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Brexit Update – Jan 3rd 2022

It seems Brexit will never be quite “done”. It is certainly set to have ongoing changes on customs regulations and ever-changing stages of implementation throughout 2022.

While the Northern Ireland protocol continues to be an area of dispute between the UK and the EU, there won’t be a definite settled position on customs processes for us.

While there are no customs processes between Ireland North and South, there should not be any freight from the UK mainland destined for the ROI (Republic of Ireland) travelling via Northern Ireland unless full customs clearance is effected when passing through Northern Ireland.

GB shipments coming into the ROI have full and complete processes now in place and these should not have any further changes relating to Brexit.

However this is not the case at UK ports for exports coming from the ROI. All changes to ROI imports are postponed for the moment but may be implemented at short notice anytime.

While the N IRL protocol is still being argued, a different timetable is being applied to imports into GB from the ROI as compared to the rest of the EU.

At different stages throughout 2022 GB plans to start implementing import controls on food and agri products from the EU that involve health and veterinary certs not required up to now.

Bear in mind the below timetable only applies to shipments from the rest of the EU, not ROI, to GB

Extract from Revenue and Customs sited below set out the timetables and some details :

UK Import and Customs Controls due to be introduced on 1 January 2022 have been postponed for goods from Ireland

On 15 December, the UK government announced that they are, “to extend, on a temporary basis, the current arrangements for moving goods from the island of Ireland to Great Britain . . . goods moving from the island of Ireland directly to Great Britain will continue to do so on the basis of the arrangements that apply currently, until further notice; and will not, for now, be affected by the changes being introduced on 1 January for all other inbound goods.”
This means, until further notice, for goods moving from Ireland directly to Great Britain there is:

  • no requirement for pre-notification of SPS products. (It is important to note that only applies for those exporters that are not already subject to pre-notification requirements)
  • no requirement for pre-lodgement of UK customs declarations
  • no requirement for compliance with full UK import controls and
  • no requirement to use the Goods Vehicle Movement Service (GVMS).

The requirement for compliance with existing requirements for full EU export formalities and use of the PBN for goods moving via RoRo ferry, as well as the existing UK formalities in relation to controlled goods e.g. alcohol, continues and are not changed. “
“ Preparing for the introduction of changes
The postponement of the changes due to take effect on 1 January 2022 is temporary. Irish businesses exporting to the UK are strongly advised to continue to prepare and be ready for the full introduction of UK import and customs controls in 2022. Irish businesses should be mindful that the lead-in time to their commencement once announced, could be quite short.”

Below is an update from HM customs in GB

UK RequirementOriginal Proposed DateRevised Date of Introduction
Full Customs declarations and controls1 January 2022Postponed until further notice for goods moving directly from Ireland to Great Britain. Requirements will apply for UK imports from other EU Member States and for goods transported from EU countries to Ireland via Great Britain either under transit or vi a distribution hub in GB.
Pre-notification of SPS goods
1 October 2021
Postponed until further notice for goods moving directly from Ireland to Great Britain unless it was already in place. Requirements will apply for UK imports from other EU Member States and for goods transported from EU countries to Ireland via Great Britain either under transit or vi a distribution hub in GB
Safety and security declarations on entry to the UK (ENS declarations)1 January 20221 July 2022
Export Health/ Phytosanitary Certificates and physical/identity checks on animal by-products; plant and plant products; meat and meat products; high-risk food not of animal origin1 January 20221 July 2022
Export Health Certificates and physical checks on all dairy products1 January 20221 September 2022
Export Health Certificates and physical checks on all remaining products of animal origin including composite and fish products1 January 2022
1 November 2022