1 January 2021: United Kingdom and European Union separate markets

Update 3 February 2021: 

Since 1 January 2021 the UK is an independent market and separate customs jurisdiction to the European single market and customs union. The EU-UK Trade and Cooperation Agreement became provisionally applicable on 1 January 2021. 

Whilst existing conditions for trade access to the EU and Northern Ireland, for third countries, such as New Zealand, continues, there are some important factors to consider.  For New Zealand exports to England, Scotland and Wales there are new registration systems for standards, customs, and sanitary/phyto-sanitary regulation.

New Zealand goods shipped to UK and then on shipped to EU (or vis versa) are  subject to import and export documentation at borders, with duty and VAT payable at each import border.  UK plan to establish Free Ports by January 2022.

PREPARE AHEAD of shipping your goods to ensure minimal disruption to your trade channels especially for goods shipped to either UK or EU for sale in the other market. Key considerations:

  • Duty: a new UK tariff applies for duty assessment for imports into England, Scotland and Wales (see UK Government link)
  • Sanitary/Phyto-sanitary: Check your importer is registered on IPAFFs for pre-clearance in UK in addition to TRACES for EU (see link below)
  • VAT: Ensure your UK and EU enterprises have UK and EU VAT numbers (EORI link below)
  • Warehousing: Expect reduced warehouse capacity late 2020 and early 2021.
    • Book early.   Capacity already reduced due to COVID-19 is under further pressure.
    • Consider bonded store options for goods being on-shipped from UK or EU.
  • Shipping: Consider shipping direct to UK or EU for respective markets and AVOID transiting goods by truck (RORO/Chunnel) between EU and UK (in either direction) until new border clearance procedures well tested.
  • Standards & Regulations: mutual recognition ceases.
    • CE Mark issued by UK standards authority will no longer be recognised in EU.  Goods will need to be re-tested by an EU testing body.
    • Goods exported to UK will need to be tested and require the new UKCA mark. The EU mark may continue to be used until 1 January 2022
  • Labelling: Goods requiring an in-market address on the label (eg. Wine) will now require both an EU and UK address.
  • Data: restrictions will apply regarding UK use of EU citizen data - get expert advice
  • Contracts: review all UK contracts which are EU law based.
  • IP: will need to be protected in both UK and EU. (see WIPO link below) Seek expert advice.

New Zealand and UK agencies have developed advice sites that will assist you to cope with these changes. Visit each of the sites below. Use the checklists and regularly check for updates. Keep in touch with the MPI, MFAT or NZTE Brexit desks - they have people who can help.

 

Brexit information pages

NZ Customs: Customs issues

MPI: for all primary industries exports

MFAT

IPAFFS

EORI

EU

EU Market Access

British Chambers of Commerce: Customs clearance service

British Chambers of Commerce

UK Government

UK Global Tariff

UKCA

UK Free Ports plan

WIPO: IP

Mutual recognition Agreements: UK EU

EU-UK Trade and Co-operation Agreement