Mid-market unprepared for EU trade full customs controls

With HMRC set to remove the current easements on full customs controls as of January 1, 2022, new research from Grant Thornton UK LLP’s latest Business Outlook Tracker* finds that around a fifth of the UK mid-market are not yet prepared for the changes.

Of the 605 mid-market businesses that responded to the survey, 445 import goods to the UK. Whilst the majority (73%) of the businesses who do import goods were aware of the HMRC full border implementation deadline, nearly one in five (18%) who were aware of the changes said they were not yet prepared.

To allow time to prepare for the new border control procedures, the government set out a staged timetable for the introduction of all the border controls, including temporary easements on custom declaration in the summer of 2021.

Further changes to requirements are scheduled for July 2022, when phytosanitary certificates and physical checks on sanitary and phytosanitary (SPS) goods will be introduced at specific border control posts. There will also be new requirements for export health certificates for animal and plant products and safety and security declarations for all imports will also become mandatory.

Commenting on the findings, Karen Robb, Head of Indirect Tax at Grant Thornton UK LLP, said:  

“With a little over a month to go until the deadline, businesses who import goods from the EU into the UK who haven’t started preparing for the new customs requirements need to urgently get up to speed to ensure supply chain continuity in the new year.

“Though it is anticipated that most businesses will use the services of a specialist intermediary, such as a customs broker, to complete the necessary border declarations it is still vitally important that all importers and exporters are fully aware of the revised border requirements, as responsibility for the accuracy of the information provided in the declarations remains with them.”

What should businesses do to prepare?

• Consider using a customs intermediary to make declarations on your behalf if you do not already have one. You need to understand the requirements of your specific supply chain as border processes can vary depending on the mode of transport used and the specific port or airport where the goods arrive in the UK.
• Make sure that relevant personnel within your businesses supply chain, customs and tax function are coordinated, aware of the changes, and whether they need to take any action.
• To submit import declarations in a timely manner, you need to have the required customs information on your goods in advance. You will be expected to provide your customs intermediary with your EORI number together with information on the type of goods their quantity, value, weights, country of origin, and any certifications etc.
• Be aware that if you are using some of the short straight routes, e.g., Calais-Dover, UK import declarations may need to be submitted prior to the ferry sailing.
• Those importing food, plants, and animal products will notice the biggest changes. For businesses importing these products it is important have all the required registrations and systems access to provide the necessary notifications to the appropriate border agency. This is a separate requirement in addition to the customs declaration.

_{*The Grant Thornton Business Outlook Tracker is a bi-monthly survey of mid-market businesses. Censuswide (on behalf of Grant Thornton UK LLP) surveyed 605 senior decision makers in UK mid-market businesses between 29 September 2021 – 12 October 2021. The UK mid-market is defined as companies with an average annual turnover between £50million - £500million.}