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i2i EU Exit No-Deal Position Statement

This week, the i2i Infinity team began developments aimed at ensuring our users and stakeholders encounter no more friction than is necessary in the event of a no deal exit for the UK from the EU. We have below, given further details of how we are preparing and the implications for your i2i software (e-z Cert, e-z Consign or e-z GTA). You may also wish to read the HMRC Partnership Pack, which contains further details and advice, including industry specific guidance.
 
Under the scenario of a no-deal Brexit it is likely that customs declarations, export documents and in some situations Certificates of Origin will be required for EU trade.  It would be helpful for us to know if you expect to increase your usage of i2i software, and if you have any estimates at this time of your EU trade.  If you use i2i software but don’t already use our available modules to facilitate those services but would like to, then please let us know. If you don’t use i2i software, and have been directed to this post via one of our social media channels, then please have a look around our site, and contact us with any questions, or would like to discuss saving time and money on your import and export operations.  
 
EMCS (excise movements)
A minor update is required to i2i software to be no-deal Brexit compliant. We have received the requirements from HMRC and have assessed the impact as low, both in terms of changes to our software and for our customers. Essentially EMCS will be restricted to UK to UK movements. This will include movements to port locations for export goods where CSE (Customs Supervised Exports) is not used.  As goods to EU countries would be classed as export, a movement would be required i.e. from your warehouse to Dover, for example.
 
Export declarations
This would apply to European trade under a no-deal Brexit. You may wish to consider utilising this module within your i2i software ahead of Brexit, to ensure that your goods can be cleared though customs ahead of despatch.  You can request assess to CHIEF to make NES declarations by completing the PA7 form on gov.uk.
               
For existing NES users:

§  A new ‘Transport Mode Code’ ( 6 – RoRo) will be added to SAD Box 25 (transport mode at the border).

§  New RoRo location codes will be added to SAD Box 30 (location of goods) for new RoRo locations i.e. the Eurotunnel.

§  A new Header Box 44 (Additional Information statement) code will be added to allow the Van or Trailer ID to be declared.

 
HMRC are currently undertaking work to increase the performance of the CHIEF server to increase the yearly capacity from 50m declarations to an estimated 250m.  Many of you will be aware that CDS is being introduced as a replacement for CHIEF, but HMRC are not now going to be in a situation where they are ready to deliver CDS for exports before Brexit on March 29th.  However, please rest assured, that at i2i we are keeping abreast of the CDS developments as they are made, and we will keep you notified of changes to our software and requirements on our customer base as they become apparent.
 
Import declarations
This would apply to European trade under a no-deal Brexit. You may wish to consider utilising this module within your i2i software ahead of Brexit, to ensure that your goods can be cleared though customs upon arrival to the United Kingdom. 
 
For existing IMPORT users:

§  A new ‘Transport Mode Code’ ( 6 – RoRo) will be added to SAD Box 21 & 25 (transport mode at the border).

§  New RoRo location codes will be added to SAD Box 30 (location of goods) for new RoRo locations i.e. the Eurotunnel.

§  A new Header Box 44 (Additional Information statement) code will be added to allow the Van or Trailer ID to be declared.

 
HMRC have also put in place Temporary Simplified Procedures (TSP) to make it easier to Import goods from the EU under a no-deal scenario, using Roll On Roll Off (RoRo) ports such as the Channel Tunnel and Dover.  For further information, and to check if this is applicable to your business, please visit the HMRC page regarding TSP.
 
Export documents
No changes have been advised on any standard UN or Sitpro aligned documents therefore no changes will be made in this area unless advised or requested.  If you don’t currently use export documentation for shipments to the EU, they may be required after Brexit.
 
Certified and preference documents
Under a no-deal Brexit UK companies would no longer have access to preference arrangements, removing access to EUR’s and A TR’s.  We remain in constant contact with the UK Chamber network in this regard, and will ensure the system is updated accordingly.  
 
Capacity Planning (e-z Consign, e-z Cert and e-z GTA On-Demand customers)
We have conducted a review of our server infrastructure and messages services and believe that efficiencies implemented during 2018 provide sufficient capacity to cope with increases volumes of usage under a no-deal Brexit.
 
Government Advice – Imports/Exports
Businesses who only trade with the EU need to act now to ensure that they are prepared from Day 1 of a No Deal EU exit.

§  Apply for an EORI number.

§  Confirm you can complete each data field in a Customs Declaration.

§  Agree responsibilities with your customs agent and logistics provider for each part of the process and update your contracts to reflect this.

§  Identify if your software is suitable for submitting declarations/documents (if you do not use a customs agent).

Government Advice – VAT
In a no-deal scenario, ‘VAT Postponed Accounting’ will be introduced for imports from the EU and Rest of World.

§  Businesses will not need to register to use postponed accounting.  They will simply make the appropriate entry and provide their VAT registration number on their customs declaration.

§  An online monthly statement will show the VAT that has been postponed.  This will provide the evidence to declare/recover import VAT on your VAT return.

§  Postponed accounting won’t be available for postal goods of £135 or less.

§  Postponed accounting won’t be available for non-VAT registered businesses.

 

If you want to understand how postponed accounting will operate please keep abreast of additions to the guidance on GOV.UK
 
HMRC have confirmed that EC Sales Lists would no longer need to be completed in a no deal scenario, but have yet to define the future of Intrastat reporting, although this is also widely expected to no longer be a requirement.
 
Inward Processing Relief
Inward Processing Relief allows you to suspend duty and import VAT on goods that you import into the UK for processing or repair.  You will then pay customs duties and VAT once the end product is in free circulation.  The duties you pay can be based on the value of the goods at import, or on the value of the final product after processing.

In most cases, you will not need a guarantee to be authorised to use Inward Processing Relief.  You can apply to HMRC for Inward Processing Relief here, and you can obtain more information on the solution that we have available in e-z GTA by contacting i2i.
 
Support Grants
UK Government has released funding designed to enable businesses to strengthen their knowledge around customs declarations. Visit www.customsintermediarygrant.co.uk for information.  

We hope you have found this Brexit update useful, and please rest assured that i2i are working hard to ensure that our solutions are going to be ready for whatever Brexit outcome is delivered by the Government on March 29th.

Please continue to visit this blog for further updates, or contact us with any queries you may have.