Trade

December 2018

Trade

Reports commissioned by the Government and undertaken by the ESRI/ Department of Finance and by Copenhagen Economics, provide evidence to demonstrate that the macroeconomic and trade implications for Ireland of a no deal Brexit will be pronounced with differentiated impacts on certain sectors and companies, depending on their level of exposure to the GB market. New checks and controls on British trade (including both exports and imports) and connectivity issues will impact in different ways and are addressed in Section 12 above. VAT and excise would arise on goodsimports.

In addition, under a no deal scenario Irish businesses will see future Irish UK  trade subject to tariffs. The tariffs that the EU have registered with the WTO would be applied to goods being traded between the UK and the EU. It is important that companies are aware that tariffs vary significantly across product type. As part of any Brexit planning strategy, companies should assess their potential tariff exposure. InterTradeIreland’s ‘Brexit Tariff Checker’4 enables companies to identify tariff rates associated with a wide range of products.

The impact of UK import and export exposure for firms could be compounded by currency volatility (depending on the extent to which a no deal has been factored in to the current value of sterling). The Department of Business, Enterprise and Innovation has recently published guidance for managing
currency risk.

It is important to recall that many of the preparations and measures required to  address an agreed central case Brexit scenario also apply in the no deal context but would need to take place at a much faster pace.

Businesses have already been planning and preparing for Brexit and the change it will bring. The Government has put in place a comprehensive suite of supports to help businesses, of all shapes and sizes and across all sectors of the economy, to prepare for Brexit. These supports are aimed at assisting
business in all scenarios, including a no deal scenario.

To help businesses prepare for a new post-Brexit trading regime, Revenue has  participated in a number of trade sector and Government organized Brexit preparedness events. Revenue has a dedicated Brexit portal on their website, which acts as a key support for trade.In order to intensify and extend engagement with the trade, Revenue have developed a comprehensive Trader Engagement Programme to assist trade in preparing for the impact of Brexit.

The target audience have been identified as the following three key groupings:
 Logistic Companies
 Large Economic Operators
 Other Economic Operators

Letters have issued to the Logistic Companies and Economic Operators (with VIES (VAT Information Exchange System) returns of over €250,000 in 2017) advising them on steps they can take to prepare for Brexit and inviting them to participate in one of the Customs Brexit Information seminars. 9,505 letters
issued on 26 November and 3,924 issued on 14 December – 13,429 businesses in total. Letters will issue to approximately 70,000 other Economic Operators in mid-January 2019, advising them of ways to prepare for Brexit and encouraging them to engage with their supply chain partners and customs brokers or agents.

These seminars will run as follows:
 Monday 3 December 2018 – Dublin
 Monday 10 December 2018 – Cork
 Tuesday 15 January 2019 – Galway
 Tuesday 22 January 2019 – Dundalk
 Thursday 24 January 2019 – Dublin
 Wednesday 30 January 2019 – Wexford
Other venues will be confirmed for February 2019.

These seminars focus on:
 Providing information and practical support to relevant businesses
 The basic principles underpinning and requirements of customs formalities for non-EU trade and how and where they apply, including import, export and transit formalities
 The supply chain challenges associated with different types of goods, including whether the goods are being distributed on arrival or brought to a warehouse/temporary storage facility
 Controls related to tariffs and prohibitions and restrictions
 Operation of the UK landbridge and transit arrangements
 Other Government agency controls applying to the movement of goods, including controls relating to the importation of animals, plants andproducts of animal and plant origin, medicines and environmental health

The format of the seminars, included presentations from Revenue in relation to Brexit and its impact, covering customs procedures and the potential facilitations available. The Department of Agriculture, Food and the Marine also provide information on SPS controls and the implications to business post
Brexit.

Revenue are meeting with customs brokers/agents to advise them in relation to Brexit preparedness and work Revenue has been undertaking. It will outline the information we have included in the letter to other economic operators to ensure they understand the requirements of these businesses.

As part of its Brexit business supports Enterprise Ireland is now offering customs training through its Customs Insights Course. The course aims to help businesses understand the key customs concepts, documentation and processes required to operate post Brexit. The course aims to provide participants with a firm understanding of customs, the implications for their business and the options from Revenue that are available to make the customsprocess more efficient.

 

July 2019

Trader Customs Requirements, Education and Supports

The macroeconomic and trade implications for Ireland of a no deal Brexit would be pronounced, with differentiated impacts on certain sectors and companies. New checks and controls on British trade (including both exports and imports) will also impact trade. VAT and excise would arise on goods imports. In a no deal scenario, Irish-UK trade would be subject to tariffs and duties.

