12 Current Government Guidance

Facing the
CHALLENGES of
Brexit TOGETHER...

Edition 1, October 2020 www.starcargo.co.uk

www.starcargo.co.uk 1|
 Contents

Star Cargo plc - Group Introduction p|3

Current Government Guidance p|4
The Importance of Incoterms and Understanding Your Responsibilities p|5
Most Frequently Used Incoterms for Road Freight Shipments p|6
Commodity Codes p|7
Anticipated Post-Brexit UK to EU Export Procedures p|8
Exports from UK to EU Flowchart p|9
Anticipated Post-Brexit EU to UK Import Procedures p | 10
Imports from EU to UK Flowchart p | 11
Your MUST HAVE Checklist p | 12
Customs Freight Simplified Procedures (CFSP) p | 14
Fiscal Representation p | 15
Additional Items to Consider p | 16
Glossary p | 17

2 | FACING THE CHALLENGES OF BREXIT TOGETHER

Group Introduction
Established in 1983, the Star Cargo plc Group comprises seven
UK-based subsidiaries, our turnover last year was £103m and we
employ over 300 staff. All of our companies are actively involved in
the International Logistics industry.
Group subsidiaries include:
The purpose of this document is to provide guidance and support to you our
valued Customer as the Brexit transition ends and we enter a new regime of
trade between the UK and Europe. It is vital to proactively prepare together
for the challenges that Brexit brings and identify the best method for selling or
buying your products in the EU.
Our extensive resources and facilities developed over 38 years puts the Star
Cargo plc Group and each of its subsidiaries at the forefront to overcome the
challenges that Brexit brings.
These facilities include:
Our own Customs clearance agent - Harbour Shipping Ltd has been providing
Customs clearance since 1983 and is the largest agent in Dover with 3 offices
located at the Eastern and Western Docks in the Port of Dover as well as
Stop 24 - Eurotunnel. Serving a wide and varied client base ranging from
International road hauliers and forwarders to manufacturers, our experienced and
knowledgeable team of Customs specialists will support your business.
We operate our own modern fleet of vehicles including curtainside trailers
providing Groupage, Part Load and Full Load services to and from Europe giving
us greater control on transit times, streamlining communication and supplying a
reliable and competitive service to our Group subsidiaries and some of the UK
and Europe’s largest manufacturers.
A network of our own warehouses are in 3 strategic UK locations – Dover,
Redditch and Selby where we are able to provide short or long term storage
solutions, consolidating cargo in readiness for Export or providing temporary
storage to European clients wishing to provide a constant supply of stock. We
are an approved Designated Export Place (DEP) at our Dover Freight Terminal
just minutes from the Port and an External Temporary Storage Facility (ETSF) for
import freight requiring temporary storage awaiting Customs clearance.
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 Current Government Guidance

On 1st January 2021 the transition period with the EU will end and the
UK will operate a full, external border. Customs controls will be placed
on the movement of goods between Great Britain (GB) and the EU.
The UK Government published a Document on Thursday 8th October 2020 titled The
Border with the European Union - Importing and Exporting Goods. The full document
can be found here:

www.gov.uk/government/publications/the-border-operating-model

For Brexit information from the EU’s European Commission please find their website click here.

4 | FACING THE CHALLENGES OF BREXIT TOGETHER

 The Importance of Incoterms and The use of Incoterms in European Road Transport takes
on a far greater significance as from the 1st January 2021.
Understanding Your Responsibilities This is one of the most important parts of the process, and we need
this information to be able to progress.

Incoterms
are agreed
FREIGHT COLLECT TERMS FREIGHT PREPAID TERMS
between buyer and
ANY MODE OR MODES SEA AND INLAND ANY MODE OR
GROUPS OF TRANSPORT WATERWAY TRANSPORT MODES OF TRANSPORT seller and not with
EXW FCA FAS FOB CFR CIF CPT CIP DAP DPU DDP your logistics provider
INCOTERM® Ex Works Free Carrier Free Alongside Free on Board Cost and Cost Insurance Carriage Paid
Carriage &
Delivered at
Delivered at
Delivered Duty
and/or Customs
(Place) (Place) Ship (Port) (Port) Freight (Port) & Freight (Port) To (Place)
Insurance Paid
To (Place)
Place (Place)
Place Unloaded
(Place)
Paid (Place) broker.
At Buyer’s On Buyer’s Alongside On Board On Board On Board At Named At Named At Named
TRANSFER OF RISK Disposal Transport Ship Vessel Vessel Vessel
At Carrier At Carrier
Place Place Unloaded Place

