Transitional Simplified Procedure and controlled goods

17 April 2019

We import goods from the EU, normally on driver accompanied or unaccompanied trailers. We want to register for the Transitional Simplified Procedure (TSP) but we understand that there are limitations on certain types of goods. I have seen mention of “controlled goods” — do you have any more specific information on what controlled goods are? We import goods that could come under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) controls, eg clothing accessories with feather, leather, etc. Also, will TSP operate at all ports in the UK?

Wooden pallet shortage after EU exit

10 April 2019

We read in the press that there will be a shortage of wooden pallets when the UK leaves the EU. We ship all our goods into the EU on wooden pallets and can’t understand why there might be a shortage. Can you explain please?

The new Transitional Simplified Procedure and airfreight

5 April 2019

Please could you explain the new Transitional Simplified Procedure (TSP) announced by HMRC on 4 February 2019. We are an importer of goods from most of the EU Member States which we further process and re-export into the EU or sell to 3rd countries such as Canada, the USA, Switzerland, etc. The goods all arrive by airfreight as they are low volume and lightweight. Should we register for TSP? It seems to only refer to roll-on/roll-off (RORO) shipments and ferry ports.

Open General Export Licences for “Dual Use” items going to the EU after “no-deal”

28 March 2019

I’ve seen that the UK Government has issued an Open General Export Licence (OGEL) just in case there is no deal for “Dual Use” items going to the EU. I have registered through the Shared Primary Information Resource Environment (SPIRE) on the Export Control Organisation (ECO) website but I wondered what the UK will do to replace the Union General Export Authorisations (UGEAs), the main one which permits the export of dual-use controlled items to the USA, Canada, Japan, Australia, Norway, Switzerland (including Liechtenstein) and New Zealand. As a business, we need this UGEA to trade with these markets. Am I correct in assuming a “no deal” will mean this can’t be used for those shipments?

Translation of import documents into a European language

25 March 2019

We have been advised by our forwarders customs experts that a German translation is required for import documents for goods to be imported into Germany.

We have never been asked to provide a translation of our product description going into non-EU countries nor have we been asked to provide a more detailed description of the goods; are you aware of this requirement and is it likely this will be necessary for France as well as we will be using a French and German hub? We have been advised that the German translation must be a comprehensible description in German showing the following information: Description of goods, usage and material texture.

Brexit transitional arrangements for the evidence required for zero rating of VAT for exports

25 March 2019

Are you aware if HM Revenue & Customs (HMRC) has introduced any simplifications or transitional arrangements for the evidence required for zero rating of VAT for exports if we exit the EU? Assuming we exit the EU the amount of work involved chasing for evidence, even when we have enough secondary evidence, will be significant if there is no flexibility around what is required.

Opening a deferment account

18 March 2019

As the outcome of Brexit is still unclear, would it be beneficial to open a deferment account to speed up customs formalities?

We have a couple of imports from Turkey a year but have used the clearing agent’s account for a nominal fee, and this has worked well, without any delays.

We did have a deferment account for many years for our regular imports from Japan, but then we moved onto a European supplier, so the account became dormant and as a cost-cutting exercise we closed it several years ago.

I’ve also seen information on Transitional Simplified Procedures (TSP) — is this something you would still recommend if we open a deferment account? If we claim Inward Processing (IP) relief can we still sign up for TSP?

Clearance instructions to freight forwarders using a deferment account after Brexit

15 March 2019

When the UK leaves the EU, especially in a no-deal exit, would it be that we continue to give clearance instructions to our freight forwarders to use our deferment account? I’ve been reading recently HM Revenue & Customs (HMRC) will not pursue payment of the VAT on a monthly basis as they do now, VAT on the deferment account can be claimed as part of the quarterly return. Is this the case for non-EU imports and EU imports?

Selling on a Delivered Duty Paid basis

15 March 2019

Our company is based in Germany and currently we sell to our customers around the EU, including to the UK, on a Delivered Duty Paid (DDP) basis. Could you please advise what would happen if our German company tries to apply for a UK Economic Operator Registration and Identification (EORI) number under our German VAT registration number?

EU Free Circulation Goods and T2 status

7 March 2019

In the case of a “hard” Brexit, would we be able to custom-clear goods into the UK within March 2019 (before 29 March 2019) and then still deliver them as EU Free Circulation Goods to our EU customers after 29 March 2019? I would think so, as the customs duty we will be paying before 29th is EU customs duty.