The Government has put in place a number of measures to advise and support businesses to prepare for new customs requirements in a no deal scenario:
 Revenue wrote to over 80,000 businesses in January 2019 outlining the steps required to trade with the UK post-Brexit;

 Revenue together with DAFM and the HSE held a series of trader engagement seminars to inform traders of customs / official control requirements post-Brexit

 From January – 19 June 2019, more than twice as many businesses (6,885) registered for EORI numbers than in all of 2018 (6,885 vs 2,976)

 Government has put in place a comprehensive suite of supports to help businesses, of all shapes and sizes and across all sectors of the economy, to prepare for Brexit;

 Last December, Enterprise Ireland launched online customs training to help businesses to prepare for their customs obligations. This free online course covers both import and export procedures;

 The LEOs rolled out a Customs Programme across the country in early 2019 with over 500 participants to date;

 Departments and agencies have reached out to businesses and representative bodies to assess levels of preparedness. In general, large companies are well prepared but SMEs need to take the necessary steps to prepare for Brexit;

 Advice for traders was published on gov.ie/brexit;

 Specific engagement with the grocery retail and distribution sector to ensure continuity of supplies.

Despite this level of activity, and increased levels of awareness amongst businesses, the Government remains concerned about the levels of business readiness for a no deal scenario. While recognising the cost and other pressures facing businesses, especially small businesses, the Government believes that effective operation of trade, including the landbridge, will only be possible if there is a significant step-up in preparedness activity. Government’s focus in the coming months will be on supporting and encouraging businesses to prepare.
There are many steps that businesses can take to prepare that are cost-free. Supports are available should preparedness work require financial investment by businesses. These steps should be taken by all businesses who trade with the UK, including Northern Ireland.

As outlined in the introduction, Ireland is engaging with the Commission on how trade would work on a North-South basis in a no deal scenario. While this engagement is not yet complete, it is clear that the current seamless and frictionless arrangements for trade on the island of Ireland could not continue in a no deal scenario, as the UK would immediately be outside the EU Single Market and Customs Union.

Since 3 April 2019, changes to the employment permit system for workers from outside the European Economic Area will now allow an additional 300 workers to come to Ireland to fill positions in the area of customs procedures and controls. This will mitigate some of the increased demand for these skills in any Brexit scenario.
Despite this measure there is a significant risk that there will not be enough capacity in the customs agents sector in the period immediately following a no deal Brexit. The Government has engaged with the Customs Consultative Committee with a view to identifying a series of targeted measures that will be taken to support and incentivise capacity-building in the customs intermediary sector.

Relevant departments and agencies are engaging with the banking sector to ensure that traders have access to appropriate bank guarantee facilities in order to avoid having to immediately pay duties on goods entering Ireland from the UK.

Next Steps

Between now and 31 October, Government actions will include the following:
 Revenue will undertake an intensified and individual business focused engagement programme designed to support and assist those individual businesses to understand the potential impact of Brexit and how to prepare for and mitigate the risks. This will include individualised letters to issue to each trader on a phased basis starting in July with a follow up phone call by Revenue staff in July/August. A dedicated number will be provided on the letters to enable traders to contact a dedicated Revenue support team.

 EORI registration is the critical first step in preparing for Brexit. However, using the individualised letters and associated follow up calls, Revenue will highlight other steps necessary to prepare for Brexit, especially relating to customs declarations, classification and other obligations relating to guarantees, authorisations and if required, third-party licencing. Department of Agriculture, Food and the Marine will continue to engage with relevant traders to ensure that they are registered on the EU Trade Control and Export System (TRACES).

 Government departments and agencies will further engage with trade representative bodies in preparing businesses for Brexit.

 Seminars offering advice and support for companies organised by government departments and state agencies will continue to take place nationwide.

 The government communications campaign will focus on encouraging and facilitating businesses to take action on getting Brexit ready.
Between now and 31 October, all businesses that trade with the UK, including Northern Ireland, need to take important steps to prepare for Brexit; many are cost-free and supports are available should preparedness work require financial investment by businesses. Steps that can be taken now by businesses include:
 Ensure they have an EORI number if they trade with the UK.  Review their supply chain.

 Make contact with their UK suppliers.

 Check to see if their suppliers use the UK as a landbridge.

 Check if their business relies on products or services that are certified for compliance with EU standards by a UK body.

 Determine their customs declaration processes, build internal expertise and install relevant software or secure the services of a customs agent.

 Register with the Department of Agriculture, Food and the Marine or the Environmental Health Service of the HSE (for food of plant origin) for goods/products subject to SPS controls.  Engage with any trade representative body of which they are a member.
 Avail of the Government’s range of advisory and financial supports.