Brexit: Making sure your customs declaration form is accurate

From January 1st, Irish companies moving goods to, from and through the UK will be required to complete customs declaration forms and pay duties on the goods.

 

Registering for customs is the easy first step; then you need to decide how to pay the duties and apply for the Deferred Payment scheme if needed. A vital additional step is to decide who will be completing the customs declaration form. According to Revenue, the biggest single reason that goods are stopped at border crossings is due to data errors – so it’s imperative that the person filling out the forms is experienced and well trained.

“It’s a very difficult process,” explains Carol Lynch, partner at BDO Customs & International Trade Services. “There are two essential streams of information that you are including on the form – the first is in relation to customs and tax and the second is in relation to the freight and movement of goods. For the latter, you should be able to provide that information by working with your haulier and referring to the weight, the packing list, the shipping details etc, but the former is a tax declaration so you need to understand custom taxes in the same way you would have to understand any other tax in order to make a return.”

 

Identify the potential pitfalls

A standard customs declaration form contains over 50 fields; some are straightforward but a lot require a high standard of customs knowledge, such as classification codes – beware, there are tens of thousands to choose from. “Possibly the most important part of the form is the customs classification tariff code,” says Carol. “That code will tell customs what the product is, what group the product falls into, what rate is applicable to your product, and if there is any licensing required. Customs classification is an art in itself – there are some products that are easy to classify, but most products these days are not straightforward as they could be a combination of technologies, or pharmaceutical and cosmetic, or a processed food. You must be able to work through the options and logically apply the one you think is correct. You should be able to explain your choice and understand the rules of classification. If you’re uncertain, you need to get a classification ruling from Revenue.

“Another tricky part is the value of your goods. It’s straightforward if it’s a simple sale of goods to a third party, but what if it’s inter-company or on consignment, how do you work out the value of the goods at that point? In that context, you need to understand the rules of origin.”

It’s also vital to talk to your customers about your international commercial terms, or Incoterms. Goods going in and out of the UK will need both import and export declarations and you need to work out who is responsible for making the declarations and paying the duties. “You need to talk to your customers about who is the importer and who is the exporter,” Carol explains. “With the EU, there were no customs and so goods were simply delivered to the customer, but if that is going to stay the case, then the goods need to be delivered duty paid – which means you have to export the goods and then import them into the UK so there’s a couple of steps. A compromise is that you act as the exporter and your customer acts as the importer, but that doesn’t always work out so you need to clarify this with your customer.”

Employ an agent

Companies can decide to fill through the forms themselves or they can employ an agent – but just like employing an external accountant, you are still responsible for the information on the form. “It’s important to understand customs, even if you’re not going to fill out the declarations yourself,” says Carol. “Look for an experienced agent – but be aware that there is a shortage of experienced agents both here and in the UK, so you need to start looking for one as soon as possible.”

Even more importantly, there is a lot of groundwork to do before employing an agent. “You need to have a master list of everything you buy from and sell to the UK. This is a schedule of all your products listed by SKU number with a description of the product, the tariff classification code and the applicable rate, along with any licences associated with that tariff code. If you only have a few products, it’s not a problem, but if you have 6,000 or more, it’s a big job.”

After that, working with a good agent is relatively plain sailing. “Once you have your agent and you’re beginning to lodge your forms, everything should be running smoothly and it’s really about auditing at this stage. Make sure you keep your master list up to date with any new products, and on an annual basis, review all your products to make sure the tariff classifications don’t change. Every month or week, depending on your volume, take a sample of the imports/exports and carry out your own internal audit.”

Take a training course

Carol would encourage everyone to undertake some sort of training in customs – and there’s plenty of courses to choose from. “Everyone should do some customs training. There are different levels; the Skillnet course is detailed training on how to fill out the form yourself, while Local Enterprise Offices are providing one day training courses on what customs is all about. Enterprise Ireland’s own customs insights course is available on Prepare for Brexit, while the Revenue and Enterprise Ireland customs webinar can be viewed onsite also. This is more than enough for most companies who will be employing an agent. And then Bord Bia is offering specific customs training for food and agri clients. I would urge anyone to avail of the training – it’s free and it’ll take the fear factor away.”

Keep Calm and Carry On Selling

Despite the understandable concern on Irish shores about the UK’s decision to leave the EU, our nearest neighbour will remain a natural first market for Irish exporters. Enterprise Ireland’s manager for the UK and Northern Europe, Marina Donohoe outlines the opportunities.

 

Enterprise Ireland manager for UK and Northern Euurope, Marina DonohoeThe UK economy will still be the fifth largest in the world by nominal GDP, with a population of around 65 million— some 14 times the size of Ireland’s. It will still be our closest trading partner by geography— sharing a language and a similar business culture— and it will still have that openness to goods and services from Ireland borne of our strong cultural relationship.

