
  • Museums. Commercial activities to, and between, museums which are accredited by Arts Council England, the Welsh Government, Museums and Galleries Scotland or the Northern Ireland Museums Council in the UK, or the International Council of Museums for museums outside the UK.


8th March 2018

The new UK Customs Bill has been published.  Its correct title is the 'Taxation (Cross-Border Trade) Bill.  This document sets out the legislation for how the UK will handle the movement of goods across its borders in the future (from the EU and the the rest of the world) and what customs procedures and processes will be available.   It is however, only a high-level bill without much of the required detail.  This detail is to follow in thousands of pages of secondary legislation to be published in April.


5th March 2018

A new version of the AEO Application Form C117 has been published by HMRC along with a new version of the guidelines for completion of the form.  You can view our notes of the changes here


4th March 2018

​Clandestine Civil Penalty Accreditation Scheme

This scheme run by UK Border Force reduces road haulage companies’ risk of receiving fines by making sure that they have effective systems to reduce the risk of illegal migrants hiding in their vehicles when they cross into the UK.   A full list of the haulage companies currently accredited can be foundhere


6th February 2018                                                                                                                                                                                         Customs Declaration Service

 The latest update from HMRC on the implementation of CDS is now available clickhere


18th January 2018
Export Control


The Consolidated List of Military and Dual-Use Goods has been updated with immediate effect.  All exporters should re-assess their products against the new list.  For further information and a link to the list see here 

 
16th January 2018
Tariff code deletions


Please see attached link for details of tariff codes being deleted with immediate notice across 12 Chapters 

 
11th January 2018
Bicycles from Sri Lanka


Anti-dumping duty (48.5%) on imports of certain bicycles produced by City Cycle Industries and consigned from Sri Lanka (whether or not originating there) has been re-imposed.   Anti-dumping duty is levied in addition to ordinary import duty. This regulation takes effect from 11 January 2018. The duty applies retrospectively from 12 April 2017.

8th January 2018
Tariff Ruling


An item (so-called ‘guy grip dead end’) made of 6 wires, each having a thickness of 3,25 mm. The wires are of galvanised cold drawn carbon steel. The wires run parallel to each other and are covered by a zinc coating. They are loosely twisted throughout their length and are bent to form a ‘U’ shape. 

The article is to be classified under CN code 7326 20 00 as other articles of iron and steel wire.

Classification under heading 7312 as stranded wire, ropes, cables, plaited bands, slings and the like is excluded because the article is not closely twisted until is it mounted on the telegraph pole.

​​27th November 2017
Customs Comprehensive Guarantee Questionnaire

The questionnaire is now available on-line here

Applicants do not need to complete the questionnaire if they currently hold AEO(C) or AEO(F) certification or if the application is only for a new deferment guarantee.

 
6th November 2017
Statistical Threshold


The Statistical Threshold allows simplified export declarations to be made for goods valued below the statistical threshold using export Customs Procedure Code 1000097, and, for Memorandum of Understanding approved operators, to use CPC’s 1000067 and 1000077 along with supplementary declaration CPC 1000007. It can also be used for imports of goods under Merchandise in Baggage.  The non-EU statistical threshold is defined in legislation as 1,000 EUR (in value) or 1,000kg (in net mass).  The value aspect of the statistical threshold for the UK in 2018 will remain at £873.

 
26th October 2017
Gift Allowance


The gift allowance for the UK in 2018 will remain at £39.  It should be noted that gifts may not be sourced and sent direct from retail stores (actual or online), as this isn’t allowed within the gift relief protocols as all consignments must be of a non-commercial nature.

Low Value Consignment Relief (LVCR)

The LVCR limit will remain at £15 for 2018. Goods with an intrinsic value of £15 or less do not incurr import VAT. Commercial consignments sent to the UK from the Channel Islands do not benefit from relief of import VAT.

 
10th October 2017
HM Treasury Customs Bill – White Paper


This White Paper sets out the government’s approach to legislating for a future customs regime, and to creating a framework that supports intra-European trade.   

As well as providing for implementation of a negotiated settlement with the EU – (the government’s preferred outcome) – the Bill provides for a range of other possible outcomes.   The White Paper therefore also sets out how the government would manage leaving the EU without an agreement on customs, in the event of no deal being reached.

