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Trading agri-food with Northern Ireland is a challenge when moving them from Great Britain. Here is how to get them into Northern Ireland. There are five commercial ports in Northern Ireland (Belfast, Larne, Londonderry, Warrenpoint and Coleraine).  Except for Larne (which is privately owned by P&O) they are all public trust ports. Belfast Larne Londonderry Warrenpoint Coleraine. Since 01 January 2021, all agri-food goods, plants and animals entering Northern Ireland from GB, must do so via a Northern Ireland Point of Entry (POE). POEs have been approved by the European Union (EU). At the time of writing, the following ports are designate the following as POEs for the purposes of (SPS) checks: Belfast Port; Larne Harbour; Warrenpoint Port; Foyle Port; and Belfast International Airport. It is important for agri-food suppliers to verify the POEs inspection facilities and the category of goods that will be inspected at each of these facilities. Download details of the POEs Download the details on the POEs, their inspection facilities and the category of goods that may be inspected at each of these facilities is available at Points of Entry listings. Notification of imports to a Point of Entry Advance notice of the products arriving at the Point of Entry must be given using TRACES NT (Trade and Control Expert System). Importers or their agents must register as "Economic Operators" before they can use the system. Authorised Traders Authorised Traders (supermarkets and their trusted suppliers) may move goods from GB-NI under the conditions and qualifying criteria set out in Section 17.1 of the Compliance Protocol until at least 1 October 2021 - unless the deadline is extended (after this date, certification requirements will be introduced on a phased basis). STAMNI The scheme for temporary agri-food movements (STAMNI) for Authorised Traders covers products of animal origin (POAO), composite products, food and feed of non-animal origin and plants and plant products. These goods and products, when they are destined for retail sale in NI, are permitted to move under a STAMNI Compliance Declaration, alongside other requirements. These temporarily replace the need for official certification (such as Export Health Certificates, Phytosanitary Certificates, Marketing Standards Certification and Organic Certificate of Inspection). Download instructions and more details See also here: https://www.daera-ni.gov.uk/articles/authorised-traders Changes to April 2021 composite products rules by EU https://www.customsmanager.org/post/pizza-fish-fingers-burgers-and-the-like-eu-food-import-controls-from-21-april-2021-ready See also here: https://ec.europa.eu/food/horizontal-topics/international-affairs/import-conditions/eu-import-conditions-composite-products_en

Let's examine why NI businesses WIN big from the NI Protocol and how the Border works today NI Ireland business gets to be the only region that best of both worlds. In the UK and - somehow - in the EU Single Market. Northern Ireland businesses still win, it's just that England, Scottish and Welsh businesses lose. Please allow us to explain. Terminology sorted Let's get the language straight first: UK = United Kingdom of Great Britain and Northern Ireland GB = Great Britain without Northern Ireland (aka England, Wales and Scotland or the UK mainland) NI = Northern Ireland The Republic of Ireland = The island of Ireland without Northern Ireland = Eire A special situation Very early on in the negotiations ahead of the United Kingdom’s withdrawal from the EU, both the United Kingdom and the EU acknowledged the unique situation of Ireland and Northern Ireland. They agreed that a specific solution was needed to reconcile the different interests at play. The WINNER: Northern Ireland This solution was found benefits Northern Ireland in four ways: Avoids a hard border between Ireland and Northern Ireland, and safeguards the all-island economy and the Good Friday (Belfast) Agreement in all its dimensions; Preserves the integrity of the EU’s single market, along with all the guarantees it offers in terms of consumer protection, public and animal health, or combatting fraud and trafficking, Maintains Northern Ireland in the UK customs territory so that it may benefit from future Free Trade Agreements (FTAs) that the UK may conclude with third countries. No admin from NI -> GB N.I has it all: Single Market Access without being part of EU EU Customs Union - EU Singe Market and Member States explained in one picture This means that Northern Ireland gets to follow EU Customs Rules without being part of the EU Customs Territory. It gets full access to the Single Market of the EU without being part of the EU. It gets access to some 450 million citizens (including unhindered access to the Republic of Ireland) without any Free Trade Agreement having to be signed. Part of the UK Customs Territory At the same time, it gets to be part of the UK Customs Territory. So no need for any controls or checks getting into your own territory, at least in theory (what to do with goods coming from the EU Single Market - how to check that they comply with UK rules?). It can also benefit from Free Trade Agreements that the UK concludes. (what about EU trade agreements, do they also apply? Can NI benefit from the best of both worlds? If so, does this means that it is OK to bring in products at a lower rate of duty into Belfast than it would cost to get these goods into Dublin? Can you then just ship them across from Belfast to Dublin without any tax adjustment?) Just sit it out and reap the rewards Northern Ireland's luck does not depend on any further agreement, like a free trade agreement. The Protocol on Ireland and Northern Ireland will become applicable at the end of the transition period. It was conceived as a stable and lasting solution, and it can be expected that it will apply alongside any agreement on the future partnership. Overall, that's what I call lucky. Or is it? Let's examine a little closer: What has been agreed in the Protocol on Ireland and Northern Ireland 1. EU rules for Products & Union Customs Code Northern Ireland will remain aligned to EU rules related to goods and the Union's Customs Code will apply to all goods entering Northern Ireland. This avoids any customs checks and controls on the island of Ireland. 2. Controls will take place from GB -> NI Necessary checks and controls will take place on goods entering Northern Ireland from the rest of the United Kingdom, including for example, Border Inspection Posts to ensure that the necessary sanitary and phytosanitary (“SPS”) controls are carried out. 3. EU Customs Duties apply EU customs duties will apply to goods entering Northern Ireland. If goods are not at risk of entering the EU's Single Market, the UK tariff will apply. No customs duties will be payable, however, if it can be demonstrated that goods entering Northern Ireland from the rest of the UK are not at risk of entering the EU's Single Market. How does the GB - NI border work in practice today ? Today, electronic documents will need to be completed. This is to achieve customs control, the UK has agreed with the EU to ensure that all goods are presented and declared to customs that travel between GB and NI. To do this in an electronic format as much as possible, we need to understand a lot of abbreviations. These describe tools and rules that need to be met. At the very least, we need to understand: GVMS CDS TSS GMR Let's explore! GVMS Under the “Goods Vehicle Movement Service” (GVMS) system, hauliers or the owners of the freight can oblige to pre-lodge three types of electronic paperwork before getting on a ferry from British ports such as Liverpool or Cairnryan in Scotland to Northern Ireland. There are three sets of documents that may have been submitted before one can embark the ferry: The first piece