UK-EU Exports

 

FROM JANUARY 2021:

 

Export declarations are required for UK goods to enter the EU

EXPORT DECLARATIONS
  • UK businesses sending goods to the EU must complete an UK export declaration using the National Export System.
  • UK businesses must also complete an EU import customs declaration for goods exported from the UK to the EU.

What do I need to complete a UK Export Customs Declaration?

  • UK EROI number (starting with GB)
  • The Commodity Code of the goods
  • The value of goods
  • Access to S&S (Safety & Security) GB system is needed to submit Exit Summary Declarations (directly or through an intermediary i.e customs agent).
    • Traders using CHIEF must obtain a CHIEF badge.
  • A license to transport the goods (if needed) Check the trade tariff to see whether you need a license.
  • An EU EROI number (if you are making customs declarations in an EU member state e.g S&S declarations into the EU Import Control System (ICS).

From January 2021 to end of June 2021:

  • If your goods are traveling between locations that do not have existing customs control systems, such as RoRo ports and non-inventory linked locations, you must submit an arrived declaration before the goods leave the trader’s premises 

From July 2021: 

  • You can only submit an arrived declaration if your goods are moving between specified locations. Once your declaration is submitted, you will either receive:
    • ‘Permission to Progress’ (P2P) meaning you can travel to the port specified on your export declaration, or
    • A specific routing to facilitate physical checks on your goods.
  • The majority of export declarations will change to being pre-lodged. 
  • Hauliers must be able to prove that this declaration has been made with valid evidence.  

Hauliers or declarant may require a physical check on their goods and will be told to move to a certain location that can facilitate this.  

Locations that use the Goods Vehicle Movement Service (GVMS), such as non-inventory linked locations – will require hauliers to use GVMS to connect their export declaration references into one single Goods Movement Reference (GMR). 

  • The GMR must be presented by the driver at the port or place of exit.  
  • GVMS will then ‘arrive’ and ‘depart’ the declarations automatically. 
SAFETY & SECURITY DECLARATIONS

If your goods will be exported from the UK-EU via a roll on roll off location to the EU, you must complete a combined safety and security and customs declaration prior to the goods arriving at the departure port.

Complete this declaration using the National Export System.

EU safety and security declarations must be submitted 1 hour before arrival in the EU (if going by Eurotunnel) or 2 hours if going by Dover. 

  • It is the haulier’s responsibility to have a safety and security declaration when entering the EU.
TRANSIT MOVEMENTS

Traders can move goods from the UK customs territory under the Common Transit Convention (CTC).

    • The CTC means that some customs procedures can be completed away from the border.
    • Traders must only submit a customs declaration and pay their import duties once the goods arrive at their final destination.
    • Safety and security requirements must still be met.

How do I export goods from the UK- EU under transit? 

  • Submit an export declaration and a transit declaration.
  • A transit declaration requires:
    • Details of the planned journey for the goods,
    • Guarantee Reference Number or details of the guarantee waiver and the local reference number.
    • The master reference number from the export declaration.
    • Safety & Security declaration (not always required)
  • Register as an authorised consignor (allowing transit movements to begin at the exporter’s own premises).
  • Once the export and transit declarations are approved, a Transit Accompanying Document will be given to the trader, which must always accompany the goods while under transit.
  • Familiarise yourself with the office of transit process for the relevant customs territory they are entering once they leave the UK.
  • The use of GVMS for transit processes will not be needed, if the goods are moving through locations without existing systems.
    • If that location ever chooses to use GVMS, traders must then submit export declarations to GVMS.
  • Apply to Customs Comprehensive Guarantee (CCG) as you must provide a guarantee to cover customs duties and import VAT.
  • Access the ‘New Computerised Transit System (NCTS)’ to lodge a transit declaration.

 

SMART FREIGHT / CHECK AN HGV IS READY TO CROSS THE BORDER SYSTEM

From January 2021 the EU will introduce full import controls on goods moving from UK to the EU. 

Drivers transporting goods from the UK into the EU, must carry the relevant evidence to prove to border officials that the goods meet the EU import requirements, including:  

  • Customs or transit declarations  
  • Other commodity-specific approvals such as Export Health Certificates. 

These documents may be checked by border officials either at UK departure points or at the EU arrival ports.  Without correct documentation, drivers will be denied from departing the UK or entering the EU, face fines or sent back to their departure point. 

What is the “Check an HGV is Ready to Cross the Border” service?  

  • The system was developed by the UK government for Roll off (RoRo) freight leaving the UK for the EU.  
  • It ensures hauliers and HGV (Heavy Goods Vehicles) drivers carry the correct customs and import/ export documentation for EU import controls. 
  • The service aims to reduce delay at the border ports and allow only those with the correct documentation to travel to the port.  

What will the service ask for?  

