The UK left the European Union on January 31st, 2020. During the current transition period, trade is still conducted under the old arrangements as if the UK is still a member of the EU. When the transition period ends on December 31st, 2020, new rules will apply but these have not yet been agreed in the form of a ‘trade deal’. If no trade deal is agreed by the end of the transition period, it is assumed that WTO rules will take effect.
Bookmaker odds of a trade deal being signed in 2020 are currently about 60%-70% according to https://www.oddschecker.com/politics/brexit. It is unlikely that a wide-ranging, comprehensive deal can be reached at this late stage, but the markets are still hopeful that a deal of some sort will be agreed this year.
In the absence of a deal, trade in goods and services between the UK and EU is likely to revert to WTO rules between third party countries. Separate rules may apply for movement of goods between Northern Ireland and the Republic of Ireland, and between Northern Ireland and mainland Great Britain. However, it is still unclear how these rules would operate.
It depends what goes into the trade deal. But some things will change whether or not there is a deal. Assuming the UK leaves the Customs Union, things like cross border VAT arrangements, third country representation and customs declarations will change.
Whether there is a trade deal or not, the current VAT arrangements between the UK and EU countries will come to an end (except between Northern Ireland and ROI). From January 1st, goods will be subject to import VAT before clearing customs at the port of entry. Goods between ROI and Northern Ireland will continue to be exempt, but some goods between Northern Ireland and mainland GB may be subject to import VAT. This would clearly present logistical and political issues that may take some time to resolve.
Broadly, responsibility for import VAT lies with the importer. Deferral schemes are likely to operate in order to speed up customs clearance and mitigate cash flow considerations.
Yes. The UK will continue to operate EU regulation 183/2005. This means that all animal feed and feed ingredients businesses in the UK still need to comply with regulation 183/2005 and compliance will continue to be enforced by the UK competent authority (Trading Standards).
EORI (Economic Operators Registration and Identification) numbers are needed when goods are moved between third party countries. After December 31st, UK businesses will need an EORI number to move goods to or import goods from EU countries. EU businesses will need an EORI number to move goods to or import goods from the UK. An EORI number will not needed to move goods between Northern Ireland and ROI, but there is uncertainty about whether that could change if trade negotiations collapse.
Third country representation is an EU requirement for companies based outside the EU who move animal feed and feed ingredients to EU countries. Its purpose is to ensure that the exporting company in the non-EU country, i.e. the ‘third country’, operates to the standard laid out in Feed Hygiene Regulation 183/2005. To do this, a suitably qualified company based in any EU country must vouch for (represent) the non-EU exporting company and verify that it operates to 183/2005 standards. Verification is normally by periodic site audits in the third country and/or demonstrable compliance with an industry wide certification scheme such as FAMI-QS, GMP+, Femas or UFAS
The UK will continue to operate the third country representation requirement after December 31st.
From January 1st, 2021, UK companies exporting feed or feed ingredients to EU countries will need third country representation in an EU country. Similarly, EU companies exporting to the UK will need third party representation in the UK. Different criteria may apply when a 183/2005 registered importer is handling customs clearance.
Third country companies using UK representation to sell their product in the EU will need to find an EU based representative. Third country companies using EU representation to sell their product in the UK will need to find UK representation.
Proviso: Given that the EU and UK will both continue to operate regulation 183/2005, third country representation between the EU and UK is, on the face of it, an unnecessary burden. There is, therefore, a possibility that third country representation rules could be waived if a trade agreement is reached. Don’t bet on it.
UK labelling will be largely unchanged after December 31st. Goods currently coming into the UK require a label that is EU compliant. Since there are no plans to change the statutory content of UK labels, EU compliant labelling will still be acceptable in the UK, and vice versa. For goods manufactured in the UK, the country of origin will have to be made clear (UK, not EU). In some cases, the importer’s address may be required if the goods are resold. This would apply in both the EU and UK. Unless there is a change to existing EU and UK law, UK goods going to the EU will be treated exactly the same as goods from any other non-EU country, and must be labelled accordingly. Similarly, goods coming into the UK from the EU will be treated the same as goods coming from any other country.
After December 31st, the UK will continue to use the EU Register of Feed Additives to determine which ingredients and additives are permitted. No changes are anticipated in the foreseeable future, and the UK is likely to remain aligned with EU legislation for some time.
No. The UK will only permit vitamin B2 from sources listed in the EU Register of Feed Additives. GMO derived vitamin B2 is not permitted.