GEN – 1118.00. The fourth round of negotiations between the European Union and the United Kingdom took place between 2-5 June 2020. Unless the UK takes the initiative to extend the transition period before 1 July 2020, the negotiations would end with a ‘no deal’. Companies that have not yet prepared for this eventuality are recommended to take the necessary precautions to keep access to the British market.
Getting ready for the end of the transition period
To assist, the Commission is reviewing the 100-plus sector-specific preparedness notices of 2018 with readiness notices of which 36 have been published between March and 8 June 2020). These can be downloaded on https://ec.europa.eu/info/european-union-and-united-kingdom-forging-new-partnership/future-partnership/getting-ready-end-transition-period_en.
Among the 36 readiness notices, the following are relevant to the HVACR industry:
- Industrial products
- Transportable pressure equipment
- E-commerce
- E-signature (electronic identification and trust services for electronic transactions)
- Online purchase with subsequent parcel delivery
- .eu domain names
- European Works Councils
- Excise duties
- Security of network and information systems
- Prohibitions and restrictions of imports/exports, incl. import/export licences
- Value added tax (VAT)
- Consumer protection and passenger rights
Practicalities
Already today, the UK is a third country without a free trade agreement with the EU.
If the ‘no deal’ agreement would go ahead, export to and import from the UK is like any export to and import from the USA, China or Russia.
This means that administrative formalities must be settled. Even though many of these formalities can be settled online, it should not surprise anyone that some of the procedures may take up to 6 months.
It is expected that companies that have not applied timely for administrative documents will not be able to export to or import from the UK from 1 January 2021 if the negotiations end up with the ‘no deal’.
Recommended Actions
With or without the no deal scenario, companies manufacturing in the UK or trading with the UK are advised to check if they would already have registered as an economic operator. The following are relevant
- UK EORI number
- UK VAT number
- UTR (Unique Taxpayer Reference)
- REX (Registered Exporter system)
- UK and national customs declarations
- UK import tariffs (form 2021)
- UK Public Contracts Regulations 2021
The Member States ministries dealing with trade and the national associations should be able to provide additional guidance.
Related documents and links
All related documents and articles can be found in the respective sections in the right sidebar.
Checklist recommended actions:
- EORI: https://www.gov.uk/eori
- VAT: https://www.gov.uk/vat-businesses
- UTR https://www.gov.uk/find-lost-utr-number
- REX: https://ec.europa.eu/taxation_customs/business/calculation-customs-duties/rules-origin/general-aspects-preferential-origin/arrangements-list/generalised-system-preferences/the_register_exporter_system_en
- UK Tariffs 2021: https://www.gov.uk/guidance/uk-tariffs-from-1-january-2021#:~:text=From%201%20January%202021%2C%20the,inform%20development%20of%20the%20UKGT.
- UK Public procurement 2021: https://www.gov.uk/guidance/public-sector-procurement-after-a-no-deal-brexit
Other sources for information:
- EU Getting ready for the end of the transition period: https://ec.europa.eu/info/european-union-and-united-kingdom-forging-new-partnership/future-partnership/getting-ready-end-transition-period_en
- EU new partnership with UK: https://ec.europa.eu/info/european-union-and-united-kingdom-forging-new-partnership_en
- EU on taxation: https://ec.europa.eu/taxation_customs/uk_withdrawal_en
- EU Brexit preparedness: https://ec.europa.eu/info/brexit/brexit-preparedness_en
- UK check to get ready for 2021: https://www.gov.uk/transition-check
- UK importing into UK: https://www.gov.uk/starting-to-import/moving-goods-from-eu-countries
- Placing goods on UK market: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-uk-market-if-theres-no-brexit-deal#new-approach-goods
- Placing UK goods on EU market: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-internal-market-if-theres-no-deal#new-approach-goods
- UK F-Gas legislation (withdrawn 13 March 2020): http://www.legislation.gov.uk/ukdsi/2019/9780111180433/contents
- UK Trade and investment: https://www.gov.uk/business-and-industry/trade-and-investment
- GEN – 1097.00 – Previous update on Brexit
- GEN – 1077.00 – Update on Brexit
