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The UK announced a delay to the Customs Border Operating model changes due to be implemented on 1 April (Import Licencing) and 1 July 2021 (Delayed Customs Declaration Submission).
The pre-notification requirements for Products of Animal Origin (POAO), certain animal by-products (ABP), and High Risk Food Not Of Animal Origin (HRFNAO) that were originally due to take effect from 1 April, will not be required until 1 October 2021. This will give businesses more time to prepare.
Customs import declarations will still be required, but the option to use the deferred declaration scheme, including submitting supplementary declarations up to six months after the goods have been imported from 1 July 2021, has now been extended to 1 January 2022. Safety and Security Declarations for imports will also not be required until 1 January 2022. However, businesses moving controlled goods into Great Britain will continue to be ineligible for the deferred customs declaration approach, and will therefore be required to complete a full customs declaration when the goods enter Great Britain.
Importers must remember that whilst delaying customs declaration until 2022 may seem a great idea, it will only work for those importers collating their customs declaration data and supporting clearance documentation as they progress throughout 2021. Trying to recreate this data towards the end of the year prior to 1 January 2022 could be a real challenge and potentially lead to incorrect customs declarations with incomplete supporting documentation being submitted to HMRC. In turn this could lead to compliance breaches and assessments being raised by HMRC.
In order to be well prepared for October 1 2021, PwC can assist with determining which documents/registration/authorisation are exactly required for your products and which authorities should be contacted to obtain them. We can assist you in the process of registration/completing documents and setting up a process to ensure compliance and avoid delays.
Furthermore, we can also help in setting up a process, in case the deferred declaration scheme is used, to ensure that all required custom data is available at the moment the actual declaration needs to be submitted.
Should you need any advice on this matter, please contact your usual PwC customs and international trade specialist at PwC
Simeon L. Probst
Partner Customs & International Trade, PwC Switzerland
Tel: +41 58 792 53 51
Dr. Michael Tervooren
Partner, PwC Germany
Tel: +49 211 981-7641