UK Border 2020 : preparedness (UK)

Civil service evidence given to MPs (select committee) yesterday expresses growing confidence that — contrary to recent predictions from industry groups — preparations would be completed on time for the new UK-EU trade border that will come into force on January 1, including computer systems, lorry parks, customs agents and vets required to complete export declarations to the EU.

The link is here.

Alex Chisholm, the permanent secretary at the Cabinet Office said that “huge advances” had been made in preparations since research was conducted for a damning National Audit Office report published earlier this month which predicted the UK was likely to face “widespread disruption”.

The sole Red designation is “Trader Readiness”, particularly amongst small traders.

Nonetheless, Export Health Certificates are an acknowledged cost, for GB to NI agrifood movement, and some items (bans) remain “in conversation with the EU”, as does “At Risk” tariff bearing goods, for those movements.

Chemicals firms trading in the GB market also face costs with reregistration in UK REACH, and further time (up to 6 yrs for small tonnages) is being given by government for data extract from EU database (see the Chemicals section of the Brexit Guidance List in subscriber’s EHS Legislation Registers & Checklists).

We (at Cardinal Environment Limited) have now commenced populating the new EHS Legislation Registers & Checklists that will go live on 1st January 2021. A further update will be in the November Email Alert.

Export-Import (Hops) (UK Brexit)

Exit day is 31st January (end of this month)

Transition Period end date is 31st December (end of this year)

Instructions for trading with the EU (hops and hop products, an agricultural product) after Exit day are set out here. Note these set out in No Deal scenario format – I have adjusted below.

I am posting this Blog because it illustrates the UK approach for trade with the EU in those agricultural products, post Brexit, for which the EU has marketing standards.

Pre-Brexit

Hops marketed in the EU must meet rules on marketing standards. This includes hops extracts, hop cones and ground, pellets or powdered hops cones.

To show that they meet these standards, imports to the UK:

• from non-EU (third) countries, must have an Attestation of Equivalence

• from the EU, must have an EU hops certificate

The UK inspection agency is the Rural Payments Agency (RPA) – this agency inspects at least 5% of hops imports from each non-EU country. The UK does not currently inspect imports of hops from the EU.

Hops produced in the UK are issued with EU hops certificates from hops certification centres. With some exceptions, the certificates are needed for:

• marketing hops in the EU (including the UK)

• exporting hops

Post-Brexit

UK certification centres will still issue hops certificates for hops produced in the UK.

UK hops certification centres must remove all EU branding (including references to the EU and the EU emblem) from certificates from Exit day (or from the end of the Transition Period). The form of the certificate and the process for getting a certificate will not change.

Hops imported into the UK (after Exit day or after the end of the Transition Period) must be accompanied by one of the following as evidence that they meet UK marketing standards:

• the new UK Attestation of Equivalence issued by an authorised third country agency

• EU Attestation of Equivalence issued by an authorised third country agency (can be used until 31 October 2021)

• EU certificate for hops imported from the EU (can be used until 31 October 2021) – this must comply with EU rules and can be issued by a body authorised by an EU member state

After 31 October 2021, all hop imports from the EU and other third countries must be accompanied by a new UK Attestation of Equivalence. This must be issued by an authorised third country agency. A list of these agencies will be published on GOV.UK following EU exit. Agencies currently registered with the EU will be registered with the UK when the UK leaves the EU.

The UK may stop accepting EU Attestations of Equivalence and EU certificates before 31 October 2021 if EU marketing standards for hops do not meet UK standards.

The EU only accepts imports of hops accompanied by an EU Attestation of Equivalence, issued by an authorised agency in the exporting third country.

The UK government intends to apply to the EU to list RPA as the UK agency authorised to issue Attestations of Equivalence. RPA will not be able to issue Attestations of Equivalence until the listing with the EU is complete.

Further details will be published when they are available. However, an exporter must first enrol with RPA to export hops after Brexit.

Other details are set out in the instructions.

New Rules from the Trade Deal

The instructions are currently silent on new rules from the Trade Deal.

Brexit Instructions (UK Brexit)

Exit day is 31st January 2020 (at the end of the month)

Happy New Year!

As of today, 2nd January 2020, the entry page to the online UK Brexit instructions (found at the base of any online gov dot uk page) does not –

(1) stipulate the transition period end date (it currently is 31st December 2020), nor

(2) identify new rules that would change the No Deal baseline

As more information comes online and is published, I will issue applicable Blog posts. Please look out for them.

Update on GB stickers (NI Brexit)

Exit day is 31st October (for the moment)

I posted yesterday with Warning re Get Ready Brexit Checker, and I said the reader should check in-country (the receiving country).

Statement from @deptinfra on GB stickers (posted by @DarranMarshal, twitter)

“The requirement that all UK motorists driving in Ireland should display a GB sticker stems from the 1949 Geneva Convention on Road Traffic. It is not an EU requirement & is not affected by Brexit.”

UK Get Ready Brexit Checker says all UK vehicles will be required to have a GB sticker when travelling in the Republic post Brexit.

Northern Ireland’s Department of Infrastructure statement:

“We are not aware of any occasion when this has been enforced by the Irish government.”

Warning – Get Ready Brexit Checker (UK Brexit)

Exit day is 31st October

It’s been drawn to my attention that the Department for Transport is asserting GB stickers must be affixed to vehicles. The text below (** text **) was showing yesterday on the Get Ready Brexit Checker, but is not showing today. Plus it is showing in the linked Guidance from Transport Goods out of the UK Instructions posted today in gov dot UK.

So the situation is confused. It may be the Get Ready Brexit Checker is simplifying. Please check with relevant Ministries and Agencies and in particular the authorities in the EU country being visited (they will be the enforcers not the UK).

** text **

UK registered vehicles displaying Euro-plates (a circle of 12 stars above the national identifier on a blue background) don’t need to fix a GB sticker to the rear of their vehicle when driving in EU countries. In non-EU countries, a GB sticker must still be displayed on the rear of UK-registered motor vehicles, caravans or trailers. Most motoring organisations and many tour operators will supply GB stickers.

Get Ready Campaign Launch (UK Brexit)

Exit day is 31st October

HMG announced today 1st September their Get Ready Campaign launch.

This will drive people to gov dot uk, and the Get Ready Brexit Checker I posted about in my last post.

Here.