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Transitional Simplified Procedures

New customs advice was announced recently for Traders / Imports to prepare and complete their own customs declarations. The new advice is called Transitional Simplified Procedures (TSP).  Click here to access the relevant page on the HMRC website which explains how TSP works.

TSP is one of the many ideas that have been requested / implemented by both HMRC and certain larger companies to try and alleviate the expected queues at ports after Brexit.

As you will see from our analysis of TSP (detailed below) we believe the ‘simplified’ part only applies to HMRC, in that we mean it’s a lot easier for traders and agents alike to actually make the import declaration at the time of entry of the goods at the relevant border,  for example Dover. However, we are not here to influence your opinions but to provide information and our own analysis, so please read on and decide for yourselves.

Registration as a TSP may help, but please note we are not permitted to register on your behalf.  However, we understand it may be possible (yet to be confirmed by government) for a transport company such as ourselves to complete the required supplementary declarations on behalf of a TSP.

You must have a duty deferment account to operate TSP. TSP is a system which allows the registered party’s EORI number to be used to allow import cargo to be waved through on arrival at a RoRo port post a ‘no-deal’ Brexit.  The importer would note details in their commercial records and have to raise a ‘supplementary declaration’ by the 4th of month two.  The problem is most traders won’t have the knowledge of how to raise supplementary declarations, the computer links or the software needed.  Often we have been told by clients that they do not have the inclination to do this anyway.  TSP is ‘transitional’ anyway; it won’t be a permanent solution.  By all means, apply for a TSP approval.  But some of our other customers have said if it is given to them, they wouldn’t know what to do with it.

For restricted goods, a simplified frontier declaration would still be required.  We do not think your goods will be restricted, but since full details of the UK Customs Tariff have not yet been released, we cannot be absolutely certain.   Note – when it comes to Customs, ‘simplified’ is never quite what it would seem.  It’s maybe simple for Customs, but always complicated for everyone else. ‘Simplified’ is the wrong choice of word, ‘facilitation’ is far more fitting. Since at least two actions will be needed (entry of data in to your commercial records; supplementary declaration), if all of the information is present, it is far easier to clear at the port when the goods arrive.

Stephen

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