The paper can be found here 

9th October 2017
Preparing for our Future Trade Policy post BREXIT


The UK Government has issued a new paper detailing how the UK can maximise our trade opportunities globally and across all countries – both by boosting trading relationships with old friends and new allies, and by seeking a deep and special partnership with the EU.

This paper has two parts: the first part outlines the world in which the UK trades and the role of trade in an economy that works for everyone. The second part outlines the basic principles that will shape the UK’s future trading framework, and the Government’s developing approach to trade policy.  

It envisages 5 key steps:

Trade that is transparent and inclusive

Supporting a rules-based global trading environment

Boosting our trade relationships

Supporting developing countries to reduce poverty

Ensuring a level playing field – a UK approach to trade remedies and trade disputes


The full paper can be found here


15th August 2017
Future Customs Arrangements post BREXIT  

We welcome the UK Government paper detailing its vision for customs arrangements post BREXIT.  That this is the first paper in a series of documents only serves to emphasise what we have always held true in that customs procedures are of critical importance to the future prosperity of the UK.   Two options are proposed:

1. Using existing tried and tested procedures for trade with third countries plus innovative facilitations to ensure as frictionless a border with the EU as possible and

2. Negotiating a new customs partnership with the EU where imports of goods destined for the EU which are transiting via the UK would be imported ‘mirroring’ the EU’s requirements.

Morley Consulting has always emphasised the importance of the Authorised Economic Operator certification scheme (AEO) to future frictionless trade and this government paper also highlights the benefits under both options for companies holding AEO status.    

AEOs are seen as crucial to reduce pressure and risk of delays at UK ports and airports.  This makes it all the more important for companies to start the process to achieve AEO now, as reaching the internal compliance level required to become ‘trusted’ takes time prior to application.

AEO status is also vital for easy movement across the Irish land border post BREXIT.

The full paper is available here
Details of AEO training are available here


13th July 2017
Proposal for New Import Licencing Requirements 


The European Commission has today put forward new rules to clamp down on the illegal import and trafficking of cultural goods from outside the EU, often linked to terrorist financing and other criminal activity. The proposal for a Regulation will now be submitted to the European Parliament and the Council of the EU. The Commission hopes that this will be swiftly adopted in the co-decision process.

The new rules foresee a number of actions which should ensure that the importation of illicit cultural goods becomes much more difficult in the future:

A new common EU definition for 'cultural goods' at importation which covers a broad range of objects including archaeological finds, ancient scrolls, the remains of historical monuments, artwork, collections and antiques. The new rules will apply only to cultural goods that have been shown to be most at risk, i.e. those at least 250 years oldat the moment of importation;

The introduction of a new licensing system for the import of archaeological objects, parts of monuments and ancient manuscripts and books. Importers will have to obtain import licences from the competent authorities in the EU before bringing such goods into the EU;

For other categories of cultural goods, importers will now have to go through a more rigorous certification system by submitting a signed statement or affidavit as proof that the goods have been exported legally from the third country

Customs authorities will also have the power to seize and retain goods when it cannot be demonstrated that the cultural goods in question have been legally exported.

Full press release can be found here 


12th July 2017
Export Finance  


Good news for exporters as new Government initiative makes more financial help available to businesses who wish to export.

Crucially support has been extended to companies in the supply chain who support exporters.

This will allow thousands of companies in manufacturers’ and service providers’ supply chains to access contract bonds and working capital loans with the government’s guarantee.

Further information is available here


16th June 2017
UCC Amendments  


The UCC Implementing Regulation (IA) has been amended and corrected with an effective date of 14th June 2017.

Notable changes:

Long Term Supplier’s Declaration of Preferential Origin – the template has been amended to show 3 dates;

1.the date of issue;

2.the date of commencement of the period (start date), which may not be  more than 12 months before or more than 6 months after the date of issue;

3.the date of end of the period (end date), which may not be more than 24 months after the start date

This amendment means that it is now possible for a Long Term Supplier’s Declaration to be issued for shipments undertaken prior to the issue date of the Declaration.

The maximum validity period for a Long Term Supplier’s Declaration is set at 24 months.

Transition arrangements for the REX system

When working with a preferential agreement where it is a requirement to register with the REX system for consignments valued over EUR6000 (or whatever value threshold is stated in the particular preferential agreement) exporters may continue to use their Approved Exporter Number on documents without the need for a signature until they complete registration on REX or until 31st December 2017 whichever is the sooner.

