Brexit actions: notes on the IES checklist jobs 1 to 4

In our last post we listed the preparations businesses need to make to be ready for 1st January. If you’ve been using the checklist, you may find these notes useful as background for the first four tasks.
We’ll be following this up with more detail, so look out for further updates.
The highlighted numbers refer to the job number on the checklist

Checklist notes: defining importers, exporters, agents and intermediaries

1. Importer/Exporter of record in UK

From January 1st 2021 an export declaration will be required when goods leave the UK destined for EU27 countries and vice versa.

• The consignor/exporter of record is responsible for any customs debt or liability incurred through a HMRC review
• Goods leaving the UK must be submitted using an EORI number starting with GB
• Goods leaving the EU must be submitted using an EORI number starting with an EU27 country code
• For goods leaving the UK, a P2P (permission to progress) message must be received from CHIEF before the truck will be allowed to enter the port.

2. Importer/Exporter of record in EU

From Jan. 1 an import declaration will be required when goods enter an EU27 country from the UK and vice versa.

• The consignee/importer of record is responsible for the accuracy of the declaration and any resulting customs debt or liability incurred because of inaccuracies
• When entering an EU27 country, the import declaration must be submitted by the Importer of Record (Consignee) using an EU EORI number starting with the EU27 country code like DE, NL, FR etc.
• When entering the UK this must be submitted by the Importer of Record (Consignee) using a UK EORI number starting with GB
• EU27 countries will have systems similar to the UK’s GVMS, to facilitate transit through ports of entry
• Goods will be customs cleared whilst they are making their crossing. This is when a decision is made whether the shipment can be allowed to disembark and go straight to its destination or whether it needs additional checks. Checks will be done by HMRC at a location away from the port.

3 and 4: Customs Intermediaries

It is usual to appoint an agent or customs intermediary to submit customs declarations on your behalf. They will normally act as a direct representative, which leaves the importer of record, ie your business, wholly responsible for the accuracy of the declarations submitted and liable for any resulting customs debt, fines or penalties levied by HMRC.
It is therefore imperative to give clear instructions to your agent, to perform regular checks on key information and to have a documented process to ensure that any errors are corrected on a timely basis.

Our advice is that businesses should prioritise preparations as the new trade environment starts in just a few weeks.