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Are you thinking the unthinkable? If not, start now…

Are you thinking the unthinkable? If not, start now…

How to take the friction out of your supply-chain?

ª  The The government have stated that they will be promoting and supporting ‘Flow over Compliance’ in relation to the flow of consignments into and through the UK. In the event of a Day 1 No Deal Hard Brexit – this will not be a permanent arrangement; make sure you have robust procedures in place that will facilitate an effective and instantly retrievable audit trail which would survive an HMRC inspection.

ª  If you are exporting to the EU be careful about the shipping route you take

o   Consider alternative routes and modes of transport which avoid the short distance channel routes. Going via alternative Ro-Ro routes or by short-sea container will avoid being stuck in a costly and frustrating queue on the M20.

ª  Ferry Lines have always made it a mandatory requirement that Exporters and their hauliers have all customs formalities and paperwork in place before they board – make sure this is the case.

ª  Design a communication system that ensures you are kept informed on how each consignment is performing against timelines through critical control points – all your haulage suppliers must adhere to this, so that accurate information is to hand at all times.

ª  Ensure that as an Importer you have a registered UK EORI number, you can apply for one before the Brexit deadline here: https://www.gov.uk/eori

ª  If you import goods from the EU into the UK (including goods travelling through the EU from the rest of the world) register for Transitional Simplified Procedures (TSP) immediately: https://www.gov.uk/guidance/transitional-simplified-procedures

ª  Your EU Suppliers may well be supplying you under DDP (Delivered Duty Paid) – do you know whether or not they have the capacity or expertise to correctly complete customs declarations on these imports? Remember, HMRC regard you as being responsible for this in line with regulations.

ª  Consider whether you have the necessary resources & capacity (e.g. staff, storage, IT systems, etc.) in place and look to increase where required.

ª  Apply for Authorised Economic Operator (AEO) status, to reduce potential delays at UK Ports as well as taking advantage of mutual recognition schemes and faster customs clearances.

ª  Consider applying for an inland clearance depot such as a Customs Warehouse or ETSF; these will benefit your business in a ‘No-Deal’ scenario.

What benefits will applying for Authorised Economic Operator (AEO) certification give you and if it is appropriate to your business, how do you get it?

There are several benefits that we are told will eventually materialise; these are listed below – here are some actual benefits that you can get access to now:

ª  You can claim

o   Up to a 100% waiver against financial guarantees raised to cover potential customs debt, e.g. a Comprehensive Customs Guarantee (CCG) held to support a Customs Warehousing Authorisation

§  Large and small ports of entry into the UK get a significant benefit from this, especially as the National Frontiers Approval Unit (NFAU) will allow tenants based ‘on-port’ to operate off the back of the Port’s Temporary Storage Approval

o   Up to a 70% waiver against financial guarantees held to cover the actual debt, e.g. a deferment account & SIVA 

ª  The Government have stated that they want AEOC (Customs Simplifications) to become the ‘gate-way’ through to international trade authorisations, e.g. Inward Processing, Authorised Consignor, CFSP and Temporary storage. We are seeing Tenders asking ‘do you have AEO’ – it is recognised in 168 countries, including the U.S.A./CTPAT https://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat

ª  A reduced risk profile within CHIEF which, through HMRC’s algorithms, will reduce untimely interventions and sometimes costly delays when entering the UK.

ª  UK companies with AEO status account for around 60% of the UK’s imports and 74% of the UK’s exports.

Other potential AEO benefits that are being promoted by HMRC:  

HMRC are likely to extend a self-assessment approach to a business involved in international trade. Consultation is pointing towards AEOC being a mandatory requirement if an application for self-assessment is to be granted.

ª  Simplified Customs declarations and EIDR (Entry in Declarant’s Records)

ª  Priority treatment of consignments if selected for control

ª  The option of a centralised clearance self-assessment

ª  Removal of previous sales provisions relating to valuations

ª  Negotiating mutual recognition of Authorised Economic Operators (AEOs), enabling faster clearance of AEOs’ goods at the  border 

ª  Bilateral implementation of a technology-based solution for roll-on, roll-off ports which could consist of pre-arrival notification of consignments on a port IT system, linked to customs declarations and vehicle registration numbers so that vehicles were not required to stop at the border, enabling traffic to flow smoothly

How can I get AEO?

Go to www.vartanconsultancy.com/authorised-economic-operator-aeo

VARTAN Consultancy has assisted approximately 10% of the 910 legal entities currently holding AEO Certification as published on the EU Taxation & Customs Union database. We do not advise companies to make an application until we know that the process will be successful, working with HMRC Officers on behalf of the customer throughout the process.

Emphasis is placed on:

ª  Making sure all processes and procedures are in place and supported by related evidence before the assessment

ª  Reviewing your systems and, where required, take you through the steps necessary to develop your company procedures to an AEO standard. We will advise you on the best way to document and present your company procedures to achieve a successful outcome for your application

ª  We are present during the HMRC audits to provide support and expertise, and will be on hand to deal with post-audit matters

ª  Maintaining your procedures at the required level and ensure any system changes made by HMRC are established in your company processes so that reassessments go smoothly –the Assessing Officer will frown upon any updates not made, and your certification will be at risk

Our expert knowledge will help ensure your company has the correct policies, procedures and audit trails in place before submitting an application, leading to a positive audit by HMRC and a successful outcome to your submission to become an Approved Economic Operator.

Article by Miles Vartan Consultancy Ltd

Health & Safety specialist, standard accreditation assistance and preparation, operator licence compliance checks.