Alterations to TIR Carnet guarantee

Article 163 of Implementing Regulation (EU) 2015/2447 determines the limit up to which any guaranteeing association in the Union customs territory may become liable in relation to a particular TIR operation. The amount of covered guarantee  has been amended from EUR 60 000 to EUR 100 000 per TIR carnet.

Rules for designating the Office of Exit under the Transit procedure

Article 329(8) has been deleted. It provided for certain exceptions from the general rule determining the customs office of exit for the export of goods that are subsequently placed under a transit procedure. Due to a renumbering error, Article 329(8) mistakenly referred to paragraph 4 of that same Article but the intention was never to provide for an exception for the goods that are loaded onto a vessel that is not assigned to a regular shipping service.Full details of the amendments can be found at here

5th April 2017
GSP Changes  


The status of Tonga and the Ukraine has been updated under the GSP regime.  You need to ensure your processes and procedures reflect the changes. 

Tonga - In 2013, 2014, 2015 Tonga was classified by the World Bank as an upper middle income country and therefore was to be removed from the list of GSP beneficiary countries in Annex II of EU Regulation 978/2012 with effect from 1 January 2017.

However in 2016 Tonga was classified by the World Bank as a lower middle income country. Therefore it has been re-instated to the list of GSP beneficiary countries in Annex II of EU Regulation 978/2012 with effect from 1 January 2017.

Therefore there has been no interruption to Tonga’s entitlement for eligible goods to benefit from GSP preference.

Tonga has informed the European Commission it is to implement Registered Exporter (REX) system with effect from 1 January 2017

Ukraine - The deep comprehensive free trade agreement between the EU and Ukraine took effect from 1 January 2016. As it provides better tariff preferences than the GSP for substantially all trade, Ukraine will be removed from the list of GSP beneficiary countries from 1 January 2018

If you believe you have paid full duties on goods eligible for preference you can submit a claim for repayment (C285) to the HMRC National Duty Repayment Centre

30th March 2017
HMRC Performance 
 

HMRC publish performance statistics which can be quite a reality check for those who are not closely involved in Customs work.  Take a look at February’s stats here

25th March 2017
SPIRE replacement testing  


The Export Control Organisation is looking for more volunteers to test elements of the system replacing SPIRE.   Now is your chance to ensure the new system is fit for purpose!  Information on how to get involved can be found here 

Export Information 

HMRC has released new data on exports by region details can be found here 

15th March 2017
Export Licencing  


The Export Control Order 2008 has been amended to reflect new rules concerning goods & drugs which could be used for cruel, inhuman or degrading treatment.   Internal processes, procedures and guidelines should be updated accordingly.  Full details can be found here

14th March 2017
ISO 8559 series updated  


These standards for clothing manufacturers have been revised to take into account current changes in the sector and to harmonize size marking worldwide.

13th March 2017
Changes to Excise Duty 
 


Details of changes to Excise duty following the Budget can be found here

Systems, processes and procedures need to be updated accordingly.

8th March 2017
Tariff classification of Thumb grips for a game console controller  


Thumb grips for a game console controller measuring approximately 20 millimetres (mm) in diameter and 6mm in height. Made of elastic silicone (plastics) with an anti-slip surface. They are equipped with a self-adhesive aluminium profile, cut to the design of the support. These grips are used as caps on the joysticks of a game console controller.  Classified as 3926 90 97 as they are neither adapting the game controller for a particular operation, nor increasing its range of operations, nor performing a particular service relative to the main function of the game controller or of the game console

6th March 2017
Morley Consulting  


We are pleased to announce that Morley Consulting has become an Associate Member of BIFA with immediate effect.

Revised Triggers for UCC Re-Authorisation  

HMRC has further revised the triggers that will force a trader to apply for revised authorisation or guarantees for Special Procedures such as IP and OP.   Where possible the triggers have been reduced to allow traders to make use of their existing authorisations for longer.  Full details are available here

4th March 2017
Address changes for HMRC 
 

As part of HM Revenue and Custom’s (HMRC) digital programme they have centralised their postal mail facility which has produced changes to addresses.   It is important to note that most mail will now be scanned off site with the electronic files being sent to the relevant departments.  This scanning process means that time sensitive submissions should be sent earlier to ensure they are received on time.  Full details of the different addresses and what to do with original documents that you need returned can be found here

1st March 2017
Open General Export Licences
  

The Export Control Organisation (part of the Department for International Trade) has amended some of the Open General Export Licences.  Please see here for details

Business Collaboration Standard 
A new standard: ISO 44001:2017 Collaborative business relationship management systems - requirements and framework, has been published designed to help business collaborate successfully.  The standard can be applied at multiple levels from single projects to multi organisation business relationships. 

