Whilst 2023 is already well underway, it is important to consider the important milestones relating pending UK import and export measures that 2023 holds.
These milestones should be considered and addressed appropriately to avoid disruption of trade flows in and out of the UK. CDS export Exporters will have more time to move across to the new Customs Declaration Service (CDS).
The planned date of the 1st April 2023 no longer applies and traders now have until 30th November 2023 to continue using the CHIEF system for export declarations. CDS for exports will be introduced in a phased approach and the key phases are: › From late February 2023 – export declarants that only move goods through ports in the UK that use the Goods Vehicle Movement Service (GVMS) – also known as non-inventory linked ports.
› From May 2023 – export declarants that currently use the National Export System (NES) web service to submit export declarations on CHIEF
› From September 2023 – export declarants using inventory-linked ports and DEPs
› From 30 November 2023 – All export declarations must be made using CDS Import controls The Government previously announced that the changes to import controls on certain products coming from the EU would not be introduced on 1 July 2022 as planned. These import controls now have a target launch date of end of 2023.
The list of controls that are now planned to be introduced by the end of 2023 is:
› A requirement for safety and security declarations on EU imports
› A requirement for health certification for further Sanitary and Phytosanitary (SPS) imports
› A requirement for SPS goods to be presented at a Border Control Post (BCP)
› A requirement for SPS currently at destination to be moved to a BCP
› A requirement to issue Certificates of Inspection (COI) for organic imports
› A requirement for organic imports to be presented at a BCP
› Prohibitions and restrictions on the import of chilled meats from the EU
UKCA marking
The UKCA marking is the product marking used for products being placed on the market in Great Britain. The UKCA marking applies to most products for which the European CE marking could be used and would have become required per 1 January 2023.
To provide businesses with some flexibility, the UK government will bring forward legislation that continues to allow recognition of the CE marking for most goods that are being placed on the market until 31 December 2024.
It should be noted that UKCA marking is already available and can be used.
Conclusion
Importers of products from the EU currently benefit from the relative flexible UK import controls measures, at least until the above listed restrictions come into play. It is however pertinent that the UK and EU come to some sort of mutual recognition on the import controls topics to ensure a continuation of the market access for all goods.
With the agreement on 27 February 2023 relating the Northern Ireland situation (The Windsor Framework), the EU and the UK have made a first step to a closer relationship.
The expectation is that this also opens up the opportunity for further cooperation on some of the above mentioned topics, including the import controls. Nevertheless, the expectation is that some of these topics will not be resolved before the provided timeframes and further disruptions and increase in cost for doing business in the UK are still expected.
Contacts
For any questions, please feel free to contact:
Arjen Odems, odems@cutraco.com
Maartje Meijer, meijer@cutraco.com