I am a UK exporter – what do I need to know about the steps the EU importer needs to take?

Importing GB to EU via RoRo Ports

Step 1 – Does the EU importer need to be registered?
Every business importing goods into the EU will need to have an Economic Operator’s Registration and Identification (EORI) number from a customs authority in the EU. After the transition period only EORI numbers issued by an EU Member State will be acceptable in the EU.

Importers will need to have an EU EORI number even if they use a forwarder or customs agent for import declarations.

A business can apply for an EORI number from customs authorities across the EU. https://ec.europa.eu/taxation_customs/national-customs-websites_en

Step 2 – Should I agree trading terms and conditions with the EU importer or their agent in advance?
The UK exporter and EU importer should agree terms and conditions so that the responsibility for tariffs, duties and border formalities is clear.

The International Chambers of Commerce create and publish a standard set of trading terms and conditions for traders who are buying, selling, transporting, and clearing goods. It is important to determine which party will be responsible for any consequences of customs checks, and who will be financially responsible in case of any issues.

Step 3 – If I am exporting controlled, restricted or prohibited goods, what do I need to do to prepare my goods for import into the EU?
Certificates or licenses will be required to import certain goods and types of products into the EU. This includes food and feed, live animals, endangered species, dual-use goods, drugs and chemicals. Certificates will need to be applied for at least two weeks in advance (time limits may vary between EU Member States).

EU Authorities will need to be pre-notified about the arrival of some goods and the relevant licences or certificates will need to accompany the goods.

High risk food and feed products entering the EU must be pre-notified. High-risk food not of animal origin (FNAO) does not have to be pre-notified but may be subject to additional checks. A consignment of live animals or animal products can only enter the EU if it has satisfactorily undergone the specific checks and a Common Health Entry Document (CHED) is issued from the TRACES-NT system (Trade Control and Expert System).

The EU Border Control Point (BCP) will need to be notified that the consignment is arriving – this notification is done by using the TRACES-NT system. Check with the Commission guidance on BCPs for all the requirements including how much notice needs to be given. The business responsible for moving the goods should check that the BCP at the Port of EU entry accepts the goods being imported.

The link to the current locations and authorisations of BCPs in the EU27 is here https://ec.europa.eu/food/animals/vet-border-control/bip-contacts_en

Endanered specimens listed in the Convention on International Trade in Endangered Species or Wild Fauna and Flora (CITES) must move via a CITES designated Point of Exit, a list of these can be found here : https://www.gov.uk/guidance/trading-cites-listed-species-through-uk-ports- and-airports-after-brexit

Step 4 – If I am exporting animals or animal product, what do I need to do to prepare my goods for their import into the EU?
An Export Health Certificate (EHC) will be required, this is an official document that confirms an export meets the health requirements of the UK. The certificate must be signed by an official veterinarian (OV) of the competent authority in the exporting country (UK). A completed EHC is required for each type of animal or animal product being exported from the UK to the EU. If a consignment includes a mix of products, a separate EHC will be required for each type of product. If the specimen is covered by CITES, you will need to arrange the appropriate documentation. Check here for guidance: https://www.gov.uk/guidance/cites-imports-and- exports

The transporter of the goods must carry the necessary certificates and licenses so they can be presented at the border if requested.

Step 5 – Has the EU importer (or their agent) pre-lodged the customs import declaration(s) or entered the transit movement onto the New Computerised Transit System (NCTS) and completed the relevant safety & security (Entry Summary Declaration– ENS) entry on the Import Control System?
All goods being imported into the EU will need to have pre-lodged a national import customs declaration into the EU Member States’ systems, or a transit entry into the EU New Computerised Transit System (NCTS), both of which produce a Movement Reference Number (MRN).

The importer or their agent must submit the customs declaration into the Member State’s customs system or into NCTS for transit movements, and that entry produces either:

·         A customs declaration (import) document from which the MRN is generated

·         A Transit Accompanying Document (TAD) which again generates the MRN

·         A combined Transit (Security) Accompanying Document (TSAD) / MRN (this option may not be available in some Member States for a few years)

This pre-lodged declaration produces the MRN for customs declarations or transit movement. It is needed by the haulier to present at the UK border. It is a number and a bar code.