OBLIGATIONS & CHARGES

Export Packaging Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller

Loading Charges Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller

Delivery to Port/Place Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller

Export Duty, Taxes &

Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller
Customs Clearance

Origin Terminal Charges Buyer Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller

Loading on Carriage Buyer Buyer Buyer Seller Seller Seller Seller Seller Seller Seller Seller

Carriage Charges Buyer Buyer Buyer Buyer Buyer Seller Seller Seller Seller Seller Seller

Insurance Negotiable Negotiable Negotiable Negotiable Negotiable *Seller Negotiable **Seller Negotiable Negotiable Negotiable

Destination Terminal Charges Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller Seller Seller Seller

Delivery to Destination Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller Seller Seller

Unloading at Destination Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller Buyer

Import Duty, Taxes &

Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller
Customs Clearance

*CIF requires at least an insurance with the minimum cover of the Institute Cargo Clause (C) (Number of listed risks, subject to itemised exclusions)
**CIP now requires at least an insurance with the minimum cover of the Institute Cargo Clause (A) (All risk, subject to itemised exclusions)

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 Most Frequently Used Incoterms for Road Freight Shipments

For International Road Transport Shipments to and from the EU the most frequently used Incoterms have been:

n T
 he Seller/Exporter is selling on an Ex-Works basis and therefore has no
EXW involvement in the onward costs.
Ex-Works n T
 he Buyer/Importer will need to organise the transport of the goods, payment of
any Export Duty, Taxes and Customs clearance.

n T
 he Seller/Exporter is selling to the Buyer/Importer on a DAP basis.
DAP n T
 he Seller/Exporter will organise the transport of goods to a specified location and
Delivered the Export Documentation.
At Place n T
 he Buyer/Importer will be responsible for the Import Customs Clearance, plus any
Import Duty or Taxes including VAT.

n T
 he Seller/Exporter is selling to the Buyer/Importer on a DDP basis.
DDP n T
 he Seller/Exporter is responsible for all Transport, Customs documentation and
Delivered any Duty or Taxes.
Duty Paid n N
 ote - the VAT can be zero rated but to take advantage of this you must engage
with a Fiscal representative. See page 15 for more information.

In our opinion we would suggest DAP will be the most suitable and possibly the simplest option for most clients.

6 | FACING THE CHALLENGES OF BREXIT TOGETHER

Commodity Codes

Prior to shipment, all cargo needs to be classified with the appropriate Customs Commodity
Code and can be incorporated into your commercial invoice
We must have at the minimum the first 8 digits of a 10 digit code for each product on your invoice, as per the example illustrated below.

For help classifying your goods, visit: https://www.gov.uk/trade-tariff

Open all headings Close all headings

Level Description VAT Third country duty Supplementary unit Commodity code

t Wheat Flour
Of durum wheat 20% or 0% 172.00 EUR / 1000 kg 11 01 00 11 00

Of common wheat and spelt 20% or 0% 172.00 EUR / 1000 kg 11 01 00 15 00

Meslin Flour 20% or 0% 172.00 EUR / 1000 kg 11 01 00 90 00

Alternatively:
https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp

The good news is if you currently trade internationally, you will be completing an Intrastat and will already have commodity codes for your products.

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 Anticipated Post-Brexit UK to EU Export Procedures From the 1st of January 2021
following the latest iteration of the Border Operating Model, October 2020