of documentation that suppliers must complete is an import declaration form, which includes the customs commodity code or codes for any items being carried to Northern Ireland. Second, the provider may need to submit a safety and security statement, which is presently waived for all items traded in the EU's single market. Suppliers will then have to furnish their truckers with a transit accompanying document (TAD) which must stay with the vehicle at all times so the EU can be assured that the cargo that leaves Great Britain is the same as the one that arrives CDS The customs declaration system to be used is called the Customs Declaration Service (CDS). It has to be used for trade with Northern Ireland. If you are using the TSS Service, there is no need to use CDS as TSS is the interface between the two. TSS HMRC simplify the procedure using the TSS, the Trader Support Service, a one-stop shop for customs clearance supported by support staff, so that the three documents, as necessary, may be collected and pre-registered with the authorities. GMR At the end of the process, stands a "goods movement reference" number, or GMR, for the haulier to provide to the ferry operator. This will show that the shipment is being processed by customs and will provide port officials with information on how to handle arrivals. Checks Some cars will be permitted to go to their destination, while others may be compelled to pay tariffs if they continue to the Republic of Ireland, and those delivering food, drink, and animal products will be subjected to health and disease checks. GB -> NI treated as exports (even though they remain in the UK) While products travelling from the United Kingdom to Northern Ireland stay in the UK market, they are considered as exports and need this documentation due to the particular procedures included in the Brexit agreement to prevent a border on the island of Ireland. The price to pay The government is quoted as: “Our approach, welcomed by businesses, ensures that Northern Ireland will benefit from unfettered access to the whole UK market and that there will be no tariffs for internal UK trade in any circumstances”. What about the NI -> GB Border? The procedures will not apply to goods going from Northern Ireland to GB. Easy, no controls, no tax. Hang on, that sounds suspicious. How do we control EU goods entering the UK via the Republic of Ireland? Do we leave that to the Irish? Consent The EU and the United Kingdom have agreed to create a new mechanism on “consent”, which will give the Northern Ireland Assembly a decisive voice on the long-term application of relevant EU law in Northern Ireland, based on intense discussions between Ireland and the United Kingdom. This consent mechanism concerns the substantive issues of regulatory alignment on goods and customs and other matters. A vote every four years: 2025 for 2027 In practice, this means that four years after the end of the transition period, the Assembly can by simple majority give consent to the continued application of relevant Union law, or vote to discontinue its application, in which case the United Kingdom would notify the EU. In such a case, the Protocol will cease to apply two years later. Every four years thereafter, the Assembly can vote on the continued application of relevant Union law. In case a vote of the Assembly gathers cross-community support for the continued application of relevant Union law, the next vote can only take place eight years thereafter. How we can help For online support, join our educational live webinars, subscribe to insightful short Twitter updates and informative YouTube videos, and stop by at our expert blog page, updated weekly: https://www.customsmanager.org/customs-global-trade-blog Join us on Linked In, too: www.linkedin.com/company/customs-manager-ltd We also offer a resources hub that covers a lot of topics, videocasts and step by steps guidance: https://www.customsmanager.org/ -> Resources There are regular customs and global trade update sessions to discuss what is coming up: https://www.customsmanager.org/customs-and-global-trade-update Join our wide range of LIVE or online training courses on the customs and global trade topics that matter to you Subscribe to our free newsletter to never miss an important update on our social media channels and expert blogs and get a round-up on all the important changes, law updates and guidance modifications for the EU and the UK). You can also call our helpline on 079146450183. The first call is free, after this, we charge a moderate fee to get instant expert support. You can access it at https://www.customsmanager.org/expert-helpline-blog-training-exclusive-briefings If you know of a business that would also find e-mails or customs and global trade blog entries helpful, please forward it on, or suggest they register to receive them directly to their inbox register to get these updates directly to their inbox. About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer public and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements

The UK wants to unilaterally tear up part of the NI Agreement. Why? Analysis, Details, Explanation and the EU response - HERE! Content The WA? Why does this agreement matter? 2021 Troubles 2022 Troubles Why is Northern Ireland trade so complicated? 5 Reasons why the NI Protocol was accepted in 2019 What customs law applies in NI? What about customs duties? Why is a new NI Bill proposed? What is in the Northern Ireland Bill of 2022? Four fundamental challenges The UK Solutions Tell me more about the Green and Red Channels Dual Laws for placing goods on the market Is this change lawful? What did the EU say? Conclusion How We Can help About Customs Manager Ltd. The WA? To recall, the WA is the international treaty that was signed in late 2019 and which regulates the divorce proceedings and makes sure that both parties break up in a civil manner. This is known as an "orderly withdrawal" rather than a chaotic one. It includes extensive provisions as regards NI-GB trade and vice versa. Why does this agreement matter? The WA, which went into effect on February 1, 2020 has legal authority under international law. Since that moment, neither the EU nor the UK have been entitled to unilaterally revise, clarify, amend, interpret, ignore, or disapply the agreement - if you want to respect international law The Protocol on Ireland/Northern Ireland, in particular, is a crucial component of the Withdrawal Agreement. It was the outcome of lengthy, comprehensive, and tough discussions between the EU and the UK with the goal of protecting peace and stability on the island of Ireland. 2021 Troubles The NI Protocol has always been about politics, trust and the law. In 2021, UK government wanted to push through the “United Kingdom Internal Market Bill” which the EU felt would constitute an extremely serious violation of the Withdrawal Agreement and of international law. The UK argued it needed the ability to disallow the lodging of export declarations out of NI to GB if it wanted to. After working through the UK's concerns, the EU and the UK found mutually agreed solutions. So the UK has instead withdrawn clauses 44, 45 and 47 of the UK Internal Market Bill, and not introduce any similar provisions in the (Cross Border) Taxation Bill. 2022 Troubles On 13 June 2022, the UK had another go, publishing a law proposed which intends to repair elements of the Northern Ireland Protocol, restore stability, and safeguard the Belfast (Good Friday) Agreement. Why is Northern Ireland trade so complicated? The Protocol-I-NI (or NI Protocol for the UK) become applicable from 1 January 2021. It was conceived as a stable and lasting solution, as a practical way to avoid a so-called “hard” (controlled) border on the island of Ireland. This has been achieved by making NI part of the Customs Union of the United Kingdom. However, NI will remain aligned to a limited set of EU rules, notably related to goods. This arrangement has important consequences for the UK and EU businesses trading with NI and vice versa. 