Since the UK left the EU, there have been some transitional arrangements including Staged Custom Controls but these will no longer apply from 1 January 2022.
These transitional arrangements included Simplified Declarations – these are for ‘not controlled goods’ only and require a declaration and entry into your business records in order for the goods to be in free circulation. You may not have needed a formal authorisation for this but that will expire on January 1 2022.
You will need to submit full customs declarations and make any duty payments due, at the point of import or your goods may not be released. You can appoint a customs/shipping agent to deal with this for you.
You may have already received authorisation to make ‘Simplified Declarations’ but, if you haven’t you will need to do so; it can take HMRC 60 days to do their necessary checks before any authorisations is given so you will need to have alternative processes in place until any authorisation is given. In order to do this, you will also need a duty deferment account.
Currently, if the goods are of EU Country of Origin, it has been sufficient only to enter ‘EU’ as the CoO, this will no longer be the case from January, you must use the correct country code. If your goods do not have a valid declaration, they will not be released and may not be able to leave the port (or Inland Border Facility).
This will also have an impact on exports, if the documentation is not correct, HMRC’s new system will not allow your goods to leave the country and they will be turned away.
During 2021, tariff preference was given when UK/EU importers could give a statement of origin or based on the importer’s knowledge and get a supplier’s declaration later. From January, this will also be no longer permitted and you may require both a statement of origin and the supplier’s declaration. You will need to have this supplier’s declaration, where required, for all goods exported this year – if they are subject to EU customs verification and you do not hold this evidence, full VAT and duty will be liable and they may impose an additional penalty.
This is a complex area and we strongly recommend you seek advice from a reputable shipping/customs agent.