Day 1 easements Stakeholder concerns - PowerPoint Presentation

Slide1

Day 1 easements

Stakeholder concerns

In a no deal scenario:

b

usinesses won’t have necessary skills and capacity to comply with full customs obligations on Day 1

agent capacity is unlikely to meet demand

a

gents reluctant to take on inexperienced traders

risk that businesses could cease to trade rather than fail to meet legal requirements

Package of day 1 easements

HMG objectives for the border

Maintaining

security

Facilitating

the flow of goods (including animals, food and plants) and people

Protection

of revenue and compliance with standards

Day one easements

RoRo locations – a recap and where we’re going further

Transitional Simplified Procedures

Intermediaries’ liability

Guarantee relaxations

Longer

term

UK government is working on data driven solutions, use of technology for smarter borders and sharing more data

4

Traders

should

either lodge declarations electronically in advance with HMRC systems or make an entry in their own records, to

avoid congestion at the frontier, and

hauliers/ferry operators have to do the same with safety and security

declarations.

In previous conversations with stakeholders, under NDA, concerns were raised about the capacity of traders, hauliers or carriers to meet the new day 1

RoRo

requirements.

HMRC have listened to these concerns and will be introducing new easements to address them.

RoRo Day One Model - recap

Importing your goods

on Day 1

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Master Reference Number (MRN) or EORI provided to haulier/freight forwarderGoods held

Pre-border

En

route

customs

Pre-lodge

import

declaration

to UK

Government or complete entry in own records

Register for EORI

Duties

paid or deferred

Update status of customs to show

goods arrived

in UK

Goods free to leave

At UK border

Businesses can defer payment if:

Paying customs in

monthly payments

Using

special relief schemes

All companies

need an EORI number to trade across UK borders

Apply now on

gov.uk

Business

Haulier

UK Government

Key:

Responsible parties

After arrival in UK, update status of declaration by close of business

next working day

Risk-based checks, no change from current approach

Transitional simplified procedures

Traders can register to use TSP to delay full declarations at RoRo locations

TSP

will be reviewed

3 to 6 months after

29

March

2019

12 months’

notice

will be given when HMG decide to withdraw or amend

To be eligible, traders must:

Be established in the UK

Have the intention to import goods into the UK from the

EU

Have

an 

Economic Operator Registration Identification (EORI

)

number

Traders will not be eligible if:

They

are an intermediary or acting on behalf of someone else

They have a history of non-compliance

Goods will not be eligible if they are:imported from outside the EU

subject to a Customs Special ProcedureDetails about TSP registration process will be published on Gov.uk guidance shortly

TSP Declaration Process

There are two declaration procedures and traders will be guided to one or both depending on the type of goods they are importing:

TSP Controlled Goods process

The trader submits a simplified frontier declaration before arrival at the border, and ensure all necessary certificates and licences are available

The reference number for this declaration is given to the haulier as proof customs formalities have been entered into

On arrival in the UK, the trader updates the declaration to arrived before the end of the working day following the crossing

This is followed by a supplementary declaration

by the 4

th

working day of the month

following

the arrival of the goods in the UK.

If the trader is already using this process, they can choose to use it for standard goods as well.

TSP Standard Goods process

The trader makes a declaration directly to their commercial records when the goods cross the border

The trader will provide the haulier with their EORI number as proof the goods are subject to a TSP process

This is followed by a supplementary declaration

by the 4

th

working day of the month

following

the arrival of the goods in the UK.

Intermediaries and CFSP

EU rules mean that:

intermediaries using their own

Customs Freight Simplified Procedures authorisation on behalf of a trader who isn’t authorised

are also liable for duties and import VAT. This discourages intermediaries

from taking on new EU/UK clients.

new

EU/UK traders

are now unlikely to receive authorisation to use CFSP themselves before Day 1.

Day 1 easements:

allow

intermediaries to act in a direct capacity whilst using their own CFSP authorisations on behalf of a trader who isn’t

authorised

the

trader would be

solely liable

for any

duties

or

import VAT

helps

intermediaries to take on a ‘one to many approach’ – catering for a myriad of traders at any one

point

this

policy is intended to be time-limited but we will give businesses a 12 month notice period when changing this.this will apply to all ports, RoRo and non-RoRo and extends to RoW

trade too. HMRC is not proposing to change the eligibility criteria or current exclusions for CFSP, but the intention is to limit it to goods released to free circulation

Duty Deferment

If a trader will have duties or import VAT to pay, they must have a duty deferment account to use TSP or an agent’s CFSP:

in practice, this is a direct debit mandate

it allows HMRC to take a monthly payment of duties

t

he direct debit is taken 15 days after the supplementary declaration is made

EU rules require a customs comprehensive guarantee (CCG) to defer duty:

this covers

multiple debts under one

financial guarantee

t

raders

must meet competence and compliance criteria to

give a CCG

can

take up to 120

days

Day 1 easements:

traders will not be required to meet the CCG criteria

traders

will have until 30 June 2019 to submit

a financial guarantee to HMRC to back their deferment account

traders can still choose to apply for a CCG, as those with AEO C status can seek a reduction in the level of guarantee required to defer duty

Other guarantee relaxations

Special procedures allow traders to suspend duties and VAT:

in some cases duties will not become due, e.g. if goods are re-exported

EU rules require a customs comprehensive guarantee (CCG) to obtain a full authorisation for a special procedure

Day 1 easements:

most traders

will not be required to meet the CCG criteria nor provide a financial guarantee for:

Inward processing

Outward processing

Temporary admission

Authorised use (a.k.a. end use)

Customs warehousing

still need to meet criteria for the special procedure

t

his policy will be monitored, and traders will be given 12 months’ notice of changes

Guarantees for transit

The requirements for transit are governed by the CTC

A CCG will still be required to cover several transit movements, but an individual guarantee can be used for single movements

An individual guarantee

can include a

guarantor undertaking from a bank or financial

institution and a

cash deposit

The level of guarantee depends on the territories that the goods are moving through

Guarantees can take several weeks to set up, so

traders should

contact

their bank

or insurer about this as soon as

possible

Questions and Comments