24th February 2017
Importing Bicycles  


The anti-dumping duty legislation that has levied additional duty on imports of bicycles and bicycle parts from China has been amended to remove or suspend some suppliers thus significantly reducing the amount of duty payable on imports of their products.  Full details can be found here

Export Control  

A new edition of the consolidated list of strategic military and dual-use Items that require export authorisation has been published.  Now is the time to review and update your internal product lists and procedures to take into account any changes that affect you.  The list can be found here


23rd February 2017
ISO Anniversary


Congratulations to the International Standards Organisation on their 70th anniversary today. Read more about the organisation here

22nd February 2017
The Trade Facilitation Agreement 
 

The Trade Facilitation Agreement (TFA) has been implemented today as it has now been ratified by more than 110World Trade Organisation (WTO) member countries.  This agreement will allow countries to benefit from more international trade by cutting the burdensome red tape associated with exporting and importing goods.  UKInternational Trade Secretary, Dr. Liam Fox, has stated that ‘studies suggest the Agreement, which largely concerns the cost of clearing goods for import and export – will greatly reduce costs, time and the number of documents required for goods to cross borders. They also suggest the TFA could add over £70 billion to the global economy, of which the UK is expected to benefit by up to £1 billion and could reduce worldwide trade costs by between 12.5% and 17.5%.’   In brief as a result of the TFA, those countries that have ratified will be required to:


  • publish fees and charges online
  • introduce a ‘fast track’ for perishable goods – reducing the amount of food that rots while waiting to cross borders
  • allow pre-arrival processing of documentation
  • allow the use of copies of documents, rather than originals
  • allow for the right to appeal customs decisions


 16th February 2017
 Changes to address
  

 Exporters can send Export Accompanying Documents (EAD) to HM Revenue and Customs (HMRC)  using a new  freepost address for indirect export movements from another Member State, where the  UK is the Office of Exit and  is discharging the EAD. 

 The new address is:

 FREEPOST 
 BT OPS 
 EAD 


3rd February 2017
Exclusions from GSP  


GSP preference will be suspended from 1 January 2017 until 31 December 2019 for the following:

Country               GSP section (Article 2(j)                Description
                             of GSP regulation

              

India                     S-5                                                       Mineral products
                              S-6a                                                     Inorganic and organic chemicals
                              S-11a                                                   Textiles
                              S-14                                                     Pearls and precious metals
                              S-15a                                                   Iron, Steel and articles of iron and steel
                              S-15b                                                   Base metals (exclude iron and steel), articles of base                                                                                                                                            metals (exclude articles of iron and steel)

                              S-17b                                                  Motor vehicles, bicycles, aircraft and spacecraft,                                                                                                                                                   ships and boats

Indonesia            S-1a                                                     Live animals and animal products excluding fish
                              S-3                                                       Animal or vegetable oils, fats and waxes

Kenya                  S-2a                                                      Live plants and floricultural products

Ukraine                S-3                                                       Animal or vegetable oils, fats and waxes
                              S-17a                                                   Railway and tramway vehicles and products


2nd February 2017
UK Government Brexit White Paper 
 
The UK Government have published the promised white paper setting out their strategy for the UK negotiations to leave the EU.    
Read the White paper here

1st February 2017
UK Parliament Brexit Vote  

Members of the UK Parliament passed the European Union (Notification of Withdrawal) Bill by 498 to 114 votes following two days of debate. The Bill allows the Government to invoke Article 50.

The Bill will now go into the Committee stage where amendments will be discussed before it moves on to House of Lords consideration.