5 Reasons why the NI Protocol was accepted in 2019 For the UK Government, which signed the agreement, we recall, that this was acceptable in 2019 because it upheld unfettered access for Northern Ireland businesses to their most important market, eliminated most Northern Ireland to Great Britain export declarations. safeguarded Northern Ireland’s place in the UK’s customs territory, established the platform to preserve tariff-free trade for Northern Ireland businesses, protected the internal UK trade and maintain the UK’s VAT area. What customs law applies in NI? The Union Customs Code (UCC) applies to all goods entering or leaving Northern Ireland. This will avoid any customs checks and controls on the island of Ireland. What about customs duties? EU customs duties will apply to goods entering Northern Ireland if those goods risk entering the EU's Single Market. No customs duties will be payable, however, if goods entering Northern Ireland from the rest of the United Kingdom are not at risk of entering the EU's Single Market. For goods coming in from another country other than the UK or EU, a good being not ‘at risk’ will mean UK duties will be charged. This includes any preferential rates under UK Free Trade Agreements where those goods are eligible. Why is a new NI Bill proposed? This has been a long time coming. The UK government stated already in July 2021 that Article 16 of the Protocol had been met, since it caused trade diversion and serious social and economic problems. EU discussions, however, for 18 months, haven't produced any long-term answers, and the Protocol prevents the creation of a new Northern Ireland Executive. So, the UK felt they had to take action. What is in the Northern Ireland Bill of 2022? The UK government says that the law proposed on June 13 intends to repair elements of the Northern Ireland Protocol, restore stability, and safeguard the Belfast (Good Friday) Agreement. In particular, the bill should improve the social and political environment while respecting the Protocol's goals, such as trade and partnership between the North and South and EU and UK interests. safeguard the delicate balance of the Belfast (Good Friday) Agreement in all of its components alleviate social and political tensions in Northern Ireland. restore East-West links without damaging North-South. It does all of this WITHOUT affecting the EU. This is the crux of the issue. The actions suggested in the bill will not impact the EU. In fact, robust safeguards for the EU have been added to the bill. Four fundamental challenges The UK says the Protocol legislation would save excessive expenditures and bureaucracy for companies by introducing lasting remedies to the four fundamental challenges the UK has identified Cumbersome customs procedures Rigid regulation Tax and spend disparities Democratic governance concerns. According to the UK, these have led to trade interruption and diversion, as well as major expenses and bureaucracy for businesses. Most importantly, they say, this is eroding all three strands of the Belfast (Good Friday) Agreement and have resulted in the breakdown of Stormont's (Northern Ireland's Parliament) power-sharing mechanisms. The UK Solutions As a result, measures are required to maintain Northern Ireland's market access to the UK and vice versa. There are four principle solutions: Green and red channels to eliminate excessive expenditures and bureaucracy for firms dealing inside the UK while guaranteeing complete inspections on products entering the EU. Businesses should be able to choose whether to place items on the market in Northern Ireland under UK or EU norms, to ensure that Northern Ireland consumers are not precluded from purchasing UK-standard goods, especially when UK and EU requirements diverge over time. Ensuring Northern Ireland receives the same tax benefits and expenditure initiatives as the rest of the UK, such as VAT reductions on energy-saving goods and Covid recovery loans Normalise governance structures so that disagreements are settled by independent arbitration rather than the European Court of Justice. Read more in the UK's Explainer Document here: Tell me more about the Green and Red Channels These are the most relevant topics for the trade in goods and customs. In a nutshell, a new green and red lane model will be set up, underpinned by commercial data and a trusted trader programme. In this way, it removes barriers to internal UK commerce while avoiding a border on Ireland, preserving both markets and lowering costs for people and companies. It will look like this: Green lane for British goods UK aims to create a new "green route" for products remaining in the UK, so alleviating the constraints and complexity generated by the current application of EU customs and SPS laws to all commodities. Goods remaining in the UK would be exempt from onerous paperwork, inspections, and levies, with just standard business information needed rather than customs procedures or complicated certification requirements for agricultural goods. This minimises inspections on agricultural items, eliminates taxes on UK commerce, and lifts superfluous product prohibitions. EU products use the red lane. Goods entering the EU or being transferred by merchants who are not part of the new trusted trader system would be subject to full inspections and controls, as well as full customs processes, preserving the EU Single Market. Robust protection of Single Market 1) Trusted Trader The green lane would be for participants in a new trusted trader scheme covering all goods exchanges. To facilitate auditing and compliance, businesses will need to show their activities and supply networks. Mail and parcels will automatically utilise the green lane without registration. 2) Punishments are harsh Traders who misuse the new system risk civil and criminal penalties and cannot use the green lane. 3) Data sharing The UK sends the EU about a million rows of data weekly. In the new arrangement, we would continue to share data with the EU on the functioning of the trusted trader system and on all items moving between the UK and Northern Ireland to monitor abuse and allow risk-based information sharing and collaboration. Purpose-built IT: Information would be available in real-time and within the time needed to cross the Irish Sea. Green lane: Merchants' regular data interchange. Red lane: Sharing over 110 customs declaration fields under EU Customs Code. 4) Risk assessment quickly The UK would continue to implement restrictions where a different hierarchy of risk exists, just as we did before the UK's EU exit (for example, on live animals). UK and EU authorities would cooperate under a new biosecurity assurance framework to control risky commodities. Dual Laws for placing goods on the market The UK also wants a dual-regulatory framework that provides businesses choice together with strong promises to defend the EU single market. What is proposed: Goods may be sold in Northern Ireland provided they fulfil UK, EU, or both standards, ensuring customers can obtain the items they want and avoiding supermarket gaps. EU-marked goods must continue to fulfil all EU criteria. If the criteria are met, goods may be CE or UKCA designated, or both. This technique has been proven and tested in the UK, where NI products have had unhindered access since January 2021. Strong EU market safeguards Safeguards would prevent UK products from entering the EU market. Importers, manufacturers, and producers will be responsible for putting products on the market according to the right laws. Goods placed on the market in Ireland must follow EU standards, just as they do today. Rulebreakers face harsh consequences. Agrifood could only enter NI through our