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Planning for a ‘no deal’ Brexit: Trade and customs

30 January 2019
For many businesses, putting in place comprehensive and effective plans for a ‘no deal’ will be a difficult, if not impossible task. There are so many uncontrollable variables, with limited clarity on how many of these issues would be managed by EU and UK authorities.
New customs checks and tariff barriers would be introduced, aviation, road haulage and ferry links would likely be affected, how excise and VAT is levied would change, and big questions over the status of financial services trade, contracts and data flows would arise. How the Ireland/Northern Ireland land border would be treated is not clear. All these issues would have wider knock on implications for growth and consumer confidence, with some sectors and regions particularly affected.
The most immediate and acute ‘no deal’ problems would likely arise around the transport of goods between the UK and Ireland. In the case of a no deal scenario, goods entering the Ireland from the UK would be treated as imports from a third country and goods leaving Ireland to the UK will be treated as exports. All relevant EU legislation on imported goods and exported goods will apply, including the levy of certain duties and taxes (such as customs duties, value added tax and excise on importation), in accordance with EU commitments under the rules of the WTO.
The below resources will help you find the information you need:

1. Review the Ibec/Accenture Brexit guide, including its practical toolkit
2. Visit the Brexit section of the Irish Revenue Commissioners website and email brexitqueries@revenue.ie for clarification on issues specific to your business
3. Identify the potential WTO tariff code and tariff rate of your products
5. Read UK Government’s guides for business on preparing for a ‘no deal’ Brexit
6. Read the ‘no deal’ Brexit preparedness notices from the European Commission and UK government
6. Take the online training course from the European Commission on the Economic Operators' Registration and Identification (EORI) system
7. Participate in the Enterprise Ireland online Customs Insights Course - free to all companies.
8. Understand your business’ requirements on standards and certifications with the Brexit factsheets from the National Standards Authority of Ireland. The British Standards Institution also has information about UK product standards and certifications.
9. Revise the new tariff rate quotas (TRQs) for agrifood imports included in the EU’s revised WTO schedule and the UK’s proposed schedule of commitment under the WTO’s GATT and GATS (bearing in mind they must be negotiated with WTO before become being confirmed).
10. Ensure your company has the skills to manage Brexit by visiting the dedicated webpage on upskilling from the Department of Business, Enterprise and Innovation.
11. Avail of customs reliefs offered by Revenue, including inward and outward processing and deferred payment authorisations, through the Customs Decisions Systems (CDS).
12. Know who in your supply chain has responsibility for what tasks, costs and risks in the national and international transport and delivery of your product by consulting the Intercom rules 2010.
13. Apply for Authorised Economic Operator (AEO) status to benefit from simplified trade facilitation.
Upcoming event:

Please note that the next Revenue Customs Brexit Information Seminar takes place on the 20th February 2019 in Dublin Castle. This seminar is targeted at the large economic operators and logistic companies / freight forwarders so please highlight this to any of your members operating in this space.

Registration can be completed here: https://www.revenue.ie/en/customs-traders-and-agents/brexit/brexit-seminars/index.aspx