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Animal Health are you ready for Brexit? Trader Readiness: Tariffs & Customs Presenter: Sarah Nightingale Please note: The content of this webinar is based on information provided by government and current at time of delivery


  1. Animal Health – are you ready for Brexit? Trader Readiness: Tariffs & Customs Presenter: Sarah Nightingale

  2. Please note: • The content of this webinar is based on information provided by government and current at time of delivery • Latest updates available on gov.uk • Webinar is funded by BEIS Business Readiness Fund • NOAH accepts no responsibility for any actions taken as a result of receiving this information

  3. Background (at 18 October 2019)

  4. Government information on preparing for a no- deal scenario can be found at: www.gov.uk/brexit It strongly advises all companies to answer the seven questions, which will then identify the advice that is available for your business. You can also sign up for email alerts.

  5. New UK status for trade with EU27: • Customs – are you ready? (Grants available) • VAT – postponed accounting on imports – exports to be zero-rated but proof of export required. Check rules in importing EU27 country, further information here: https://ec.europa.eu/taxation_customs/uk_withdrawal_en

  6. New UK status for trade with EU27: • Commodity codes - do you need a Binding Tariff Information decision (BTI)? • Tariffs on exported goods • Contract terms • Trade route information • Rules of origin • REACH - https://www.hse.gov.uk/brexit/reach.htm • Data flows and data protection (GDPR) (https://ico.org.uk/for-organisations/data-protection-and-brexit/)

  7. Commodity Codes • You’ll need a commodity code to make your customs declaration when you bring goods in or send goods out of the UK. • If you classify your goods correctly you’ll know what rate of duty and import VAT you should pay, and if: • the duty is suspended • you need a licence to move your goods • your goods are covered by: – the Common Agricultural Policy – anti-dumping duties – tariff quotas

  8. Commodity codes are listed in the UK Trade Tariff: https://www.gov.uk/trade-tariff • Based on international Harmonised System which groups goods into 98 chapters, arranged in 21 sections. Finding your commodity code can be complicated and you may wish to consult with HMRC: - Informal advice (3-day wait) - Legally binding advice (up to 60 days wait) stays valid for 3 years (BTI – Binding Tariff Information) Previous EU BTI rulings can be accessed here: https://ec.europa.eu/taxation_customs/dds2/ebti/ebti_consultation.jsp?Lang=en

  9. What about flea collars?? • Is it a collar? 4201000090: Saddlery and harness for any animal (including traces, leads, knee pads, muzzles, saddle-cloths, saddlebags, dog coats and the like), of any material (EU import tariff: 2.70%) • Is it a veterinary medicine? Chapter 30: Pharmaceuticals including those for veterinary use (https://www.gov.uk/guidance/classifying- pharmaceutical-products) • It is a pesticide: 380891: Further classified according to the active substance (EU import tariff: 6%)

  10. Some Government guidance on hard to classify goods: https://www.gov.uk/guidance/finding-commodity-codes-for- imports-or-exports#hard-to-classify-goods • Pharmaceuticals: https://www.gov.uk/guidance/classifying-pharmaceutical- products • Organic chemicals: https://www.gov.uk/guidance/classifying-organic-chemicals

  11. Key chapters for animal meds • Chapter 28: Inorganic chemicals; organic or inorganic compounds of precious metals, of rare- earth metals, of radioactive elements or of isotopes • Chapter 29: Organic chemicals • Chapter 30:Pharmaceutical products • Chapter 38: Miscellaneous chemical products

  12. Import from EU • You need a UK EORI (Economic Operator Registration and Identification)number for imports into (and exports out of) UK (it will have 12 digits and start with “GB”) • Decide how you will fill in import declarations • Check your commodity code • Look at Customs facilitating procedures • If using TSP set up duty deferment account • Are your goods “standard” or “controlled” goods

  13. Transitional Simplified Procedures (TSP) declaration process for standard goods Before the goods enter the UK • You’ll need to record: • your unique reference number for the consignment • a description of the goods and the commodity code • the quantity you’ve imported • purchase and (if available) sales invoice numbers • the customs value • delivery details • supplier emails • serial numbers of any certificates or licenses

  14. TSP declaration process for standard goods After the goods enter the UK • Update records with date and approx. time goods arrive in UK • Submit a supplementary declaration by the fourth working day of the following month ( HMRC will allow up to 6 months before you need to start making supplementary declarations from 1/11/2019 ) For further information, see HMRC flow chart for TSP through RoRo locations

  15. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/ file/833337/How_to_import_goods_from_the_EU_into_the_UK_through_roll_on_roll_off__RoR o__locations_after_Brexit.PDF

  16. Government-secured freight capacity (GSFC)– Category 1 goods include: • All vet meds authorised under the Veterinary Medicines Regulation 2013, including finished and unfinished products, and Active Pharmaceutical Ingredients (for import and export) • Also, unauthorised medicines permitted for import under the VMD's Special Import System

  17. Tariffs on import • UK Government has published its Temporary Tariff Regime (TTR), updated on 8 th October • 88% of imported goods will enter UK duty free • Tariffs for sensitive sectors (agriculture, ceramics, fertiliser, automotives) and where preferential access for developing countries is beneficial (textiles)

  18. Temporary Tariff Regime (TTR) • To apply for 12 months • Government to monitor closely • Exceptional Review Process announced in October – online feedback form • Full consultation on permanent approach to tariffs from January (business, interest groups and consumers)

  19. In the long term, UK tariffs will be limited by UK WTO commitments

  20. In the long term, UK tariffs will be limited by UK WTO commitments

  21. Export to EU • Decide if you or an agent will make the declarations • If you do, you need to buy specialist software to make declarations online using the National Export System (NES) • Register for the National Export System (NES) • Ensure your EU importer has an EU EORI number • Complete a combined Export and Exit Summary Declaration using NES • Ensure the driver has a Movement Reference Number (MRN) for the country where the goods enter the EU • If goods are moving through different countries look at transit procedures and consider registering for the New Computerised Transit System (NCTS)

  22. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/ file/833339/How_to_export_goods_into_the_EU_through_roll_on_roll_off__RoRo__locations_af ter_Brexit.pdf

  23. Customs procedures • Customs freight simplified procedures – need an agent or direct HMRC authorisation • Inward processing relief – suspension of customs duty and import VAT while goods are being processed. You only pay duty and VAT when goods are released into free circulation • Outward processing relief : If you temporarily export goods for processing you can claim full or partial duty relief from UK customs duty when you reimport the goods in their processed form • Transit - The UK is a member in its own right of the Common Transit Convention. You need to register for the New Computerised Transit System (NCTS) to make transit declarations and provide a guarantee.

  24. Other issues to consider: • Currency fluctuations • Wooden pallets • Longer term customs authorisation, e.g. Authorised Economic Operator (AEO) status (can take up to a year for approval) • Future trade deals and mutual recognition agreements • Opportunities from moving away from EU regulation?

  25. Further NOAH Brexit activities ( https://www.noah.co.uk/focus-areas/brexit/) 1. Veterinary Medicines – Regulatory & Pharmacovigilance Webinar on 21 st October https://www.noah.co.uk/animal-health-brexit-ready-free-webinars-noah-help-animal-health- businesses-prepare/ 2. Animal health: are you Brexit ready? Regional seminars from NOAH to help animal health professionals prepare: Birmingham 21 Oct Newport 22 Oct Edinburgh 24 Oct Belfast 25 Oct https://www.noah.co.uk/animal-health-brexit-ready-regional-seminars-noah-help-animal-health- professionals-prepare/

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