01 A Customs export declaration must be submitted to CHIEF
(Customs Handling of Import and Export Freight) whilst the
goods are at the trader’s premises (unless the transport
operator has a DEP accredited facility). Once the export
declaration has been cleared, the goods will be granted P2P
(Permission to Progress) and the goods can be loaded to a
vehicle. The trader is defined as the Exporter/Manufacturer or a
Logistics provider operating a DEP.
02 Customs Agent or Freight Forwarder or Exporter prepares
T-form (NCTS) and pre-lodges it to the Customs NCTS System.
03 Prior to the T-Form being raised, a Clearance Broker in the EU
must be nominated by the UK Exporter, unless the goods are
being shipped to an Authorised Consignee.
04 Vehicle reports to an Authorised Consignor or a Customs
office of departure where the pre-lodged T-form is processed
generating a Master Reference Number (MRN) and Barcode
against the T-form. Driver will also be issued with a paper copy
of the T-form.
05 If the Goods Vehicle Movement System (GVMS) is in place
from the 1st of January then the MRN from the T-form will be
uploaded onto the GVMS Platform by the Carrier.
06 An EU Safety and Security declaration into an EU platform may
be required subject to EU/UK negotiation.
07 Driver reports to Ferry/Train operator who will physically
check the T-form or, if GVMS is in place, will be asked for the
GVMS MRN to verify the driver has the appropriate Customs
documents and can then ship.
08 Driver presents the T-form to the Customs authorities on arrival
in the EU who will scan the barcode on the T-Form.
09 Driver proceeds to the Customs clearance point and presents
the T-form.
10 EU Customs Broker or Authorised consignee arranges Import
Customs clearance, paying relevant taxes and discharges the
T-form.

8 | FACING THE CHALLENGES OF BREXIT TOGETHER

Exports from UK to EU

EXPORTER/AGENT/
TRANSPORTER EXPORTER/AGENT/
UK EXPORTER HMRC
TRANSPORTER
GB-EORI EAD Export entry to CHIEF Export Permission
at Trader’s premises Export T-Form raised
number to Progress - P2P
with required info
MRN issued

AGENT/TRANSPORTER ensures all documents

AGENT/TRANSPORTER
are present & correct via Smart Freight
MRN scanned at Port
T-Form authenticated by HMRC at Authorised
of Departure
consignor or HMRC office of Departure

AGENT/TRANSPORTER AGENT/TRANSPORTER/IMPORTER
MRN document scanned Vehicle proceeds to designated
at Arrival Port Clearance point. T-Form discharged
Calais/Dunkerque & Customs clearance effected

It is vital that the EU Importer has the relevant EU authorisations for example
VAT registration number, EORI number or any other requirement.
The UK EXPORTER is responsible for ensuring that their customer has
the appropriate registrations/authorisations.

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 Anticipated Post-Brexit EU to UK Import Procedures From the 1st of January 2021
08 following the latest iteration of the Border Operating Model, October 2020

01 EU Customs Broker/Freight Forwarder/EU Exporter prepares 06 The Pre-lodged import entry number or CFSP Approval Number
Export Accompanying Document (EAD) and permission to or Importers EORI Number is communicated to the driver by
progress is granted. the Haulier.

02 Goods are loaded and the driver is issued with the EAD which
incorporates a Master Reference Number and unique Barcode.
03 When travelling via French Ports the vehicle registration, trailer
number and the EAD MRN are uploaded by the Haulier to the
French SI Brexit System.
04 Subject to Brexit negotiations, a separate Safety and Security
declaration may be required to be submitted into a new UK
Government platform which is called UK S&S.
05 If using DAP, the Importer must decide how the cargo is to be
Customs cleared. The two most commonly used methods are
either a Pre-Lodged Import declaration which accounts for VAT/
Duty at the time of import or Supplementary declarations via
Customs Freight Simplified Procedure (CFSP) which allows a
six month easement for goods imported before the 30th June.
07 If the port of departure is Calais, by the use of ANPR Cameras,
the SI Brexit system will either send the driver to a Green lane
or a Red lane. Green lane traffic moves directly to the Ferry
Port. Goods diverted to the red lane will go to a holding area
and have to resolve any Customs issues they have.
08 Driver ships giving the ferry/train operator the pre-lodged
Import entry number or the CFSP Approval Number or EORI
Number.
09 Goods arrive in the UK and deliver.
10 Pre-lodged Customs entries must be made live on CHIEF by
the end of the next working day after arrival. For Supplementary
Declarations a six month easement is available to importers
choosing to use CFSP (a more detailed explanation of this is
found on the page 14)

Please note VAT Registered importers can choose to use

Postponed VAT Accounting when using Pre-lodged import
entries and MUST use postponed VAT accounting when using
CFSP. Importers must confirm in writing what method of VAT
Payment they are using.

