Traders continually need to stay abreast of changes to rules and procedures for moving goods across international borders, and the next few months are no different.
The IOE&IT Daily Update here summarises some key developments in UK customs.
1: UKIMS comes into view
The UK Internal Market Scheme (UKIMS) will replace the existing UK Trader Scheme (UKTS) in under two weeks, from 30 September.
Under the scheme, businesses will be able to declare that goods entering Northern Ireland from Great Britain are ‘not at risk’ of moving to the EU, ensuring EU duty is not payable on the goods. Once authorised on UKIMS, businesses can declared goods as not at risk when completing declarations by using the code ‘Northern Ireland remain’ (NIREM).
If a business’ authorisation is not processed by the time that UKTS closes on 30 September, HMRC advises that businesses will, if eligible, be able to claim any duties back via the Duty Reimbursement Scheme or claim a customs duty waiver.
The Trader Support Service hosted a webinar on the new scheme earlier in the year, which you can watch here.
2: Russia steel and iron sanctions
Goods containing iron or steel originating in Russia that are processed in a third country will face new sanctions from 1 October, as per Chapter 4CA in Regulation 3 in the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023.
Anna Doherty, a senior trade and customs specialist at IOE&IT, said the regulation “allowed for a window within which businesses could import goods which were processed in third countries, but which contained specific iron and steel products from Russia”, but this window is due to close on 30 September.
“This places extreme importance on businesses having robust processes in place to review their supply chains,” she said. “This includes not just tier 1 vendors but further down the chain too.”
She said that businesses now didn’t have “much time to adjust any of their manufacturing and purchasing strategies”.
She added that it’s important that businesses understand their commodity codes and country of origin requirements, while conducting proper due diligence, alongside their suppliers, to seek confirmation that the products they are importing do not contain Russian-origin components or materials.
3: Electronic Trade Documents Act
The Electronic Trade Documents Act is due to come into force on Wednesday this week (20 September), potentially heralding a new era for UK trade.
Technology and digital economy minister Paul Scully has said the legislation – which gives electronic versions of key trade documents equal legal footing as their paper equivalents – could save businesses up to £1.1bn over the next decade.
You can read more about the possible impact of the legislation here, as well as some of the hurdles that need to be overcome to make its potential a reality here.
4: New trusted trader scheme pilots
Businesses can express their interest in the development of pilot trusted trader schemes goods subject to certain sanitary and phytosanitary controls that are deemed ‘medium risk’ under the Border Target Operating Model (BTOM).
HMRC’s Joint Customs Consultative Committee (JCCC) wrote to stakeholders to explain the new ‘Accredited Trusted Trader Schemes’ (ATTS):
“The proposed ATTS is a scheme aimed towards frequent importers of ‘medium risk’ Products of Animal Origin (POAO) and Animal By-Products (ABP) from the European Union (EU) and the Rest of World (RoW). ATTS has been designed with a modular framework which will provide businesses with flexibility and choice in how they engage with the Trusted Trader approach.
“Businesses will be able to build a package of facilitations that aligns with their specific operational needs rather than needing to engage with a one-size-fits-all solution. Each module will be piloted as a first step to determine if the module will be included as part of the scheme indefinitely.”
You can read more about the schemes and how to apply here.
5: VAT changes for second-hand car sales in NI
The JCCC has also reminded businesses, in its regular ‘Borders Bulletin’, that “the way VAT-registered businesses account for VAT on used motor vehicles bought in Great Britain and moved to Northern Ireland for resale has changed”.
For GB-bought second-hand motor vehicles moved to NI before 1 May 2023, businesses can continue to use a pre-existing VAT margin scheme, provided these vehicles are sold by 31 October 2023. If they are sold after the latter date, the business will have to account for VAT on the full selling price of the vehicles.
A new second-hand vehicle payment scheme was also introduced on 1 May 2023, and can be used by businesses that have moved second-hand vehicles in GB and moved them to NI on or after 1 May 2023. The new scheme allows traders to pay the same net amount of VAT as if they had continued access to the previous VAT margin scheme.
