Following the appointment of Boris Johnson as Prime Minister, it has become more likely that the UK will leave the EU on 31 October 2019 without a deal or a transitional period.
Mr Johnson has stated his intention to reach a new deal with the EU, but this will be very difficult within the time available. Although there would be a number of political barriers which may prevent a no deal situation it is now a very possible outcome. The new government is focusing much more clearly on the possibility of a no deal exit on 31 October, with daily meetings to monitor progress in planning, and increased spending on preparations and on providing information to businesses and households about the likely effects.
All businesses who trade in goods will need to reconsider and update any plans they had in place for 31 March, and any businesses who have not yet prepared should reconsider this position in the light of the change in government policy.
Businesses which currently only trade internationally with the EU will need to make sure they are set up to use customs processes for imports and exports and have obtained an EORI – the international version of the VAT number which is needed for customs documentation. Customs documentation also requires commodity codes for all items and evidence of the origin of the goods as well as commercial invoicing information.
There is a transitional simplified process for import documentation which will require advance registration, further information about importing and exporting is at the links below.
HMRC has already announced a temporary tariff for imports into the UK from all countries which don’t have a trade deal so this can be used to check the extent of any duties on goods arriving in the UK. The external tariff for the EU can also be used to check the tariffs which will be charged on goods arriving in the EU from the UK after no deal. Customs duties are part of the cost of the goods and contracts may need to be reviewed to see whether it is the seller or the buyer of the goods who is responsible for any duty.
Non tariff barriers
There are also specific regulatory issues facing specific industry sectors such as food and drink, fishing, pharmaceuticals and financial services with a large number of guidance notes being published both by the UK government and the EU commission setting out what new rules with apply after a no deal Brexit.
These can be found at the links below: