The chancellor, Jeremy Hunt, announced his Spring Budget yesterday (15 March) and reaction has been generally mixed, with some commentators calling it “not bold, but not bonkers”.
Importantly, the government also published a new package of customs measures alongside the budget, which are designed “to simplify customs import and export processes for traders, taking advantage of new freedoms following EU exit whilst at the same time upholding the UK’s high regulatory and security standards at the border”.
Although most of the measures are subject to industry consultation, the government has indicated that it is looking to simplify processes around customs declarations and authorisations.
The government’s statement also alludes to the introduction of new “voluntary standards for customs intermediaries”.
What’s in the package?
Customs declarations
The paper says that the government is “reviewing customs declarations requirements” for both exports and imports, including an assessment of the “potential scope for simplifications” for both “simplified and standard” declarations.
It says it will engage with traders and the border industry though “webinars, round tables and one-to-one engagement” across the second half of 2023.
Authorisations
Government said it will also seek to “streamline and digitise” the customs and excise authorisations currently offered by HMRC. This will include a reduction of the number of authorisations on offer – there are currently 42. The paper says the new authorisations will be “more facilitative”.
Part of this will involve categorising authorisations into five groups, with traders only needing to make a single application to gain access to all facilitations within a group. These groups are:
- Authorised Economic Operator (AEO)
- Fiscal
- Simplifications and declarations
- Transit
- Ports and wharves
Government says a new digital “self-serve portal” will allow traders to “apply for and manage their authorisations” and will “replace paper applications and give traders real-time updates”.
This new system will “reduce administrative burden” by adopting a “once and done” approach to data collection, whereby “traders will never have to submit the same information twice”.
The government says it will commence industry engagement on this project in March with delivery expected in the second half of 2023.
SCDP
In regard to the Simplified Customs Declaration Process (SCDP), it has announced three significant “improvements”. These are:
- Changing the date at which supplementary declarations are submitted for imports and exports to the 10th calendar day of the month following the goods movement
- This only implies to exports when there is more than one consignment of goods
- Changing the date at which final supplementary declarations are submitted to the 11th calendar day of the month after the goods movement
- Allowing traders to submit one ‘aggregated’ supplementary declaration for goods imported over the course of the month
Under SCDP currently, supplementary declarations are submitted on the fourth working day of the month following the goods movement, with a simplified declaration submitted before the goods cross the border. The simplified declaration has a reduced dataset compared to a full import or export declaration.
The government has said that it is going to “work with stakeholders separately to set out the timeframes for delivery” for these improvements.
Transit
The government is also looking to improve transit – the procedure through which traders can streamline customs requirements on goods moving across multiple customs borders to an end destination.
For outbound transit movements, improvements include:
- Making it easier for authorised consignors to start a movement at a client’s premises via a new “digital notification process”
- Making the 100% guarantee waiver the default position when authorising consignors, while “signposting” applicants to options for operating without a financial guarantee
- Clarifying how authorised consignors can initiate a transit movement from their own premises (or their client’s) when “exporting goods from standard export ports”
For inbound movements, improvements include:
- “Modernising the unloading process” for authorised consignees
- Clarifying how transit movements can be ended when goods are loaded on ships, trains and planes destined for stores
- Export declarations will be simplified in such cases
Industry engagement on transit improvements will take place in the summer before being delivered. The latest version of the New Computerised Transit System – ‘NCTS 5’ – is due to go live in November 2023.
Customs guarantees
Government also said it will look to enable certain facilitations to be authorised for traders without the requirement of a financial guarantee, saving traders on costs and time.
This will include further removing guarantee requirements for special procedures, temporary storage and duty deferment.
The government said it will begin “informal engagement, including via existing stakeholder working groups” in the spring
Voluntary code for customs intermediaries
Noting the feedback from traders in a 2022 consultation about the UK’s post-Brexit customs regime, which suggested “quality varies across the customs intermediary market”, the government has said it will run a three-month consultation in the summer on “introducing a voluntary standard for customs intermediary”.
It says this will improve “the overall quality of service provided across the sector”.
Advanced Valuation Rulings
Although not included in the aforementioned customs package, the government also published a policy paper on the day of the Spring Budget about ‘Customs Advanced Valuation Rulings’.
Advanced Valuation Rulings are legally binding decisions made by customs authorities regarding which valuation method a trader should use when submitting a customs valuation on a declaration.
There are six main methods for determining the customs value of an imported good, as outlined by the government here. The method used by a trader can impact the duty that is due on their imported goods.
The Spring Finance Bill 2023 will amend Section 24 the Taxation (Cross-border Trade) Act to establish “the system under which a customer may apply for an Advance Valuation Ruling for specified goods when they are imported into the UK”.
The ruling decisions issued by HMRC, “for the specified goods and scenario”, will be legally binding and will apply for three years, unless the ruling is withdrawn or cancelled.
The rulings “will provide certainty to customers on how to arrive at the customs value for their goods,” the government said. “Advance Valuation Rulings will, in turn, assist customers in the completion of customs declarations.”
How’s it going down?
Consulted
The package draws on views and insights gathered by government last year in its ‘Call for Evidence: An Independent Customs Regime’ consultation.
The Institute of Export & International Trade’s (IOE&IT) director general, Marco Forgione, said that he welcomed the fact that the views of the IOE&IT’s members had been heard.
“The changes announced in regards to customs facilitations are a positive move, but we need to understand the detail of what this actually means.
“The announcement of a further consultation around a voluntary code for customs agents is another positive move and something the IOE&IT would definitely endorse.
“We’d like to thank the IOE&IT’s members for all your help, support and input. We’ve fed your views into government, which has informed its thinking”.
Significant
IOE&IT director of strategic projects and international development, Kevin Shakespeare, also welcomed yesterday’s announcement and said the new customs package could have “significant implications” for traders.
“We’re really glad to see that many of the insights of our members, which the IOE&IT put forward in last year’s consultation, have been heard by the government.
“IOE&IT will continue to engage closely with government on how these new facilitations are implemented. The package could have significant implications for traders, simplifying many customs processes and enabling easier trade.
“We look forward to seeing more detail in the coming weeks and months, particularly as we are also expecting developments around the Target Operating Model and Single Trade Window soon as well.
“We will continue to update members about how customs processes and requirements are evolving, including through webinars, training and the IOE&IT Daily Update.”
IOE&IT is running a webinar about the new package of measures on Tuesday 28 March, which you can sign up to here.