Trusted Trader Scheme, with strict sanctions for noncompliance. EU has approved that products may enter and stay in NI under the present framework for supermarket items. Market surveillance authorities will continue to have powers to ensure product safety inside the UK internal market, including the ability to visit premises, confiscate items, and seek legal action for criminal offences. These measures would be strengthened, including with coordination between UK, Ireland, and EU agencies to promote compliance and parallel operations. Is this change lawful? The UK Foreign Secretary thinks so. Overall, the UK government wants the EU to recognise that the Protocol must be implemented and operated with Northern Ireland's specific circumstances, constitution, identities, and sensitivities in mind. If the EU is unwilling to renegotiate the Protocol, then unilateral action must be taken. Here is our summary of why the UK government believes that that international law authorises this legislation: It is the word "Necessity" which explains why international obligations aren't always kept. International law uses "necessity" when a state can't protect a vital interest without violating another responsibility. Article 25 of the International Law Commission's 2001 Articles on State Responsibility specifies the core condition that must be met is that the activity can't injure the opposing state(s) or if the using state made the situation necessary. As a consequence, the UK government may be able to avoid international tariffs in certain situations. The situation in Northern Ireland is very unique. Only because Northern Ireland is a difficult, complicated, and one-of-a-kind region has the government enacted these rules, which means that certain previously made responsibilities will not be honoured. As a result, the UK government considers that failing to satisfy its responsibilities under the Withdrawal Agreement and/or Protocol is legal under international law. Finally, Article 16 of the Protocol grants the UK the right to protect against serious economic, social, or environmental challenges that may restrict trade - that is yet to be triggered. What did the EU say? The EU insists on the Protocol's non-negotiability. The EU thinks lengthy talks may muddle Northern Ireland's legal position. Instead, the EU wants the UK to honour the legally binding Withdrawal and Trade agreement. After hours of line-by-line negotiations, this was the only way to protect Northern Ireland's peace process while addressing Brexit and the UK government's form of Brexit. Rather than changing the legal text, the EU wants to discuss the potential flexibilities with the UK quickly. Concerns The protocol allows Northern Ireland enterprises to sell in the EU Single Market - a key benefit. The UK government's actions threaten this access and opportunity for businesses in Northern Ireland. Therefore, the EU is concerned about the UK government's plan to block vital Protocol elements. One-sided behaviours damage trust. Next Steps for the EU Commission First, the EU Commission will examine the proposed legislation from the United Kingdom. Then it will determine whether to continue the March 2021 infringement actions against the UK (legal action was suspended in September 2021 to explore remedies, but the UK's behaviour currently violates this spirit). The Commission will also examine further measures to protect the EU Single Market from the risks that Protocol violations pose to EU businesses and EU people' health and safety. The EU will soon provide further details regarding our approach to flexible Protocol implementation, which is based on long-term Protocol solutions. This will demonstrate that there are solutions to Northern Ireland's problems within the Protocol The EU further clarified that any amendments to the TCA could not be addressed until the Withdrawal Agreement was implemented. The UK move undermines the trust required for the EU and the UK to collaborate on the TCA. EU Press release Conclusion So the show must go on. The political bickering goes on. Right now, there are no activities that firms can take. You must, however, exercise caution. This is an opportunity for trade groups to shine by collaborating with governments to establish appropriate and friendly solutions that enable firms to deal with one another without friction in all directions. Without a question, the UK's planned simplifications are appealing. Furthermore, Red Lane and Green Lane are ideas that are readily understood by enterprises. It is critical to reduce red tape and bureaucracy. It is also unclear to the typical company owner why enterprises in Northern Ireland should be handled differently from those in the United Kingdom. And, absolutely, if there are advantages in the United Kingdom that firms in Northern Ireland are not receiving, then surely, that cannot be acceptable. So, what do we make of it at Customs Manager Ltd? Well, just as we have requested the UK to carefully explore and collaborate with EU initiatives, we need the EU to step up and reconsider these new UK ideas as well. If it can be guaranteed that no damage is done to the EU Single Market and that red tape may be cut if you are a certified trustworthy trader, such as an AEO-accredited firm, then perhaps the Green/Red channel notion isn't that bad? EU, could we please take this concept into consideration? How We Can help For online support, join our educational live webinars, subscribe to insightful short Twitter updates and informative YouTube videos, and stop by at our expert blog page, updated weekly: https://www.customsmanager.org/customs-global-trade-blog Join us on Linked In, too: www.linkedin.com/company/customs-manager-ltd We also offer a resources hub that covers a lot of topics, videocasts and step by steps guidance: https://www.customsmanager.org/ -> Resources There are regular customs and global trade update sessions to discuss what is coming up: https://www.customsmanager.org/customs-and-global-trade-update Join our wide range of LIVE or online training courses on the customs and global trade topics that matter to you Subscribe to our free newsletter to never miss an important update on our social media channels and expert blogs and get a round-up on all the important changes, law updates and guidance modifications for the EU and the UK). You can also call our helpline on 079146450183. The first call is free, after this, we charge a moderate fee to get instant expert support. You can access it at https://www.customsmanager.org/expert-helpline-blog-training-exclusive-briefings If you know of a business who would also find e-mails or customs and global trade blog entries helpful, please forward it on, or suggest they register to receive them directly to their inbox register to get these updates directly to their inbox. About Customs Manager Ltd. Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world. Need to stay up-to-date with changing customs and global trade rules? We monitor legislation so our clients don't have to. Learn about all changes in our fresh expert blog, join exclusive briefings and ask any questions 24/7 through to the VIP hotline. Or sign up to our no-charge, insightful newsletter. Entrust us with your training needs and help us to upskill you and your teams in English, German, French and Spanish. We offer public and private live, in-house and on-demand (study from anywhere and anytime) courses. To complete our support for globally trading businesses, we are also a UK Customs Broker. We act as a customs clearance agent on behalf of many EU and UK businesses, assisting with customs documentation and all other formalities to ensure the customs clearance of our goods. Whether you’re seeking a long-term partner to look after your customs clearance or require support for a one-off shipment, please don’t hesitate to get in touch to discuss your requirements.

