Import and export of goods between the UK and the EU: updates to the Border Operating Model

In November, the UK Government updated the Border Operating Model (BOM), the primary document outlining the UK’s border controls for the import and export of goods between the UK and the European Union.

The dates from which certain changes will take effect have changed. The key takeaways for businesses, which particularly impact those in the agri-food sector, are:

From 1 January 2022

• The temporary concession to delay customs declarations will end. This concession currently allows an importer to routinely import goods on arrival in the UK but submit a formal customs declaration up to 175 days later.
• Full customs declarations and controls will be required, at the time of import, for all imports.
• Pre-notification requirements for Sanitary and Phytosanitary (SPS) goods, originally due to be introduced on 1 October 2021, will commence.
• For the Imports of Products, Animals, Food and Feeds System (IPAFFS), UK importers must be registered with IPAFFS, have a UK address and be responsible for submitting the prenotification of incoming consignments before the consignment is due to arrive.

From 1 July 2022

• Safety and security declarations on imports will be required from this later date, rather than 1 January 2022, as previously announced.
  Certification and physical checks will be introduced for any remaining regulated animal by-products, regulated plants and plant products, meat products and high-risk food not of animal origin.
• High priority plants and plant products checks will transfer from the place of destination to designated Border Control Posts (BCPs) and control points.

From 1 September 2022

• Certification and physical checks will be introduced for all dairy products.

From 1 November 2022

• Certification and physical checks will be introduced for all remaining regulated products of animal origin, including composite products and fish products.

Live animal physical checks will also take place at designated BCPs, where a facility is operational at the point of entry. Where there is no designated BCP, checks will remain at the destination for other ports of entry until sufficient BCPs are operational. Checks at Sevington inland BCP and designated airport BCPs will commence from 1 July 2022. Department for Environment Food & Rural Affairs (DEFRA) will provide further information on the phased approach to physical checks for SPS goods in the new year.

The UK Government believes this revised timetable considers the challenges businesses have been dealing with during the pandemic and provides sufficient time to adjust to the changes. UK importers and exporters will, however, need to react quickly to implement these changes to ensure goods can move through the border as quickly and as efficiently as possible.

How we can help

Should you or your business need assistance dealing with these additional complexities, please contact one of our VAT advisers or your usual Smith & Williamson contact.

DISCLAIMER
By necessity, this briefing can only provide a short overview and it is essential to seek professional advice before applying the contents of this article. This briefing does not constitute advice nor a recommendation relating to the acquisition or disposal of investments. No responsibility can be taken for any loss arising from action taken or refrained from on the basis of this publication. Details correct at time of writing.

Tax legislation is that prevailing at the time, is subject to change without notice and depends on individual circumstances. Clients should always seek appropriate tax advice before making decisions. HMRC Tax Year 2022/23.

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