Impact of DEAL OR NO DEAL BREXITand HMRC Guidance to Exporters and Importers

The United Kingdom (UK) will be leaving the EU, including the Customs Union, at 11pm (UK time) on 29 March 2019.

The UK government has reached agreement with the EU on the vast majority of withdrawal issues, including the terms of an implementation period. Full agreement on this will mean that trading with the EU during the implementation period would broadly stay the same from the end of March 2019 until 31 December 2020.

No Deal BREXIT

In the event of No Deal, Deputy Chief Executive of HMRC, Jim Harra, says that the government is committed to prioritising stability for businesses. That they will continue to work closely with industry to ensure that delays and any additional burdens for legitimate trade are minimised.

It seems from that the priority in such a scenario would be to minimise disruption and to maintain status quo for as long as it takes for all aspects to settle down.

If you’re a trader based in the UK currently importing and/or exporting goods within the EU and you do not currently trade with non-EU countries then the possible changes that may impact your business would be:

1. UK businesses having to apply customs, excise and VAT procedures to goods traded with the EU, in the same way that already applies for goods traded outside of the EU.

2. Trading partners in the EU having to apply customs, excise and VAT procedures to goods they receive from you, in the same way that they do for goods received from outside of the EU.

3. If your business currently trades only with the EU then you’d have to start completing customs declarations from March 2019 and customs checks would apply to your business for the first time.

Steps to minimise disruption

You may take the following steps to ensure that the transition is smooth for your business.

1. Understand the obligations you may need to take to continue to trade with the EU if the UK leaves without a deal are broadly the same as those that apply to businesses that trade with countries outside of the EU.

2. If you are a member of a trade body, they might have useful information.

3. Review the following guidance and notices from the HMRC:

4. Importing from non-EU countries; and 

• Exporting goods outside the EU.

• Customs – ‘Trading with the EU if there’s no Brexit deal’ 

• Tariffs – ‘Classifying your goods in the UK Trade Tariff is there’s no Brexit deal’

• VAT – ‘VAT for businesses if there’s no Brexit deal’

Hammad advices on all aspects of Customs and Excise law and can assist your business in dealing with the uncertainty that your trade faces regarding leaving the EU.