United Kingdom Revises Timeline for Phased Implementation of Border Controls

brexit jigsaw

Since January 1 2021 the United Kingdom is no longer a part of the European Union, which means it is also no longer part of the EU’s Single Market and Customs Union.  

In contrast to the European Union, the British Government has opted for a phased approach to the implementation of import controls. April 1st the next phase of this implementation was supposed to start, but this has now been postponed. 

Changes to the Original 3 Phased Plan 

The UK approach is based on a 3 phased plan. The first phase, which started on January 1st 2021 imposed customs checks on controlled goods, such as alcohol and tobacco, live animals, and high-risk plants. For other products, there is a transition period in which companies get time to get used to the upcoming checks and tariffs and implement the necessary processes. Companies still need to keep records. This period has been extended from 6 months to 12 months until January 1 2022. 

In the original schedule, checks would also be done on all products of animal origin as of April 1 2021. Plants and plant products would also be subject to checks. These checks will require pre-notification. This date has now been moved to October 1 2021. As of March, there will be checks on live animals and low-risk plants and plant products.  

As of July 1st, all goods would be subject to customs declarations and tariffs when importing them into the United Kingdom. 

The New 3 Phased Plan 

Michael Gove, the Minister of the Cabinet Office, has released a statement last week stating the following: 

We are therefore announcing today a clear revised timetable for the introduction of controls, as follows: 

  • Pre-notification requirements for Products of Animal Origin (POAO), certain animal by-products (ABP), and High-Risk Food Not Of Animal Origin (HRFNAO) will not be required until 1 October 2021. Export Health Certificate requirements for POAO and certain ABP will come into force on the same date. 
  • Customs import declarations will still be required, but the option to use the deferred declaration scheme, including submitting supplementary declarations up to six months after the goods have been imported, has been extended to 1 January 2022. 
  • Safety and Security Declarations for imports will not be required until 1 January 2022. 
  • Physical SPS checks for POAO, certain ABP, and HRFNAO will not be required until 1 January 2022. At that point, they will take place at Border Control Posts. 
  • Physical SPS checks on high-risk plants will take place at Border Control Posts, rather than at the place of destination as now, from 1 January 2022. 
  • Pre-notification requirements and documentary checks, including phytosanitary certificates, will be required for low-risk plants and plant products and will be introduced from 1 January 2022. 
  • From March 2022, checks at Border Control Posts will take place on live animals and low-risk plants and plant products. 

Companies importing controlled goods into the United Kingdom will not be eligible for any deferred declaration approach. Because of the nature of these goods, they will need to complete a full customs declaration. 

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