You can read the Bill here


26th January 2017
Celebrating International Customs Day 2017 


This year’s theme is ‘Data Analysis for Effective Border Management’.   HMRC and the UK Border Force have indicated that they intend to enhance their current levels of targeted, intelligence led interventions for those considered to be either negligently or deliberately opening their international supply chains to risk.   Post BREXIT managing to ensure that the majority of shipments pass through ‘non-risky’ supply chains will be key to achieving the country’s global trade ambitions.   Find out more here 

Imports of Concrete 

Due to changes to anti-dumping regulation the following tariff codes have been deleted from the UK tariff listing with immediate effect -7214 1000 00, 7214 3000 00, 7214 9110 00, 7214 9190 00, 7214 9910 00, 7214 9971 00, 7214 9979 00, 7214 9995 00.   They have been replaced with new codes.  Please ensure you update your systems and use the new codes with immediate effect.

 Changes to Open General Licences 

The Export Control Organisation which is part of The Department for International Trade has advised that 13 open general export licences (OGELs), two open general transhipment licences (OGTLs) and an open general trade control licence (OGTCL) have been updated.   The new OGEL’s will take effect from the 31stJanuary 2017.   Details can be found here. Please ensure you understand the changes and how they apply to your business.

 

24th January 2017
UK Supreme Court Ruling on Brexit  


The UK Supreme Court have issued their ruling on whether the UK Government can enact Article 50 without a Parliamentary Act. 

8 to 3 majority rules that the Government cannot trigger Article 50 without an Act of Parliament.  

When the UK withdraws a source of UK law is cut off and changes are made to individuals rights.

The court has also ruled that the Government does not have to consult the Devolved Parliaments.

The full ruling is available here
 

23rd January 2017
US withdraws from TPP  

President Trump has signed the order to withdraw the US from the Trans-Pacific Partnership trade deal. He has also indicated that he plans to either re-negotiate or completely scrap the NAFTA trade deal between the US, Mexico and Canada.

18th January 2017
Voice ID for HMRC services
 


HMRC are seeking to make it quicker and easier for customers to access their services by reducing the effort required for security.  This month see the introduction of voice recognition services for customers phoning the tax credits and Self Assessment helplines with customers being encouraged to enrol for the voice identification (Voice ID) by speaking a security phrase five times.  This phrase is then spoken and used to automatically perform over 100 element comparisons to determine the callers identity when phoning in to the services, reducing the number of security steps needed. 

Users of HMRC's mobile app are already able to use fingerprint recognition to access services on compatible phones/devices.


17th January 2017
PM Mays Brexit Plan
  

The 'Plan for Britain'


1. Provide certainty about the process of leaving the EU
We will provide certainty wherever we can.

2. Control of our own laws
Leaving the European Union will mean that our laws will be made in Westminster, Edinburgh, Cardiff and Belfast.

3. Strengthen the union between the four nations of the United Kingdom
A stronger Britain demands that we strengthen the precious union between the four nations of the United Kingdom.

4. Maintain the Common Travel Area with the Republic of Ireland
We will deliver a practical solution that allows the maintenance of the Common Travel Area with the Republic of Ireland.

5. Control of immigration coming from the EU
Brexit must mean control of the number of people who come to Britain from Europe.

6. Rights for EU nationals in Britain and for British nationals in the EU
We want to guarantee rights of EU citizens living in Britain & rights of British nationals in other member states, as early as we can.

7. Protect workers' Rights
Not only will the government protect the rights of workers set out in European legislation, we will build on them.

8. Free trade with European markets through a free trade agreement
We will pursue a bold and ambitious Free Trade Agreement with the European Union.

9. New trade agreements with other countries
It is time for Britain to get out into the world and rediscover its role as a great, global, trading nation.

10. The best place for science and innovation
We will welcome agreement to continue to collaborate with our European partners on major science, research and technology initiatives.

11. Co-operation in the fight against crime and terrorism

We will continue to work closely with our European allies in foreign and defence policy even as we leave the EU itself.


12. A smooth orderly Brexit
We believe a phased process of implementation will be in the interests of Britain, the EU institutions and member states.

PM May stated that the Brexit vote was the 'moment we voted to embrace the world' and to become a 'truly global Britain'. 

She comfirmed that she wanted the UK to be able to trade as freely as possilbe with the EU but that 'partial membership or associate membership or anything that leaves us half-in or half-out' was not acceptable. We will therefore not be members of the Single Market post Brexit. 

Instead she will lead the UK to be one of the firmest advocates of free trade anywhere in the world and will persue a bold, ambitious Free Trade Agreement with the EU.

