EU-to-GB trade changes in 2022: a compliance check list for traders

Mon 20 Dec 2021
Posted by: Noelle McElhatton
IOE News

EU-GB trade

As regular readers of the IOE&IT Daily Update bulletin will know, customs declarations and full import controls start applying for goods entering Great Britain from the EU on 1 January 2022 onwards.

This deadline has not changed, despite an easement being announced this week (Wednesday 15 December) for goods entering GB from the island of Ireland – to allow for ongoing negotiations over the Northern Ireland Protocol.

Easements now ending

As the leading institute for trade and customs expertise, the IOE&IT is busy guiding its members through these changes.

With 2021’s easements now ending, the IOE&IT is here to support you and your intermediaries in moving goods EU to GB compliantly – especially if you have chosen to delay making customs declarations.

Trader concerns

“The delay in needing to make EU-to-GB declarations, while helpful to keep trade flowing during 2021, is now a cause of concern among some GB importers – be they retailers, manufacturers, distributors or hauliers,” said Vicky Payne, team lead at the IOE&IT Academy.

“This concern stems from realising that customs declarations are the trader’s responsibility – even though those declarations are possibly being managed in the trader’s name by an intermediary.”

IOE&IT checklist: 'Safeguard your EORI number'

GB importers of goods from the EU can no longer delay making customs declarations and need to pay the relevant tariffs at the point of import

Your business needs to pay any outstanding duties if you’ve moved goods from the EU to GB in 2021

Ensure you have an EORI number to move goods across the EU-GB border – in particular, you need this number for your supplementary declaration

If using intermediaries such as customs agents and hauliers, talk to them to be confident they understand the Border Operating Model and its obligations

Be vigilant when issuing instructions to intermediaries to make sure your company information is used correctly and that any movements are declared in the correct manner – over and above standard classification, VAT and origin

Your intermediaries are likely to have access to your EORI number. Ensure they are using your EORI correctly and legitimately

Agree Incoterms with your intermediaries and retrospectively check your Incoterms documentation. Do not assume shipments are being sent under Delivered Duty Paid (DDP terms) and remember the ultimate responsibility for import declarations rests with the trader

Apply to HMRC for Management Support System data (MSS) on imports and exports, which enables visibility of declarations being made against your EORI number. “This is a great tool enabling you to reconcile known shipments and should be used as part of your internal compliance programmes,” said Payne.

Help from IOE&IT

The IOE&IT is here to help, offering a dedicated Customs Health Check service to ensure any declarations made in your name are compliant.

“The penalties for non-compliance are often severe and can damage the reputation of a company – with both its clients and HMRC itself,” Payne said.

Check out Customs Health Check to ensure importing from the EU works as efficiently and compliantly as possible.  

Our full Border Operating Model Suite of courses can be found here.

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