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HMRC Updates Border Operating Model

HM Revenue & Customs (HMRC) have released an updated Border Operating Model (18 November 2021) document to assist traders moving goods in and out the UK. Within that guidance HMRC detail the end of many post-Brexit transitional regimes and changes to many Customs easements that will impact the majority of companies importing goods into Great Britain.

There are a number of notable dates for traders to remember:

On 1 January 2022 the ability to delay customs declarations will end and full customs controls will be implemented. Therefore, from that date if an importer wants to defer or delay customs declaration they must become authorised under one of the existing Simplified Declaration regimes. At the moment, under the UK’s special transition arrangements, an importer can routinely import goods and submit a customs declaration 175 days later. This facility will end on 1 January 2022.

Safety and Security declarations (called ENS) on imports will be required as of 1 July 2022 as opposed to 1 January 2022 as previously stated by HMRC.

From 1 January 2022 (instead of 1 October 2021), UK importers of Products of Animal Origin (POAO), animal by-products, and high-risk food and feed not of animal origin, must pre-notify UK import authorities of incoming consignments. Shipments coming from the EU or European Economic Area must be pre-notified before the consignment is due to arrive in Great Britain.

Products of Animal Origin (POAO), Sanitary and Phytosanitary products (SPS) are broken down into:

  • Sanitary products relate to animal health and certification is required to determine the health of the animals.
  • Phytosanitary relates to plants and fauna certification. These are referred to as SPS checks. POAO relates mainly to the food chain however it does include other industry sectors, such as products from leather, gelatine, etc.

From 1 July 2022, for exporters based in the EU an Export Health Certificate (EHC) will be required for exports of POAO from the EU into the UK. EU exporters must be registered on TRACES NT to apply for an EHC. TRACES is the European Commission’s digital certification and management platform for all sanitary and phytosanitary requirements, supporting the importation of animals, animal products, food and feed of non-animal origin and plants in the European Union.

Also, on 1 January 2022, UK importers must be registered with IPAFFS (Import of Products, Animals, Food, and Feed System). This is part of DEFRA – the Department for Environment, Food and Rural Affairs – and they are responsible for the import. They must have a UK address and are responsible for submitting the pre-notification of incoming consignments with the attached EHC via IPAFFS before the consignment is due to arrive. IPAFFS is a web-based service used to notify UK authorities of imports of live animals, their products, and germplasm. There are also special rules for Composite Products such as confectionery and those items containing different types of animal and plants when mixed with other substances.

Checks and inspections on SPS goods will be undertaken more frequently from 1 July 2022.

Would you like to know more?

If you would like to learn more about how Brexit may impact you, please visit our Practical Guidance: Brexit hub.

And if you have any questions or would like to discuss your specific circumstances, please get in touch with your usual Blick Rothenberg contact or Simon Sutcliffe using the details on this page or the form below.

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