While strategies to offset whatever consequences arise from the UK vote are advisable, businesses in Ireland would be missing a trick if they discounted the UK market.

In fact, Enterprise Ireland has identified seven key opportunities for Irish companies based on UK government initiatives and evidence of sectoral growth:

 

  1. The National Infrastructure Delivery Plan
  2. The Northern Powerhouse Agenda
  3. Scottish Government Investment Plan
  4. National Health Service’s ‘Five Year Forward View’
  5. Water market
  6. Financial services/Fintech
  7. Aerospace

 

National Infrastructure Delivery Plan (NIDP)

The NIDP envisages £503 billion of investment in 339 infrastructure projects across all sectors in the UK to 2021 and beyond. Irish companies are operating in these sectors already and there are huge opportunities such as:

 

Northern Powerhouse

The Northern Powerhouse is an initiative to address a constellation of issues surrounding economic growth and productivity in the North of England.

The UK government intends to spend £134 billion, 32% of which will be spent in Northern England. The goal is to rebalance the country’s economy and establish the North as a global powerhouse.

Cities include Liverpool, Leeds, Sheffield, Newcastle and Hull, as well as regions such as Cumbria, Lancashire, Cheshire, North Yorkshire and the Tees Valley.

The opportunity for Ireland lies in supporting initiatives in road, rail, freight, aerospace and skills development. Key deliverables include improving freight capacity, and road and rail infrastructure. For example, the HS2 high speed train network alone will cost £55.7 billion.

 

Scottish Government Investment Plan

Enterprise Ireland continues to have a strong geographical focus within the Scottish market. Holyrood has highlighted the strategic, large-scale investments it intends to take forward across a number of key sectors over the next 10 to 20 years. Key areas of investment which will provide opportunity for Enterprise Ireland clients include energy, water and housing.

 

National Health Service (NHS)

Despite the political and economic uncertainty the healthcare sector has remained strong over the last 12 months. An ageing population, improved diagnosis and an ever-changing world of assistive and diagnostic technologies have all ensured the sector’s appeal to client companies.

The NHS is rife with opportunities as the funding gap is set to widen to £30 billion by 2021. The NHS needs to deliver £22 billion in efficiency savings to try and offset this figure, with a lot of this being driven by a focus on digitising as much of the landscape. Our Digital Health and Health IT webinar provides expert insights into procurement pathways and winning business with the NHS, watch it here. Although the private healthcare market is also growing (currently around £4.5 billion) it pales in comparison to the £107 billion NHS budget.

 

Water market opportunity

UK water utilities are planning a total expenditure of £41 billion between 2015 and 2020. Enterprise Ireland is working with UK and global buyers who have access to this opportunity and could also prove to be a stepping stone to international projects. Our podcast on the impact of Covid-19 on the water sector and the emerging opportunities for supply chain companies is available here.

 

Financial services/Fintech

With over 250 foreign banks; expertise across retail banking; insurance; capital markets; bonds; equities; currency; payments; regulation; and sector-specific advisory, legal and professional services, the breadth of the UK financial services sector is huge. The sector employs 2.2 million people in the UK. It is a truly global centre of expertise and one that will continue to offer opportunity for Irish fintech companies after the UK exits the EU.

Opportunities will emerge as the negotiations get under way, particularly for legal, advisory, professional services and IT solutions providers, as UK firms may seek new structures around regulation, compliance, currency handling, money laundering and data handling.

This is a sector Enterprise Ireland has been working in for many years and, as new opportunities unfold, we are well placed with high level contacts to introduce our clients to key decision makers.

 

Aerospace

UK Aerospace industry captures 17% of the global market and is considered the largest player in Europe and second globally after the US. Aerospace is vastly outperforming the wider UK economy with productivity up 30% over the past five years, compared with the national average of 2%. Though heavily impacted as a result of Covid-19, the Aerospace Growth Partnership (AGP), industry and government are working together to ensure the UK is well placed for future growth opportunities. Investment in skills, technology and the competitiveness of the UK supply base is supporting this.

 

Internet of Things (IoT)

Enterprise Ireland is reacting to opportunities emerging outside of these seven key sectors too. In particular, we are responding to the growth of IoT technologies. The UK has some of the best equipment (mobiles, tablets, computers) usage rate projections in the world. The main growth areas are artificial intelligence, big data, smart cities, connected homes, transportation, health, manufacturing and smart grid for electricity.

IoT is clearly a massive growth market and as a result a source of business opportunities for Irish companies.

 

For latest news on UK opportunities visit Evolve UK.