The UK left the EU Single Market and Customs Union in January 2021 and the post-EU Transition Period ended in December 2021.
Movement of goods between the UK and the EU is now regulated by the Trade and Co-operation Agreement (TCA), whilst the Northern Ireland Protocol governs movement between Great Britain and Northern Ireland.
When the Transition Period ended, the EU implemented full border measures on goods arriving from the UK at once.
The UK is implementing border measures for EU goods more gradually. The first phase of changes - affecting live animals, alcohol and tobacco and High-Risk Plants - was competed on 01 January 2021.
What happens next?
For food and drink traders, the next phases of change at the UK border will occur on 01 October 2021, 01 January 2022 and 01 March 2022.
This timeline is not the one originally planned – Phases 2, 3 and 4 have been delayed, but further delay is unlikely.
UK importers are responsible for ensuring that measures are complied with but, to ensure smooth supply chain operation, businesses in the EU will also need to be informed and prepared.
Moving goods from the EU to the UK is likely to become more complex in the near future, especially for food, drink and associated items.
EU exporters should co-ordinate with UK importers - action may be needed to minimise the business impact of border changes.
Key changes are as follows:
From 01 October 2021
- Import of Products of Animal Origin (POAO), some Animal By-Products (ABP) and High Risk Food Not Of Animal Origin (HRFNAO) must be pre-notified, via the Import Of Products, Animals, Food and Feed System (IPAFFS)
- The notice period is usually at least 24 hours, but a temporary derogation allows notice of at least 4 hours – this will last until December 2021
- Imports must be accompanied by an appropriate Export Health Certificate (EHC), completed correctly, in full and signed by a qualified person
- Imports may arrive at any location and shipments will not be stopped for physical inspection at the border - inspection may occur at other locations, however Customs declarations must be made for each shipment, but these may be delayed for up to six months
From 01 January 2022
- POAO, ABP, HRFNAO and High-Risk Plants will be subject to physical checks at the UK border and must arrive at locations with a suitable Border Control Post (BCP)
- Imports of Low-Risk Plants and Plant Products must be pre-notified via IPAFFS and accompanied by a Phyto Sanitary Certificate
- Customs declarations must be submitted without delay, although some traders may be eligible to defer payments
- Importers must provide Safety and Security Declarations
From 01 March 2022
- BCPs will conduct physical checks on Low-Risk Plants and Plant Products. Live animals may also be checked, if BCP capacity allows.
In addition to these changes, EU businesses dealing with the UK should note the following:
- Goods intended for sale in the UK must comply with UK regulations – most EU rules have been copied into UK law and continue to apply as before, but there have been some changes (eg: labelling) – special arrangements apply for goods sold in Northern Ireland
- EU drivers and vehicles must have the correct documents for entering the UK and for re-entering the EU when they return to their point of origin
- The UK now has an independent tariff system, the UK Global Tariff (UKGT) – some goods now have zero tariff, but tariffs still apply to many food and drink products. Goods traded under the TCA benefit are not tariffed, if they comply with Rules Of Origin (ROOs)
- UK exit from the EU has not changed requirements for products entering the UK from other countries - some trade deals made by the EU with third countries have been “rolled over” and the UK continues to benefit from the same or similar terms
- All wooden packaging (eg: pallets) used to transport goods from the UEK to the UK must comply with ISPM15 requirements
Where to find out more
- The Border Operating Model (BOM) is a complete guide to how the UK border will function as new arrangements are implemented.
- The UK government has provided step-by-step guides for businesses importing to the UK and guidance for businesses exporting from the EU
- IGD has worked with other UK organisations to create a simple “FAQ” website aimed specifically at food and drink traders
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