The first change you'll have to deal with is the fact that you have to file an "export declaration (EU-A)" for all shipments sent to the UK. This is standard for all countries outside the EU. If you have shipped to countries outside the EU before you will already be aware of this procedure. But if you have only shipped goods within the EU until now, this is something new you'll have to take into account.
Submitting the declaration digitally
An "export declaration" can only be made by an EU company. Your customer in the UK cannot arrange this themselves. Therefore they will probably ask you to arrange this. A declaration is made digitally via the customs system. The EU-A document you receive after the declaration is usually available after 15 minutes, but Customs may want to physically inspect the shipment. In that case they will be at the specified inspection location within 2 hours. So this will be completed and issued the same day.
Importing goods into the UK
This is the export side. Once the goods are at customs in the UK, it's the start of the importing process. This can only be done by someone who has a UK EORI number. Usually your customer will have already applied for this and the customer can handle it himself.
There is, however, also an option to open your own UK entity and then apply for an EORI number in the UK so you can handle this yourself.
Import duty EU-UK
Shipping without import duties is also a bit of a hassle. The best thing to do is to check the Access2Markets website to see if there is a duty at all. Enter the HS code of your product, choose the country of origin and the UK as country of destination. Under "Tariffs" you can see whether there is a duty for your product. This is listed under Most Favoured Nations (MFN). The percentage mentioned here is the duty that will be imposed if you cannot provide additional documentation, or if your goods do not have EU origin.
Statement on origin
If there is a percentage mentioned at MFN and your goods are of EU origin, you can use the "Statement on origin" to prove the preferential EU origin and thus import into the UK without import duty. This is an invoice declaration which you may place on your own invoice.
REX registration number
or an invoice value above € 6.000,- you should have a REX registration number and mention this in the invoice declaration. For invoices below € 6.000,- only mentioning the text is sufficient. Make sure that you have proof of the origin in your own administration in case of questions from, for example, the Economic Service. For a trader, this means incoming preferential supplier's declarations from your supplier(s), and for a manufacturer it means the product process description with cost price calculation and any incoming preferential supplier's declarations from your supplier(s).
Importer Knowledge file
Another option to avoid import duties is to create an "Importer Knowledge" file. In this file the importer records what the origin is. This file will consist of several documents and it's therefore possible that your customer asks for a Certificate of Origin for the shipment to the UK. The importer will include this in his file, which is then presented to customs. In this case the Certificate of Origin serves as additional evidence.
Preferential Suppliers Declaration
Brexit also affects you if your supplier is based in the UK and you ship to other countries outside the EU. Do you have for example Preferential Supplier Declaration showing products with UK origin, or Preferential Supplier Declaration issued by a company based in the UK? If so, these will no longer be valid as of January 1, 2021.
For example: You may have applied for a EUR1 for a certain product to Egypt last year. From now on this is no longer possible because your product has UK origin or one of your raw materials that you use to make your own end product has UK origin. Therefore you suddenly no longer meet the requirement for the EUR1. Read here more about the EUR1 certificate.
Our advice: Check all your supplier declarations and in case you are a producer, also check if you still meet the requirements for a EUR1 to one of the countries with which the EU has an agreement.
More about Brexit & trade compliance changes
This whitepaper was prepared by our specialists and contains an action plan that tells you what action points you need to take regarding trade compliance obligations.
Sr. Export Documentation Agent