A separate safety and security / entry summary declaration (ENS) must also have been entered onto a Member States’ Import Control System (ICS).

Step 6 – What is the procedure if I am moving goods subject to excise duty?
The e-AD (electronic Administrative Document) covers the movement of excise goods in the EU only and allows them to move within the EU27 in duty suspension.

The goods will have to first be imported from the UK into the EU. When importing excise products, an EU Import Declaration will be required and excise and other duties will need to be paid.

Once the goods cross the border into the EU, if they are subject to excise duty (alcohol, tobacco, oils) and are moving in duty suspension, they will move across the EU on the electronic accompanying document (e-AD).

The process below sets out how excise goods circulate between Member States.

·         The eAD is validated in the Member State of dispatch. A European register of operators (SEED) is used to check the excise numbers of the consignor and consignee.

·         The eAD is electronically transmitted by the Member State of dispatch to the Member State of destination.

·         The Member State of destination forwards the eAD to the consignee

·         The consignee submits a “report of receipt” once he/she has received the excise goods. This report should mention any anomalies, such as shortages or excesses in the consignment.

Step 7 – The importer (or their agent) has contacted me to say that the goods are being selected for a check at the border – what does this mean?
Once an import declaration and associated data has been pre-lodged to the administrations, the various authorities in the Member States will risk assess that data – and they may select the consignment for a check on the documents and / or the goods.

The status of the pre-lodged declaration will change to “arrived” once the risk analysis has been performed by the administrations. A percentage of consignments will be selected inspection of the goods and/or paperwork.

Documentation for CITES specimens require 100% checks at the border, relevant documentation must be presented to Border Force on exiting the UK.

Step 8– The goods are going to a different country from the Port or terminal of arrival, can the importer clear them in the country of arrival and then move them?
The importer and exporter can agree to move the goods in the following ways:

Option 1:

A transit declaration issued in the UK and continues up to final destination (or to an agreed destination in EU) using the Common transit procedure.

Issuing a transit up to an EU border may not be an option because it would mean the truck would have to stop and getting the necessary guarantee in place and this could be an issue for some companies.

Option 2:

An EU pre-lodged transit declaration issued in by an EU company using the Union transit procedure

Option 3:

A pre-lodged import declaration issued in the country of arrival by an EU company (the EU company needs an authorisation from the country of arrival).

The barcode of the MRN for all of these options would have to be sent to the driver before crossing.

EU Ports / Terminal Requirements

RoRo Ports – France

The SI Brexit system

The SI Brexit system is designed to prioritise fluidity of freight in and out of France.

The SI Brexit system is an interface between the carriers at French Ports and the Eurotunnel terminals and the French customs declaration service.

·         The “envelope” function within SI Brexit allows traders and hauliers to consolidate multiple consignments under a single “declaration” and allow the haulier to present one single MRN.

·         The trader, agent or haulier downloads the application either from the douanes website (link) or via the operator, and the barcodes of the MRNs are scanned, paired with the data from the number plate of the truck and the paired data is sent to the Customs DELTA or Transit NSTI systems for risk analysis and clearance.

·         If the trader is using an electronic data interface (EDI), the data entry for all consignments will be automatically changed to “arrive” when the ferry or train sets off. A notification will be sent to the declarant for approval of advance declarations, and there will be a limited timeframe to approve this.

·         If the trader is not using an EDI, they must wait for the message telling them that the ferry or shuttle has left the UK – and then manually validate the declaration to arrive, this is not automatic.

·         The carriers will display information on the crossing that identifies trucks that are selected for checking on arrival in France.

