Ahead of the new year and the new border operating model, we detail some of the key points for the Core Model for imports – the processes that all goods movements must follow from January 2022. The Core Model is not an exhaustive list of all the requirements which may apply to a goods movement. Further requirements applicable for particular goods movements are outlined on the government website here.
In order to fulfil the import process, all traders will need to ensure they have:
- A GB Economic Operator Registration and Identification (EORI) number.
- The Commodity Code of their goods – needed to make a customs declaration and calculate duties on an import.
- The customs value of goods – needed to make a customs declaration and calculate duties on an import. The rules for valuation are based on the World Trade Organisation (WTO) valuation agreement.
- Considered whether they are able to, and would benefit from, using any available customs simplifications or facilitations. More information is available here.
- Considered how they will make customs declarations to HMRC systems, and whether they will use an intermediary.
Delaying customs declarations will not be available from January 2022 onwards. Importers bringing or receiving goods from the EU (or someone appointed on their behalf) will have to complete a customs import declaration. Customs declarations are complex. Most businesses that currently trade outside the EU use an intermediary to submit customs declarations to HMRC systems. Further information on intermediaries can be found here.
Completing a customs declaration requires:
- A GB EORI number
- The Commodity Code of their goods. More information is available here.
- The value of goods – needed to make a customs declaration and calculate duties on an import. The rules for valuation are based on the WTO valuation agreement.
- The origin of goods - where supply chains mean that parts of a goods consignment are produced outside the EU (for importers) or outside the UK (for exporters), this may affect the origin of the goods. The practicalities of rules of origin can be complex and in these cases it’s a good idea to take expert advice to ensure compliance as an importer or exporter.
- Access to HMRC systems either directly, or via an intermediary with the access.
The New Pre-Lodgement Model
Under the pre-lodgement model, to achieve customs control whilst maintaining flow, industry must:
- Ensure all goods have the appropriate declarations before they board
- Communicate to the person in control of the goods (e.g. the driver of a lorry for accompanied goods or the carrier for unaccompanied goods) by the time they arrive at the border, to inform them whether goods are cleared to proceed on their journey or alternatively whether the goods require a check.
The Goods Vehicle Movement Service (GVMS)The GVMS is an IT platform which supports the pre-lodgement model. The GVMS will allow:
- Declaration references to be linked together so that the person moving the goods (e.g. a haulier) only has to present one single reference (Goods Movement Reference or GMR) at the frontier to prove that their goods have pre-lodged declarations.
- The linking of the movement of the goods to declarations, enabling the automatic arrival in HMRC systems as soon as goods board so that declarations can be processed en route.
- Notification of the risking outcome of declarations (i.e. cleared or uncleared) in HMRC systems to be sent to the person in control of the goods by the time they physically arrive. If port operators decide to use the pre-Lodgement Model they will need to:
- 1. Ensure goods are not allowed to arrive at that location without pre-lodged declarations. For example, by being listed as a RoRo location or through commercial arrangements with users that goods without declarations will not be allowed into the location.
- 2. Take reasonable steps to ensure those goods identified as needing checks are controlled upon arrival
The Temporary Storage Model
Goods imported from the EU can be stored temporarily under customs control before they are released to free circulation, exported or placed under the outward processing procedure, or placed under a special procedure (inward processing, customs warehousing, authorised use, or temporary admission). This will mean traders can defer making a customs declaration and paying duties and taxes for up to 90 days from the date the goods are presented. An authorisation is required to operate a temporary storage facility. From January 2022, an inventory system is required for all temporary storage facilities (including those currently storing non-EU goods). More details are available here. Border locations using the temporary storage model can use GVMS to facilitate the control of pre-lodged declarations for both accompanied and unaccompanied goods. If GVMS is being used to facilitate control at a temporary storage location, GVMS must be integrated with the border location’s inventory system.