The EU reverse-charge mechanism which allows foreign companies not to charge VAT is maintained until 2026 Reverse-charge VAT is a major challenge for businesses of all sizes, but especially startups that are just launching. We've put together this blog post to help you understand what it's about and to check that you follow the correct processes and procedures. Background Reverse-charge VAT impacts businesses across the EU. The measure was introduced as a rapid response to widespread fraud, allowing foreign companies not to charge VAT on their sales if below 10 million euros (or 5 million euros for some countries). This means that EU companies are obliged to self-assess and pay VAT when they purchase services (e.g. consultancy) or products (e.g. e-books) from non-EU businesses, instead of having them charged differently at source by those non-EU businesses, like is the case for domestic sales. This has been a radical change from how VAT has historically been implemented within the EU, where businesses are most often used to charging their clients for VAT and paying it to their local tax authority afterwards. No change to VAT Reverse Charge The EU decided to maintain the VAT reverse-charge mechanism, which allows foreign companies not to charge VAT on services or digital products sold in the EU, until 2026. This remains a temporary measure and will only be available until a long-term solution for cross border trade has been found. A temporary solution to fight VAT fraud The measure was initially introduced as a temporary solution to fight VAT fraud. To date, it remains temporary, however, and will be phased out once the agreed EU-wide VAT system has been fully implemented in all member states. What is VAT fraud? VAT fraud occurs when a company, often an e-commerce site or small business shop, charges VAT but fails to properly submit it to the government. This may happen if they don't have the proper documentation or if they choose not to report it for any reason (such as avoiding taxes). What is VAT Reverse Charge? Reverse charge VAT occurs when a business sells products on behalf of another EU-based firm without charging them for it—for example, if you're selling items from Amazon's warehouse in France for them in exchange for a commission. In this case, Amazon would be responsible for paying French tax on its sales through your marketplace account instead of yours; however, most reverse charge agreements specify that sellers need their own VIES number before becoming eligible for reverse charge registration with DGIACFA (the French Customs Authority).. What is the future of VAT in the EU? A consensus among EU states could be reached in 2021 by digitalizing the VAT system and concluding discussions on the Digital Services Tax. The VAT system will be digitalized. This could lead to an agreement among all EU Member States on a common reverse-charge mechanism until 2026. The existing reverse-charge mechanism will remain in place until then. Conclusion In conclusion, VAT reverse-charge impacts many businesses (both in the EU and non-EU) when providing services to customers across the EU. It was introduced as a temporary measure to fight widespread VAT fraud and is only applied to businesses above certain thresholds. The European Commission has proposed it should remain in place until 2026, when a more permanent solution can be implemented within the Union, but some member states disagree with this timeline. Fortunately, there are also ongoing efforts to digitalize the VAT system and conclude discussions on how to levy tech giants that operate entirely online. These moves could reduce or eliminate the need for reverse-charge altogether. Businesses have faced a steep learning curve when it comes to understanding the reverse-charge mechanism, and its complexities have led to mistakes. It’s important to keep in mind that the system is designed to help businesses comply with local VAT rules, not simply collect revenue. Legal Text The text adopted by the European Parliament on 3 May 2022: “Common system of value added tax (VAT): extension of the period of application of the optional reverse charge mechanism to the supply of certain goods and services presenting a risk of fraud and the rapid reaction mechanism against VAT fraud”. The EU has now finally decided to maintain the reverse-charge mechanism on certain risky products until December 31, 2026. COUNCIL DIRECTIVE (EU) 2022/890 of 3 June 2022 amending Directive 2006/112/EC as regards the extension of the period of application of the optional reverse-charge mechanism to the supply of certain goods and certain services presenting a risk of fraud and the rapid reaction mechanism against VAT fraud published in OJ L 155/1 of 8.6.2022.

Our Import Guide walks you through 15 essential questions to help you get your goods into any country in the world, effectively, efficiently and, of course, compliantly. You may have to follow these steps if you're moving goods permanently to your country from a different country, which your country has not agreed on a customs union. What you need to do may be different if you are: moving goods between countries that formed a customs union getting goods through the post bringing goods in your luggage for personal use bringing goods in your luggage, car, or van to use in your business or sell bringing in goods temporarily bringing goods back into your country after they were rejected at another country’s border moving to your country with your belongings. Our 15 Import Questions for expedited importing Question 1: Is this process right for you? Question 2: How shall I get ready to import? Question 3: How can I check the business sending you the good can be exported? Question 4: Who will make customs declarations? Question 5: Who will transport the goods? Question 6: What are the commodity codes for my goods Question 7: How can I work out the value of my goods? Question 8: How can I reduce or delay customs duty? Question 9: How can I check if I need a licence or certificate for my goods? Question 10: Have I checked the labelling, marking and marketing rules? Question 11: How do I get your goods through customs Question 12: Can I claim a VAT refund and if so how? Question 13: If you paid the wrong amount of duty or rejected the goods – what shall I do? Question 14: How long do I need to keep invoices and records? Question 15: Who do I reach out to if things so wrong or I have a further question?