More information can be found here: https://www.douane.gouv.fr/fiche/entreprises-preparez-vous-au-brexit https://www.douane.gouv.fr/dossier/french-customs-business

https://www.douane.gouv.fr/sites/default/files/uploads/files/Brexit/Other_languages/customs- guidelines-preparing-for-brexit-january-2020.pdf

Further information on goods imported into the EU via France can be found at:

https://www.brexit.gouv.fr/files/live/sites/brexit/files/contributed/Documents/SPS%20Controls%2 0for%20goods%20imported%20from%20the%20UK%20to%20the%20UE%20via%20France.pd f

Netherlands

RX SeaPort is a digital system that joins up the data submitted and required by all parties at the Port of Zeebrugge. The data is registered for imports and exports through their e-Desk. This can be done manually, through a linked data connection or through customs software.

Drivers will not be allowed to proceed to the Zeebrugge Terminal if customs declarations have not been pre-notified through the e-Desk of the RX Seaport system. Information on pre- registration of customs data via the e-Desk can be found at

Further information on importing using RX Seaport can be found at https://rxseaport.eu/en/import-wizard/

Rx Seaport (for Antwerp)

The pre-notification of customs documents in Antwerp is done via the Port Community system of C-point. This pre-notification can be lodged by the exporter. Also, the forwarder, customs agent and transport company are able to submit a pre-notification.

For this an account is needed on C-point. Customs agents often link their customs software to this platform in order to automate this flow.

Information on customs procedures at Antwerp can be found at: https://www.c-point.be/en/services?search[service_category][0]=Customs Additional information can be found at https://www.nxtport.com/

RoRo Ports – Spain Teleport 2.0

Ports in the South of Spain, such as Algeciras Port Authority, use the integrated technology platform Teleport 2.0. A similar integrated IT system will soon be rolled out to the northern ports of Santander and Bilbao.

Teleport 2.0 aims to obtain a seamless integration of the port throughout the logistic chain. The system will support all the services encompassed by the logistics chain and make them available to the port logistics community, including integrated services for the vessel’s management, services for notification of dangerous goods and export declarations, and

integrated service for cargo trucks.

The information service element of Teleport 2.0 will provide complete traceability to importers and exporters of the cargo throughout the logistics chain, and those who register can trace their goods via the online e-service – http://www.ttialgeciras.com/en/e-service/

More information on teleport 2.0 can be found at https://innovacion.apba.es/en/teleport-2-0/

More information on import and export in Spain can be found at: https://www.agenciatributaria.es/AEAT.internet/Inicio/La_Agencia_Tributaria/Aduanas_e_Impue stos_Especiales/_Presentacion/Procedimientos_y_gestiones_en_la_Aduana/_EMPRESAS_Y_ PROFESIONALES/Entrada_y_salida_de_mercancias/Entrada_y_salida_de_mercancias.shtml

RoRo Ports – Ireland

All forms of customs declaration for import to Ireland must be lodged electronically through the AEP system.

The AEP system handles the validation, processing, duty accounting and clearance of customs declarations. The system also checks the data format, validations and prohibitions and restrictions, and verifies that sufficient credit is available in a trader’s account before clearing the declaration and allowing release of the good.

You will find further information about AEP in the AEP Trader Guide and Appendices on the Revenue website Customs Electronic Systems.

In November 2020, Revenue will implement a new National Import system that will replace AEP for Imports only. Further information about the new Automated Import System (AIS) can be found at https://www.revenue.ie/en/customs-traders-and-agents/customs-electronic- systems/ais/what-is-ais/index.aspx

Pre-approval for DTI

Any trader who wishes to make an import declaration themselves must first be pre-approved by the AEP Accounts Unit for what is known as Direct Trader Input (DTI). DTI users communicate with the AEP System via Revenue’s On-Line Service (ROS) and require a digital certificate obtainable form ROS.

The AEP System operates on an almost 24 hour basis.

·         Further details on how to apply for the DTI facility can be found at https://www.revenue.ie/en/customs-traders-and-agents/customs-electronic- systems/aep/direct-trader-input.aspx

The AEP Trader Guide contains instructions for users of the AEP system. – https://www.revenue.ie/en/customs-traders-and-agents/documents/electronic/aep-export- trader-guide.pdf
A guide to Customs Import Procedures – https://www.revenue.ie/en/customs-traders-and- agents/documents/electronic/aep-import-trader-guide.pdf

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