Another week nearer the end of the transition period, and still no clarity on what the post-Brexit trading landscape will look like.
The readiness – or rather lack of readiness - of business to deal with whatever happens on 1st January is becoming an increasing worry. Although the government’s advertising campaign is urging firms to get ready for Brexit, the reality is that doing so is very difficult without knowing what it is that they are preparing for exactly.
The ads have been heavy on the suggested benefits of Brexit and somewhat lighter on the practical impact on business, and explaining exactly what action is needed to continue trading after 31st December.
There is no prospect of the transition period being extended (despite many calling for it to be, if only because everyone’s attention has been rather taken up elsewhere for the past nine months).
It is clear that when it comes to exports, the EU will be strictly implementing new controls from the first hour of the UK finally leaving.
When it comes to imports, however, there will be more flexibility. This is one area where the UK will be able to ‘take back control’ (although even if there is no deal, it will still be bound by WTO rules), and the government has indicated that there will be a phased approach to introducing the kind of border controls which could otherwise paralyse the movement of goods into the country.
From day one, traders importing ‘standard goods’ will need to prepare for basic customs requirements, but will have six months to complete customs declarations – and any tariffs will not fall due until the declaration has been made. There will be checks on controlled goods such as alcohol and tobacco, and full customs declarations on these will need to be made at the point of entry into the UK.
Pre-notification and health documentation will be required for live animals and high-risk plants and plant products, and high-risk animal by-products.
From April, all products of animal origin, such as meat, pet food, honey, milk and egg products, as well as all regulated plants and plant products, will also require pre-notification and the relevant health documentation prior to import.
From July, declarations will have
to be made at the point of importation for all goods, and tariffs paid at the
same time. There will also be an
increase in physical checks and the taking of samples, especially Sanitary and
Phytosanitary (SPS) checks.
All of this will apply whether there is a deal or not (except for the payment of tariffs, if a deal removes these). And it is still not clear what the situation will be with imported components which are then used in manufactured goods destined for re-export. Like everyone else, we await clarification with bated breath.