 Details of the HGV transporting the goods to the EU (submitted when goods are being loaded or prior to the journey commencing), including: 

  • Vehicle Registration Number (VRN) 
  • Destination,  
  • Expected travel date,  
  • Consignment(s) details,  
  • Self-declarations to confirm the appropriate customs and import/export documentation required are in place and carried with the vehicle 

 Customs documentation, including:  

  • Movement Reference Number (MRN) for the EU customs import declaration  
  • Transit Accompanying Document 
  • ATA Carnet 
  • TIR Carnet 

 Correct documentation for certain goods, including: 

  • Export Health Certificates 
  • Phytosanitary Certificates 
  • Catch Certificates 
  • Documentation for restricted goods including CITES goods.

If these documentations are complete and approved by the service, the vehicle may travel to the port. 

EU TARIFFS AND RULES OF ORIGIN

UK businesses exporting certain goods can benefit from zero tariffs and zero quotas on exports to the EU, provided they meet the Rules of Origin (RoO), which determine the nationality of a good.

  • Typically the importer pays the tariff, but both the importer and exporter must provide evidence that the goods meet the rules of origin in order to benefit from the preferential tariffs.

How can I prove that I meet Rules of Origin? 

  • A statement on origin can be an invoice or commercial document which describes the product in detail, to enable its origin to be identified. This invoice or document is completed by the exporter of the originating product.

OR

  • Use ‘importer’s knowledge’, where the importer can declare that they are content that the goods meet the rules of origin rules based on the the proof they have collected. No statement on origin is required by the exporter here.

What if I cannot meet the Rules of Origin requirements? 

  • You must not prove the origin of the goods.
  • The EU’s external tariff and payment of tariffs and duties will apply to these goods.
  • The EU’s process for imports must be followed instead.
EU EROI NUMBER

A UK exporter or haulier that is not established in the EU customs will require an EU EORI in the following situations

  • To submit a customs declaration in the EU customs territory.
  • To complete an EU Entry Summary declaration into the Import Control System (ICS) of the relevant Member State.
  • To submit a temporary storage declaration in the customs territory of the EU
  • When acting as the carrier of goods being transporting by sea, inland waterway or air
  • When acting as the carrier connected to the customs system and intents to receive notifications from submitting or changing an Entry Summary Declaration. 

UK businesses can apply for an EU EORI number from various customs authorities across the EU. 

EU IMPORT REQUIREMENTS

When UK hauliers arrive at the EU border they must present the following documents:

  • Entry Summary Declarations (ENS) – Accompanied Freight
    • This declaration is often referred to as the Safety and Security Declaration.
    • The haulier is responsible for submitting this declaration into the Import Control System (ICS) of the member state at hand.
  • Entry Summary Declarations (ENS) – Unaccompanied Freight
    • The ferry operator must submit the ENS when they enter the EU port.
    • You must apply for an EU EORI number to submit the ENS declaration into the ICS system.
  • Customs Declarations
    • A Movement Reference Number (MRN) is required to complete an EU customs import declaration or the transit (CTC) movement.
    • The haulier will need to show the MRN at both the GB and the EU border. This is displayed as a number as part of a barcode.
  • Register for EU Port Systems (Port Community Systems – PCS)
    • Traders and transporters must be registered for these systems to prevent disruption to ‘UK check-in’ and arrival at the EU ports.

Other Requirements: 

  • Drivers should have a hard copy of certificates or licences needed to import goods into the EU, such as a signed Export Health Certificate.
  • There may be additional Covid-19 entry requirements to permit UK hauliers entering an EU member state, i.e to enter France, a valid COVID-19 test is needed from the past 72 hours.
GUIDE FOR EU IMPORTERS

 

