As part of its no-deal Brexit preparations, HMRC has automatically issued some 80,000 businesses with Economic Operator Registration and Identification (EORI) numbers. This has been done because of increasing concern that businesses that have previously only traded within the EU may still be unaware that an EORI number is essential to import or export goods after Brexit. After Brexit, all movements to and from the European Union will be treated as Imports or Exports and, if the UK leaves the EU without a deal, all post Brexit trade in goods with the EU will require an EORI number.
The EORI registration is a standard procedure and should not be confused with the Authorised Economic Operator (AEO), which is a different scheme with very different benefits and requirements.
HMRC has previously written to the businesses they think may be affected, but the number of applications for EORI numbers still fell well short of the numbers that HMRC was expecting. This is why they have gone one step further and simply issued numbers to those they think need them.
The move by HMRC is very welcome and may reduce difficulties immediately following the UK’s departure from the EU. It is probable however, that some businesses have been missed out so we would recommend that all businesses that trade goods with the EU check that:
- They already have an EORI number in the UK; or
- They have just received a letter from HMRC explaining the auto enrolment and showing their EORI number; or if not
- They should apply for an EORI number as soon as practical.
Businesses that have not previously carried out Brexit planning may also want to take the time to review these top 5 checks:
- Make sure that you have an EORI number as, without it, you will not be able to trade goods with any country outside the UK – if you attempt to import goods into the UK without an EORI number your customs entry may be rejected by HMRC and your goods will not be allowed into the UK.
- Make sure that your teams understand how to move goods to and from the EU after Brexit and how the various rules apply to your particular goods – NB. There are special procedures for some types of controlled goods
- Consider applying for the Transitional Simplified Procedure (TSP), as this will make moving goods easier and provide a cash flow advantage on any duty payable – it is also important to familiarise your team with how to operate TSP before Brexit.
- Check whether your exports/imports are liable to duty – note that the UK has announced a unilateral temporary tariff for goods coming into the UK, but not all duties have been suspended. Goods moving from the UK to other member states will fall under the standard EU tariff. If you are obliged to pay duty then make sure that you are able to do so and have access to a deferment account (yours or your freight forwarders).
- Trace your supply chain and consider whether there are any possible VAT/Duty implications following Brexit. For example does it lead to an overseas VAT registration requirement, will you lose an EU VAT simplification or will you end up paying customs duty twice?
For more information please check the information on BDO’s Brexit Planning for Business site. It is clear however, that the pace of change is increasing so we would also suggest that businesses monitor news outlets and the HMRC guidance pages on the gov.uk website for potential changes.
The following BDO information may also be useful:
Brexit: the no deal plan for customs declarations
BDO Insight: Brexit: Government releases tariff with details of customs duty rates
BDO Hard Brexit Trade Assessment
BDO Insight: Why Authorised Economic Operator status is essential for manufacturers with non UK supply chains
BDO Insight: Brexit - Government sets out its no-deal plan for VAT