Deal or No Deal? What about changes to Customs procedures?

Preparing for Brexit – does your business import, trade with or move goods through the UK or into the EU?

Regarding cross border trade with the UK post-Brexit whether there is deal or not - In the absence of a transition period (as tabled in the withdrawal agreement) or a definitive arrangement, trade relations with the UK will be governed by general WTO (World Trade Organisation) rules, without application of preferences.

This means that:

  • Customs formalities will apply, declarations will have to be lodged, and customs authorities may require guarantees for potential or existing customs debts.
  • Customs duties will apply to goods entering the EU (including Ireland), without preferences. This will affect goods imported directly into the UK for subsequent delivery to destinations in the EU and products already imported into the EU and transported through the UK to Ireland or another EU country.  

A pivotal element of EU Customs procedures is the requirement of a business involved in the import of goods that are Customs regulated in the EU to obtain and use an EORI (Economic Operator Registration and Identification code) number.

It facilitates the efficient customs treatment of undertakings involving the import or export of goods into or out of the EU.

Businesses can only be allocated and avail of the use of a single EORI number and this is issued by the Customs Authority of the EU member State where the business is established.

With the pending exit of the UK from the EU, the continued use of an EORI as issued by the UK Tax Authorities will not be allowed.

So for any business who currently trades and imports goods into the EU using the UK issued EORI number, the use of this UK issued number will become invalid post Brexit as the UK will no longer be part of the EU Customs regime. 

Contingency plans allow for businesses affected to apply for an EORI number in one of the other remaining EU member state where they have an existing VAT registration. This will allow for the continuation of import and export activity under the current EU Customs regime.

By way of update in Ireland, ROS (the Revenue Commissioners online tax compliance system) has been adapted to facilitate the request for Irish EORI numbers even where a GB issued EORI number already exists.

This change to the ROS online system provides transitional contingency support for businesses effected by Brexit and who are VAT registered in Ireland.

So if you are a business already VAT registered in Ireland or seeking to became a VAT registered  trader here from the UK or elsewhere to maintain access to EU markets, access to an EORI here in Ireland is available.  

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The exact consequences for future policy and regulation remain unknown. It will take time to fully understand the implications of the vote, and it is important to note that Article 50 of the Lisbon treaty provides for two years, from the date the UK Government gives notice to the Council of Europe, to negotiate and agree exit terms.



Can you afford to avoid the risk? Ineffective VAT management can represent a major cost risk and compliance burden for business. If done correctly it offers very significant opportunities for cash-flow and bottom-line savings.