10 | FACING THE CHALLENGES OF BREXIT TOGETHER

Imports from EU to UK Flowchart

EXPORTER/AGENT/ AGENT/TRANSPORTER
UK EXPORTER TRANSPORTER
EAD covers transport to EU port of Departure
GB-EORI EAD raised with required info
number Accompanying Doc & MRN to be scanned at Port
MRN issued into French SI Brexit System

AGENT/TRANSPORTER
UK IMPORTER (See Note)
UK Customs intermediary
UK Importer to specify Customs Clearance
completes import
instructions to Customs intermediary
declaration

AGENT/TRANSPORTER
On arrival in UK vehicle is either:
• Given OK to Exit Port and proceed
or
• Selected for Document/Examination

NOTE
Check that all relevant Docs
All UK Importers must have a GB EORI Number, & VAT Registration present & correct.
Number
To effect Customs Clearance there
A Duty Deferment account is recommended. are 2 options.
Sealane Freight and its Agents are unable to assist companies without a) Use Importers own CFSP
the above. authorisation - UK IMPORTER
OR
b) Use pre-lodged entry -
AGENT/TRANSPORTER
Entry must be “Arrived” before
the end of the next working day.
Details require loading to UK
GVMS - AGENT/TRANSPORTER

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 Your ‘MUST HAVE’ Checklist

You MUST nominate a Customs Clearance Agent

• All loads will require both Export Customs Clearance from the Seller’s Country
and Import Customs Clearance into the Buyer’s Country.

• Therefore if you have an existing relationship with a Customs Broker you must inform
us if you wish them to facilitate Customs formalities on your behalf.

• Alternatively you may be able to utilise us and our partner network to complete Customs Documentation on
your behalf. This requires you to complete a Letter of Direct Representation and a Letter of indemnity and return
them to us. To download and complete these documents please click the following link: Link Required

You MUST HAVE an EORI number

• An EORI number is an Economic Operator Registration and Identification number.

• An EORI number is not a VAT number, however, if you are registered for VAT the EORI number will be linked to it.

Without an EORI number you will not be able to move goods between the UK and EU.
The EORI application process takes differing amounts of time in different countries, if you don’t have this number please register today.

In the UK- please visit www.gov.uk/eori

12 | FACING THE CHALLENGES OF BREXIT TOGETHER

You MUST be able to provide the following information a
minimum of 72 hours prior to the loading date or your freight
cannot be collected:
EORI & VAT number of the Importer and the Exporter
The information opposite
can be incorporated Invoice Number
into your commercial
invoice, packing list and Clear description of the cargo
any other accompanying
Commodity code(s)
documents.
Consignor/Exporter (Name and Address)

Please advise us of the Exporter’s designated Customs Clearance Agent

Consignee/Importer (Name and Address)

Please advise us of the Importer’s designated Customs Clearance Agent

Delivery Address (If different to the Consignee)

Country of Origin

Number and Types of Packages

Net and Gross Weight

Payment Terms

Incoterms

Value (Confirm currency)

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 Customs Freight Simplified Procedures (CFSP)
UK Importers are able to take advantage of a special temporary
arrangement from the 1st January up to 30th June 2021,
which allows non-controlled goods to ship to the UK without
Customs clearance taking place at the border on arrival.
Importers are required to make a record in their own commercial records at the
time of entry into the UK, and then follow this with a supplementary declaration
to be submitted to HMRC within 6 months of the time of Import. This approach
simplifies requirements for the vast majority of goods until July 2021.
We suggest you check the relevant Customs requirements, which are quite
specific. Link Required
Our opinion is that UK Importers give this method serious consideration
- the advantages are:
• You can avoid possible delays
• There is no requirement for a pre-lodged Customs entry
• There is a potential cost saving
If Importers wish to take advantage of this method they must be registered
for VAT in the UK and accept to use Postponed VAT Accounting. At the
time of Import you will be required to keep your own Entry in Declarants
Records (EIDR) as detailed in the Governments’ Border Operating Model.
14 | FACING THE CHALLENGES OF BREXIT TOGETHER
When you are ready to submit your first delayed Customs declaration you will
need to either hold your own CFSP approval number or have an agreement with
a Customs Intermediary with a CFSP approval number that they will represent
you. Access to a deferment account will be required to pay import duties.
From the 1st July 2021 the 6 months easement will be withdrawn and
Importers will need to be in a position to submit their Customs declarations,
for example for goods imported in July 2021 by the 4th August 2021.
If Importers choose to engage the services of a Customs
intermediary you will need to sign a letter of Direct Representation
making yourself responsible for any potential Customs debt.
Please note deferred declarations replaces Transitional Simplified
Procedure (TSP), which has now been revoked.
Pre-Lodged Customs Entries
The alternative to CFSP for UK-based Importers
is that full Customs Declarations are completed
before the goods arrive in the UK. To be prepared for
this requires a great deal of planning and advance
notification of all shipments. We are able to provide
pre-lodged Customs entries if required to do so.
 Due to the increased complexity of UK/EU trade after Brexit we recognise that some of our
Fiscal Representation clients may wish to adopt different methods or Incoterms in order to manage cash flow, VAT &
Duty, or other commercial factors.