PM May wants tariff free trade with the EU, not to be bound by the Common External Tariff and to lodge our own tariff with the WTO.  This will mean negotiation regarding the UK's place in the Customs Union to acheive an agreement but at this point she has no preconceived position regarding the shape of any such agreement but it may mean leaving the Customs Union. 

She was also clear that she did not want an 'indefinite' transitional period. She wants an agreement to be reached by the end of the two years negotiation post lodging Article 50 in March and then a period of phased implementation to prevent a 'disruptive cliff edge'. 

She also warned the EU that no deal was preferable to a bad deal for Britain as the UK would then be free to trade globally as it wished.


12th January 2017
Export Licencing 


All export licensing pages on .gov have been revised and moved.   If you have bookmarks you will need to change them.  Click on this link to access the new pages click here


New Registration requirement 

The EU has now made imports of certain hot-rolled flat products of iron, non-alloy or other alloy steel originating in Russia and Brazil subject to registration.   This means that should anti-dumping duty be allocated to these products (a decision is awaited) it can be applied retrospectively to registered products.   Importers need to adopt contingency plans to ensure they are covered for the possible additional import duty.

Full details can be found here

 
9th January 2017
Importing Solar Panels
 

Imports from the following two companies are now subject to both anti-dumping duty and countervailing duty:

Ningbo Huashun Solar Energy Technology Company Limited   AD 36.2%   CD 11.5%

Jiangsu Seraphim Solar System Company Limited  AD 41.3%  CD 6.4%

Tariff codes concerned are:

8541 4090 21

8541 4090 22

8541 4090 23

8541 4090 29

8541 4090 31

8541 4090 32

8541 4090 33

8541 4090 39

6th January 2017
Registered Exporter Database
  

The global transition period has begun which moves traders from the present system of origin certification to the new EU REX system, initially for GSP shipments.   The transition period will last until 30th June 2020.  As each set of countries implement REX the Form A certificate of preferential origin will be phased out and will be replaced with declarations on commercial documents.

Traders are reminded that registering for REX does not mean that the registered company has been vetted in any way regarding the validity of any origin statements it provides.  Traders are expected to conduct their own due diligence before relying on such statements.

It should be noted that post BREXIT the UK may or may not remain part of the EU GSP origin system of preferences.   Traders should therefore consider their strategic position in the event that the UK is outside the system and without a replacement option or has a new system in place.

The following countries will apply the REX system from 1st January 2017:

Angola

Burundi

Bhutan

Democratic Republic of Congo

Central African Republic

Comoros

Congo

Cook Islands

Djibouti

Ethiopia

Micronesia

Equatorial Guinea

Guinea Bissau

India

Jenya

Kiribati

Laos

Liberia

Mali

Nauru

Nepal

Niue Island

Pakistan

Soloman Islands

Sierra Leone

Somalia

South Sudan

Sao Tome & Principe

Chad

Togo

Tonga

Timor-Leste

Tuvalu

Yemen

Zambia

The following countries have indicated they will operate the REX system from 1st January 2019

Bangladesh

Benin

Burkina Faso

Cabo Verde

Cambodia

Haiti

Indonesia

Kyrgyz Republic

Lesotho

Madagascar

Mauritania

Mongolia

Nigeria

Paraguay

Philippines

Samoa

Senegal

Tajikistan

Uganda

Uzbekistan

Vanuatu

Vietnam


VAT Rate Decrease  

From 1st January 2017 the Romanian VAT rate has been decreased from 20% to 19%.  Traders are advised to ensure any systems that hold this data are suitably amended.


Updated CNENs  

Chapter 9404 Bedding and Furnishings stuffed internally with any material has been clarified to indicate that ‘stuffed internally with any material’ includes material of any thickness.

Chapter 8504 Electronic components that supply power to motor vehicles – specifically an electronic control unit (ECU) which supplies power to the xenon headlights of motor vehicles when the headlights are turned on by firstly converting the direct current 12 volts from the on-board electrical system into 1200 V DC and transmitting it to the igniter and then converting the DC into AC to light the lamps and continuously generates the voltage required to keep the lights burning.   Classification of this device is 85044090 other static converters.

The following countries have been removed from the GSP scheme with effect from 1st January 2017:

Cameroon

Fiji

Georgia

Iraq

Marshall Islands

Tonga

Samoa is removed from the Everything But Arms ‘EBA’ listing from 1st January 2017.

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