The EU decided that the sixth package of sanctions would include crude oil and petroleum products sent by Russia to EU Member States. We break it down + law A temporary exception will be given for crude oil transported through a pipeline. In the event of a sudden disruption in supply, emergency actions will be implemented to guarantee supply security. "The European Council was able to agree on the sixth package of sanctions that would allow us to prohibit Russian oil with a temporary exemption for oil flowing via pipeline," said Charles Michel, President of the European Council. “This implies that 75 percent of Russian oil is directly impacted. That implies that by the end of the year, this legislation will have covered roughly 90 percent of Russian oil shipped into Europe”. The summary The agreed-upon package contains a number of measures aimed at effectively impeding Russia's ability to continue its actions. Oil The EU resolved to ban the purchase, import, or transfer of Russian crude oil and certain petroleum products into the EU. The withdrawal of Russian oil will take six months for crude oil and eight months for other refined petroleum products. A temporary exemption is planned for crude oil pipeline imports into EU member states who, owing to their geographical location, are reliant on Russian supply and have no viable alternative choices. Furthermore, Bulgaria and Croatia will benefit from temporary exemptions on imports of Russian seaborne crude oil and vacuum gas oil, respectively. Additional Russian and Belarussian banks have been de-SWIFTed. The EU is expanding the existing prohibition on the provision of specialised financial messaging services (SWIFT) to three more Russian credit institutions - Russia's largest bank Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank - as well as the Belarusian Bank For Development And Reconstruction. Broadcasting The EU has suspended three additional Russian state-owned outlets' broadcasting operations in the EU: Rossiya RTR/RTR Planeta, Rossiya 24 / Russia 24 and TV Centre International. The Russian government has utilised these mechanisms to manipulate information and spread falsehoods regarding the invasion of Ukraine, including propaganda, in order to destabilise Russia's neighbours as well as the EU and its member states. In accordance with the Charter of Fundamental Rights, these regulations will not preclude those media outlets and their employees from engaging in activities other than broadcasting in the EU, such as research and interviews. Export controls The EU is increasing the list of individuals and companies subject to export restrictions on dual-use products and technology. Russian and Belarussian entities have been added to the list. Furthermore, the EU will broaden the list of items and technologies that may help to Russia's defence and security sector's technical advancement. This will comprise 80 compounds capable of being utilised to create chemical weapons. Services for consulting Accounting, public relations, and consulting services will be prohibited by the EU. Listings of individuals Furthermore, the Council decided to sanction additional individuals and entities, including those responsible for atrocities committed by Russian troops in Bucha and Mariupol, war supporters, leading business people and family members of listed oligarchs and Kremlin officials, as well as defence and financial organisations. The Rules On June 3, 2022, the Council passed Decision (CFSP) 2022/884, which added more restrictions in a number of areas. It adds three more Russian credit institutions to the list of those who can't offer specialised financial messaging services. It also adds more people to the list of those with ties to Russia's defence and industrial base who have to follow stricter export rules for dual-use goods and technology, as well as goods and technology that could help improve Russia's defence and security technology. The EU has added more items to its list of controlled items that could help Russia improve its military and technology or build up its defence and security sector. The EU also suspends Russian media broadcasting licences because Russia is manipulating and distorting news and media to destabilise its neighbours and the EU. There are bans on buying, importing, or transferring Russian crude oil and various petroleum products into the Member States, as well as on ensuring and re-insuring the marine movement of these goods to third nations. Transitions are necessary. Due to the location of the certain Member States, which renders them dependent on pipeline crude oil from Russia and leaves them with no alternative short-term supply choices, import sanctions on Russian crude oil do not apply to pipeline imports into these Member States until the Council determines otherwise. Member states should identify alternate oil sources to seize Russia's crude oil pipeline imports as quickly as possible. We dedicate a special section on our expert blog to Russian Sanctions, where you can read explainer articles, videos and more, for example: EU Sanctions On Russia: What are the top 5 questions that companies are asking? + Answers & BONUS EU - Russia RPS: Top Ten of Groups of Individuals Sanctions that firms need to know EU-Russia Sanctions: Can I Still Get Paid? Receiving payment may be more difficult than you think. Here are some things to think about before signing a contract. EU-Russia Sanctions: What are the penalties for air, road, and sea transportation? Trade in EU Goods with Russia: What do company owners need to know? Selling Around Sanctions: Know Who You Are Dealing With How we can help We help with understanding sanctions. We analyse the impact on your business and show you ways to comply with sanctions. We offer extensive training on sanctions, and we also provide restricted party screening solutions for your business. Schedule a call today on www.customsmanager.org Sources Russia: Main 6th sanctions package https://www.consilium.europa.eu/en/press/press-releases/2022/06/03/russia-s-aggression-against-ukraine-eu-adopts-sixth-package-of-sanctions/ https://www.consilium.europa.eu/en/press/press-releases/2022/05/31/remarks-by-president-charles-michel-following-the-first-day-of-the-special-meeting-of-the-european-council-30-may-2022/ https://www.consilium.europa.eu/en/press/press-releases/2022/05/31/european-council-conclusions-on-ukraine-30-may-2022/ https://www.consilium.europa.eu/en/meetings/european-council/2022/05/30-31/

There are numerous way you can pay HMRC from Cash Accounts to Duty Deferment and more. Discover them here and contact us to help you select the right ones. Cash Accounts The Customs Declaration Service operates on a cash basis. These take the place of the CHIEF's Flexible Accounting System (FAS). All companies who sign up for the Customs Declaration Service are issued a cash account instantly. A trader may deposit money into their cash account and then use that money to pay for declarations. A trader may also authorise an agent to pay for declarations on their behalf using their cash account. Ask us how you can use the cash account for Customs Declaration Service declarations. Accounts for duty deferment A duty deferment account enables you to make one payment each month for any imports, rather than paying each time you import products, which helps you manage your cashflow. Whether you utilise a third party to make declarations on your behalf, such as a freight forwarder, customs agent, or express operator, you should check with them to see if you need your own duty deferment account or if you may use theirs. Your intermediary will be able to advise you on the best route to take in this situation. Ask us to advise you on how you can open a duty deferment account. Top-up payments If you have a Customs Declaration Service duty deferral account and you have reached your monthly deferment limit, you may make a payment to boost your available amount. When making a duty deferral top-up payment, your payment reference will be 'CDSD' followed by your duty deferment number. Ask us how to replenish your duty deferral account with the Customs Declaration