The government this week has sent a warning letter to GB-based traders that have used the delayed declarations procedure to bring goods into the UK since 1 January 2021 but have not yet completed a supplementary declaration.
The letter from HMRC is addressed to those businesses that have moved goods from the EU into GB in the past – but have not yet made supplementary declarations this year according to HMRC records.
Though the requirement to make full frontier declarations has been delayed until 1 January 2022 under the government’s phased Border Operating Model, traders that have imported goods from the EU from the start of this year still need to have made supplementary declarations by 25 June, under the 175-day rule.
The latter is an easement in place since the end of the transition period (31 December 2020) that has allowed importers of goods from the EU to delay completing declaration requirements until 175 days (or roughly six months) after the goods arrived in GB.
In the letter, traders are told that if they moved goods from EU to GB free circulation since 1 January 2021, “you must make customers declarations for these goods”.
Traders that have imported non-controlled goods from the EU in 2021 are told “you can choose to delay your declarations.
“You’ll need to enter the goods in your records (known as an ‘entry in declarants records or EIDR) and then provide full details in your supplementary declaration. You need to do this within 175 calendar days after your goods are entered into your records or the date your goods arrived in Great Britain,” the letter says.
Revised government timetable
The new requirements are part of the UK’s Border Operating Model, whose revised timetable is here.
The legal obligation to complete supplementary declarations falls on traders themselves. HMRC has this year been warning that firms found to have deliberately not complied with the requirement to submit supplementary declarations may:
• Lose the option of delaying future declarations
• Have to submit all declaration information at point of import
• Receive financial penalties
The IOE&IT is encouraging traders to learn how to do supplementary declarations through its Border Operating Model suite of courses.