  • EU importers must be registered in the EU
    • EU importers of UK exports must have an EU EORI number issued by a customs authority in a Member State.
  • Trading Terms and Conditions with the EU importer
    • The UK exporter and EU importer must clarify who is held accountable for tariffs, duties and border formalities – In addition, who will bear the financial responsibility of temporary storage costs or customs fines.
    • If the UK exporter wants to clear goods in the EU they need a fiscal representative (representative of foreign traders) to handle administrative procedures such as VAT.
  • Certificates and Licenses
    • If imported goods are controlled, restricted or prohibited they will require additional certificates or licenses to be imported into the EU.
    • Traders must notify EU Authorities in advance about the arrival of these goods and these licences or certificates must be presented and accompany the goods.
  • EU Border Control Posts (BCP)
    • Check with the Commission guidance on BCPs for all the requirements including how much notice needs to be given.
    • Ensure the transporter or logistics company will move the goods through an EU port of entry that will accept the imported goods (or through a BCP if required).
    • Check that the EU importer has informed the BCP that the goods will be arriving (through the TRACES-NT system). TRACES is the European Commission’s ‘Trade Control and Expert System’ of managing sanitary and phytosanitary certifications needed to import animals, animal products, plants etc into the EU.
    • The transporter or logistics company is required to present the relevant certificates and licences at the border if asked.
  • Customs Import Declarations for EU importers:
    • Complete a customs import declaration or enter the transit (CTC) movement into the EU New Computerised Transit System (NCTS).
    • Submit the Entry Summary declaration (ENS) / Safety and Security declaration into the Import Control System (ICS).
    • Once the importer has submitted an import customs declaration into the Member State’s Import Control System (ICS) or for transit movements – into NCTS, one of the following will be produced:
      • A customs declaration (import) document from which A Movement Reference Number (MRN) will be generated.
      • A Transit Accompanying Document (TAD) which will produce an MRN.
      • A combined Transit (Security) Accompanying Document (TSAD) / MRN (may not be available until Member States’ ICS systems are updated).
  • EU Import Taxes 
    • Imports will be taxed once the goods arrive in an EU Member State.
    • The EU importer must have an EU VAT number.  
    • Postponed VAT accounting may be available in some Member States.  
    • If foreign traders cannot register VAT themselves, then a fiscal representative or local entity must do so on behalf of the trader.  
    • Traders without an EU VAT number, whose goods are going to another Member State can use the EU EORI and EU VAT number of an agent or broker to clear the import.  
  • Importing Excise Duty Goods into the EU
    • Import the excise goods into the EU by completing an EU Import Declaration and paying excise and other duties. 
    • Excise duty goods can then be moved within the EU in duty suspension with an e-AD (electronic Administrative Document) by following these steps: 
      • Get your eAD approved in the Member State the goods are being sent from. The excise numbers of the consignor/ consingee will be checked on SEED (A European register of operators).
      • The eAD will be sent from the host Member State to the Member State receiving the goods.
      • The eAD will be sent to the consignee by the destination Member State.
      • A  “report of receipt” will be submitted by the consignee when the excise goods have been received. Any abnormalities of the consignment should be listed such as shortages or surpluses.
      • The “report of receipt” will be sent to the consignor, to release the movement and regain any financial guarantees placed for the excise goods.
    • The Excise Movement and Control System (EMCS) monitors the movement of excise goods under duty suspension electronically. This system is not connected to the EMCS system in the UK.
  • EU importer must notify the UK exporter of potential checks
    • Notify the UK exporter that the consignment (goods and/or documents) may be subject to physical border controls.
    • Each Member States has varying verification and release regimes (read Belgium’s regimes below) 
    • If SPS requirements are not met, the consignment could be denied entry or destroyed.  
    • When the import declaration and the relevant data (including ENS data, pre-notified EHCs etc) are entered into the Member State’s system, customs authorities will evaluate the data to decide whether a physical check of the consignment is necessary.
BELGIAN ROLL-ON-ROLL OFF (RORO) PORTS - ZEEBRUGGE

Port of Zeebrugge:

  • Drivers may only proceed to the Zeebrugge terminal if their customs declarations have been pre-registered on the e-Desk of the RX Seaport system.
  • If no customs declaration is pre-submitted, the goods will be held at the port in temporary storage for a maximum of 90 days until the correct documentation is received. 

What is the RX SeaPort system? 

Steps to Importing into Belgium: 

  • Step 1: The hauliers (or shipping company for unaccompanied freight) should submit the Safety & Security Declaration, also known as an Entry Summary Declaration (ENS) to customs at when you reach the first entry point in the EU. Short-sea travel must submit this 2 hours before arrival.
  • Step 2: The shipping company will submit a temporary storage declaration (an electronic CUSCAR message sent to Belgian Customs), for goods that are being discharged in the EU port based on the data inputed by the haulier when booking.
  • Step 3: The port authority will submit an ‘arrival notification’ of the vessel and the goods to Belgian Customs. This indicates that the goods are now in Temporary Storage (RTO) under customs supervision at the terminal to complete any follow-up declarations or until ‘authorized customs-approved treatment’ such as deferment of import duties, VAT and excise duties are fulfilled.
  • Step 4: The importer or customs representative will submit a follow-up declaration to Belgian customs with information to determine what import duties, VAT and excise duties should be paid. The declarant should also update the customs status in e-Desk.
  • Step 5: Once the importer or the customs representative has notified the terminal operator (via the e-Desk) that a follow-up declaration (or a transit) has been made, the terminal operator can release the goods. The carrier can also check on the RX dashboard to see if the cargo has a green light, signalling they can leave the terminal. 

Read more about the RX Seaport System

BELGIAN ROLL-ON-ROLL OFF (RORO) PORTS - ANTWERP

Port of Antwerp

  • Pre-notification of customs documents in Antwerp are submitted through the C-point system. 
  • Exporters, the forwarders, customs agents or transport companies can submit this pre-notification. 
  • Create an account on the C-point system.

Step 1: The shipping company should submit an ISPS Declaration (International Ship and Port Facility Security Code) electronically to the customs authorities concerned when sending ships to an EU port.

Step 2: 

 

The information provided on this page does not constitute legal advice and is subject to change in line with government rules and laws. While BritCham will endeavour to keep the information on these pages as current as possible, we advise you to seek expert independent legal advice an any matters relevant to your situation