Service. Immediate payments A business has the option of paying when filing an import declaration. A trader may utilise the following methods to make a payment on the same or next day: Banking over the phone or online (Faster Payment) CHAPS (Clearing House Automated Payment System) Using the online payment facility, you may pay with a debit card or a corporate credit card. A trader may also pay via BACs (Bankers Automated Clearing Services), which will be processed in three working days, or by check. When making an urgent payment, your payment reference will be 'CDSI' followed by the particular number provided for you by Customs Declaration Service. Learn more about how to pay for goods reported using the Customs Declaration Service. Accounts with a guarantee (including individual guarantees) A customs guarantee is an agreement to settle customs tax, import VAT, and excise arrears. When duty is not paid at the time of import or export, it is often demanded. When the amount of import tariffs is uncertain or contested, a guarantee may be required. A financial institution must support guarantees. Instead of giving separate individual guarantees, a general guarantee account enables you to give many individual guarantees from the same account. It also permits you to continue importing items into the UK while paying the agreed-upon sum later. Download HMRC's Guide

Download official guidance from HMRC on the move to CDS, CDS Trader's Checklist, and Import Guide using CDS, Export Guide using CDS, Movement Reference Number Guide using CDS, CDS Finance Options. CDS Trader's Checklist Import Guide using CDS Export Guide using CDS Movement Reference Number Guide using CDS CDS Finance Options

Every customs manager should know how to complete a customs entry. We explain how. The Single Administrative Document (SAD) is a customs declaration form used in the United Kingdom, the European Union, Switzerland, Norway, Iceland, Turkey, the Republic of North Macedonia, and Serbia. It is constructed of a collection of eight duplicates, each with a separate purpose, in paper form. It is also used in the United Kingdom until 2022. It is gradually being replaced by the UCC Data set which replaces the paper copy with electronic data elements. Download the C88 Using a single document saves administrative effort while increasing standards and harmonisation of trade data. Where is the Single Administrative Document used? The single administrative document is used for international commerce and the transportation of foreign products inside a country/jurisdiction. Since the 1987 Convention on the Simplification of Formalities in Goods Trade, it has also applied to the territories of EFTA countries (Switzerland, Norway, and Iceland), Turkey (since 1 December 2012), and the Republic of North Macedonia (since 1 July 2015), as well as trade between these countries and the EU. Procedures covered The document covers the placement of any goods under any customs procedure such as export, free circulation, transit (where the New Computerised Transit System was not used), warehouses, temporary admission, inward and outward processing, etc. It has more than 50 boxes, and they need to be completed on a step by step basis. What do I need to complete the SAD? This will depend very much on what you want to do, the type of movement. The option are: A: Export/Dispatch B: Customs warehousing procedure in order to obtain payment of special export refunds prior to exportation or manufacturing under customs supervision and under customs control prior to exportation and payment of export refunds C: Re-export after a special procedure other than the customs warehousing procedure D: Re-export after customs warehousing E: Outward processing F: Transit G: Community status of Union goods H: Release for free circulation I: Placing of goods inward processing or temporary importation J: Placing under a customs warehouses. When is information Mandatory, when not? There are only three options: A: Mandatory: Particulars required by every Member State (A = Absolutely necessary) B: Optional for the Member States: Particulars which the Member States may decide to waive (B = Both possible) C: Optional for operators: Particulars which operators may decide to supply but which cannot be demanded by the Member States (C = Choice) The SAD Matrix The EU Commission has now published a simple Matrix that explains when a box needs to be completed and when not. There are also notes to read for completion of the SAD In this combination, it is easy to understand when a data element is required and when not. 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Customs classification can be challenging. Try your luck with our guided classification challenge and compare your results with the official solution Every once in a while, the EU issues customs classification decisions. Just like on this product. We have based our analysis on the analysis of the EU. So, when we present you with the solution, you know that we are totally aligned with the EU decision-makers and EU Customs authorities. This is why they are helpful for the trade community in creating a best practice classification argumentation and checking if you had reached the same commodity code. This is why we run these classification quizzes and talk our members through difficult cases. Together we can crack customs classification. OK, so you are ready to try your skills as a customs classifier of this shower-bath in the form of a flat tray? Great, before we start, let's remind ourselves of some top tips. Solid customs classification advice. Thank you! – Jane Williams, Customs Manager Ltd, Logistics company Customs classification is a journey of discovery. Start with answering these fundamental questions: What is the product that I am looking at? What are the necessary characteristics that I need to know about? What is the product used for? What is the commercial description vs. what it actually is? What about some technical features, length, thickness etc? We, as customs consultants EU and UK, have found in our years of classification experience that starting with the right description of the product has really helped with the classification of the product. Step 1: Nail the Description So we know that the EU has classified a shower-bath. What are the characteristics? It has the form of a flat tray, made out of a mixture of minerals and plastics and a white outer plastic coating. The product is by weight composed of the following: 65 % calcium carbonate; 28 % polyester resin; 5 % silicon dioxide; 2 % polyester ‘gel-coat’ (outer surface). The mineral components (calcium carbonate and silicon dioxide) are made out of marble chips, quartz or finely crushed granite. The production process involves first mixing the mineral component with plastic material (polyester resin). That mixture is then poured into a mould, which is lined with the polyester ‘gel-coat’, and the polyester resin is finally cured. Step 2: Build your argument, grounded in law Time to make our case Start with a section. Which one does this product fall into? Look at the GIR/GRIs and think about which ones could apply in this case? 1 & 6 is a given, but what about 3? Get your support tools ready. Have you got the Section & Chapter notes handy? Have you got access to the national explanatory notes of your country? What about the WCO classification explanatory notes? What about BTI? Case Law? Next, consider GIR 1 and find possible competing headings and try to unravel them with careful consideration of the section and heading notes. Use all the tools, including exclusions and exceptions, to support your case. Consider any other GIR rule you think is appropriate here Look at specific rules of your national tariff, like additional notes and subheading rules for numberings past 6 digits. Draft and fine-tune your justification and conclude by determining the article. How should a justification look, sound and feel There is no fixed rule, but it should clearly answer the question: Why is this code correct and give reasons backed up by the rules of classification. The geekier the better. Here is an example: