Economic Operator Registration and Identification Number and Post Brexit Trader scheme

Shanker Singham from TSS provided an overview of the TSS Operational updates as of December 2020, highlighting that regardless of whether or not a deal is agreed between the UK and the EU prior to the end of the transition period, the NI protocol and associated arrangements will be implemented from 1^st January 2021. This will have an impact on the ways in which goods move across the GB/NI Boundary. The protocol aims to ensure that the movement of goods will be as free flowing as possible, and although no changes will be made as to how goods move between NI and Ireland, and from NI to GB, there will be changes to how goods are moved from GB to NI.

TSS will offer education and advice, a digital first service for goods moving from GB to NI and a contact support centre which will assist with issue resolution of the new mandatory news. To avail of TSS you must register with the service.

From 1^st January 2021, administrative changes will come into effect and import buying will be different than it is currently. These changes will impact upon all organisations who are trading into or out of Northern Oreland for which Customs Declarations will be a requirement.

Frank Dunsuir from TSS continued the presentation and provided information on the types of goods that will be impacted and how these are divided between three different categories. These are based on an import type process and each category will require different administrative consideration.

In order to trade between NI and GB and to avail of the TSS, NI organisations will need to register for an Economic Operator Registration and Identification or ‘EORI’ Number, and subsequently be provided with an XI/EORI number as NI will be within an EU facing system whereas the rest of GB will be within an UK facing system. Shanker stated that you need to have an XI/EORI number in order for an organisation to be entered by the TSS onto the EU Customs facing system.

Elly Paterson, HMRC, advised participants to stay aware of further information that will be released in the coming weeks.

Stephen Kelly, DfE, finished the presentations with a look at how organisations should prepare for the end of the transition period. The exact nature of changes is different for different business models however, but regardless of your business model or where you are based, there are steps you can take now to prepare for the end of the transition period.

If your business operates across the UK or sources goods from GB to sell in NI, it is important to be aware of the change to EU Regulatory requirements including labelling. As well as registering for an EORI number and signing up to TSS, it is important to remember that EU Regulatory requirements for goods will still apply in NI despite no longer applying in GB. Some organisations may not be impacted by these changes, but you should talk to your suppliers, particularly if they are based in GB, and consider these requirements.

If your business operates across the island of Ireland or has a presence in other parts of the EU, it is important to understand that the protocol does not cover the trade or exchange of data. It is recommended therefore that you conduct a mapping exercise of your data flows. Further information can be found on Home | ICO.

Stephen also stated that those who have EU Nationals working for them, not including Irish Nationals, should highlight the EU Settled Status scheme to their employees. More information can be found at Stay in the UK ('settled status'): step by step - GOV.UK (www.gov.uk)

DfE recommend that organisations should look at the 10 Point Checklist of actions that can be taken now in order to prepare for the end of the Transition period.

• Assess your exposure to changes
• Register for the Trader Support Service
• Get an EORI number
• Find out the commodity code for goods you buy or sell
• Speak to you haulier
• Speak to you suppliers, particularly those in GB
• Check your goods regulation
• Consider your data
• Apply for the EU Settlement scheme
• Apply for an Immigration Sponsorship Licence

Questions

If an organisation with locations across the UK and NI, and your HQ has already signed up to the EORI Number do you have to do it again for the NI base?

If you have a GB EORI number already, there is mechanism that allows you to get the XI/EORI.  If you are registered on TSS however you will be auto enrolled. The XI number is specific for NI organisations as they will be input within an EU System whereas those within GB will be within a GB facing system.

Will GDPR no longer apply?

There is no formal arrangement on this as of yet, however GDPR has already been put into UK Law. As this is still a subject to change, it is recommended that organisations look at how they store their date and map how the exchange it so that they are prepared for future changes that may come into effect.

Do these changes apply to a charity with a base in Belfast, and other locations through the UK, who don’t trade but rather move goods between their locations?

If goods are moving across the GB/NI boundary, then technically customs declarations will still be required. It will depend on what goods are being moved as to which declarations and exemptions will be applied.

Is an EORI number required if you are purchasing from GB for internal use rather than to sell on?

As XI/EORI number will still be required as there is still a movement to goods from GB to NI.

Do the new rules apply even if you are not VAT registered?

Yes – movement of goods are looked at by customs whereas VAT implications are a separate process. There is a separate application for those who are VAT registered and it can be found at HMRC: Structured Email (tax.service.gov.uk).

As a UK Charity with a HQ in London and office in Belfast, who should register?

TSS recommends that both offices register for a number as the London Office will require a EORI number whereas the Belfast Office will be provided with an XI/EORI number.

Further information can be found on:

Get an EORI number - GOV.UK (www.gov.uk)

Home - Trader Support Service

Brexit | InterTradeIreland

EU exit readiness checklist - 10 steps to take | nibusinessinfo.co.uk

Guidance-for-businesses-in-Great Britain-Selling-or moving-goods-to-Northern-Ireland-from-GB.pdf (nibusinessinfo.co.uk)

Regulatory requirements for placing goods on the NI and GB markets from 1 January 2021