Classification is determined by general rules X and X for the interpretation of the Harmonised System of Classification as published by the WCO, version of year 20XX, and (insert name of national tariff). We considered the following Notes and wordings of HS/commodity codes: note XX and xx to Section XX Wording of HS codes XXXX, XXXX National Tariff commodity codes: XXXX XXXX The articles are produced in/by .... (see note XX to Section XX). Taking into account their xxx character the articles are to be considered as xxx. In addition, note xxx to Section xxx classifies Product A like Product B in that section. Classification under heading XXXX is excluded, because (see also the Harmonized System Explanatory Note to heading XXXX (X) and the Explanatory note to the National Tariff XXXX ). Consequently, the articles are to be classified under National Code XXXX XX XXas a xxx Now it is up to you :-) Can you try to find the 6-digit code for the WCO and the eight-digit code for the EU (or your country?) YOUR ANSWER IS __ __ __ __ __ __ __ __ Solution Our answer is published in a subsequent post, with detailed explanations. Access it here Help is here If you get stuck, please reach out to us in the chat. We are always happy to assist you. Good luck! While you are here, check out these resources: An online library packed with classification tips, tricks, videos and quizzes. On-Demand Classification Training (study anywhere and anytime) All classification tools, per chapter in one place LIVE Customs classification training

Customs classification can be challenging. So here is the solution to our challenge. What was the product CN Code you came up with? To recall, apart from this picture, this is what we know about the product: It has the form of a flat tray, made out of a mixture of minerals and plastics and a white outer plastic coating. The product is by weight composed of the following: 65 % calcium carbonate; 28 % polyester resin; 5 % silicon dioxide; 2 % polyester ‘gel-coat’ (outer surface). The mineral components (calcium carbonate and silicon dioxide) are made out of marble chips, quartz or finely crushed granite. The production process involves first mixing the mineral component with plastic material (polyester resin). That mixture is then poured into a mould, which is lined with the polyester ‘gel-coat’, and the polyester resin is finally cured. This is our justification. Did you get to the same results? As you know, there is no fixed rule, but any justification should clearly answer the question: Why is this code correct and give reasons backed up by the rules of classification? If questioned by the authorities, what argument are you going to give? Here is what we suggest: For the interpretation of the EU Combined Nomenclature and the phrasing of CN codes 3922 and 3922 10 00, we have applied the general interpretative rules 1, 3 (b), and 6. The product is not a natural stone replica, since the plastic covering covers the useable surface. As a result, it cannot be classified as a piece of artificial stone under topic 6810. (see also the Harmonized System Explanatory Notes to heading 6810 , third paragraph). In terms of product utilisation, the plastic material is the most significant component. It provides the shower tray with its important characteristics of tensile strength, chemical resistance, and water impermeability. The minerals in the mix act as a filler. As a result, the product will be classed as a shower-bath of plastics under CN code 3922 10 00. Help is here If you get stuck, please reach out to us in the chat. We are always happy to assist you. Good luck! Review the EU Decision here: While you are here, check out these resources: An online library packed with classification tips, tricks, videos and quizzes. On-Demand Classification Training (study anywhere and anytime) All classification tools, per chapter in one place LIVE Customs classification training

Customs classification can be challenging. Try your luck with our guided classification challenge and compare your results with the official solution OK, so you are ready to try your skills as a customs classifier of these hairbands. Great, before we start, let's remind us of some top tips. Solid customs classification advice. Thank you! – Jane Williams, Customs Manager Ltd, Logistics company Customs classification is a journey of discovery. Start with answering these fundamental questions: What is the product that I am looking at? What are the necessary characteristics that I need to know about? What is the product used for? What is the commercial description vs. what it actually is? What about some technical features, length, thickness etc? We, as customs consultants EU and UK, have found in our years of classification experience that starting with the right description of the product has really helped with the classification of the product. Step 1: Nail the Description Here is what we know about this product when looking at the picture and measuring it. It is a articles consisting of a tubular knitted, elasticated fabric It has synthetic fibres combined with a rubber thread It has the of loops with a diameter of approximately 4,5 cm and a width of approximately 2 cm (when unrolled). The articles are knitted in a tubular form and cut at a defined (pre-programmed) width (2 cm). Due to the rubber thread contained in the elasticated fabric, the edges of the articles roll-up, which gives the articles the form of hairbands, ready for use. See images. Step 2: Build your argument, grounded in law Time to make our case Start with a section. Which one does this product fall into? Look at the GIR/GRIs and think about which ones could apply in this case? 1 & 6 is a given, but what about 3? Get your support tools ready. Have you got the Section & Chapter notes handy? Have you got access to the national explanatory notes of your country? What about the WCO classification explanatory notes? What about BTI? Case Law? Next, consider GIR 1 and find possible competing headings and try to unravel them with careful consideration of the section and heading notes. Use all the tools, including exclusions and exceptions, to support your case. Consider any other GIR rule you think is appropriate here Look at specific rules of your national tariff, like additional notes and subheading rules for numberings past 6 digits. Draft and fine-tune your justification and conclude by determining the article. How should a justification look, sound and feel There is no fixed rule, but it should clearly answer the question: Why is this code correct and give reasons backed up by the rules of classification. The more geeky the better. Here is an example: Classification is determined by general rules X and X for the interpretation of the Harmonised System of Classification as published by the WCO, version of year 20XX, and (insert name of national tariff). We considered the following Notes and wordings of HS/commodity codes: note XX and xx to Section XX Wording of HS codes XXXX, XXXX National Tariff commodity codes: XXXX XXXX The articles are produced in/by .... (see note XX to Section XX). Taking into account their xxx character the articles are to be considered as xxx. In addition, note xxx to Section xxx classifies Product A like Product B in that section. Classification under heading XXXX is excluded, because (see also the Harmonized System Explanatory Note to heading XXXX (X) and the Explanatory note to the National Tariff XXXX ). Consequently, the articles are to be classified under National Code XXXX XX XXas a xxx Now it is up to you :-) Can you try to find the 6-digit code for the WCO and the eight-digit code for your country? The answer will be published in a subsequent post with detailed explanations, so please look out for this. Help is here If you get stuck, please reach out to us in the chat. We are always happy to assist you. Good luck! While you are here, check out these resources: An online library packed with classification tips, tricks, videos and quizzes. On-Demand Classification Training (study anywhere and anytime) All classification tools, per chapter in one place LIVE Customs classification training