These matters need solid professional advice and we have teamed with 2 organisations who we
believe can offer such a service to our valued clients.

Fiscal Solutions offer a comprehensive VAT service to all those looking to do
business anywhere in the world. Their specialist team collaborates to provide
the highest calibre advice for your business. Based in London and all under one
roof means their team of multi-lingual specialists are able to act as a single point
of contact for all our clients, working collaboratively to solve any VAT issues that
may arise. Fiscal Solutions have enjoyed consistent growth over the last 30 years
and continuously invest in building sustainable partnerships.
Their unique service provides a comprehensive solution to the burdensome task
of approaching a number of providers in different countries.
No matter what the task or the country, Fiscal Solutions can help you solve your
business VAT needs.
Contact: Mr Stephen Pope – Senior Manager
Telephone: +44 (0)20 7831 5115 or Email: Stephen.Pope@fiscalsolutions.co.uk
For 40 years, RMB has taken on fiscal, social tax, and environmental tax filing
obligations for companies. This activity is also known as fiscal representation.
RMB is renowned as one of the primary actors in France and Europe for this
type of activity.
Throughout the years, RMB has continued to remain independent. This quality
is essential as it has given RMB the important ability to adapt and to make
quick decisions. RMB’s goal is to ensure that our clients can sell their products
and their services in all countries of the European Union without having to set
up a permanent establishment. RMB’s steady business development, as well as
its excellent financial standing makes RMB a reliable and trustworthy partner.
Contact: Michael Boulanger – CEO
Telephone: +33 (0)3 20 25 70 70 or Email: m.boulanger@rmboulanger.com

Fiscal Solutions Ltd RM Boulanger SA

130 Wood Street 17A Rue du Vertuquet
London 59660 Neuville en Ferrain
EC2V 6DL France
United Kingdom
www.rmboulanger.com
www.fiscalsolutions.co.uk

www.starcargo.co.uk 15 |
 Additional Items to Consider

Importers may consider having a Duty Deferment Account, Safety and Security declarations may be required – your
Import duties will be collected at the time of submitting the Transporter will be responsible for completion of these.
Customs declaration so an importer will either need their own
deferment or an agreement to use an Intermediary’s deferment. Some goods may require Certificates of Origin

You may wish to take advantage of Postponed VAT Please ensure all wooden pallets are to the correct
accounting processes, if so, please advise your Customs standards - ISPM 15 approval. More Info >
Clearance Agent that you are able to meet the Governments
HMRC will be introducing a new operating system called
criteria and wish to use this process. More Info >
GVMS on the 1st July 2021 which will undoubtedly
Importers may wish to consider what other Import regimes mean further changes in the Customs processes.
could be beneficial to them once we leave the EU. For
We expect there to be considerable delays in the Documentation
example: Customs warehousing, Inward Processing
process as from January 2021, which will impact on transit times.
Relief, Outward Processing Relief. More Info >

Companies exceeding the Intrastat thresholds will still be

required to make Intrastat Declarations beyond the 1st January.

Exporters sending goods to Europe on a temporary

basis with them returning in an unaltered state
may wish to explore using ATA Carnets.

16 | FACING THE CHALLENGES OF BREXIT TOGETHER

Glossary of Terms
Term Definition

ANPR Automatic number plate recognition

Authorised Consignee Status This will allows a company to receive goods under the Common Transit Convention or Union Transit at their own premises rather than at a customs office.

Authorised Consignor Status This allows a company to start the movement of goods under the Common Transit Convention or Union Transit at their own premises rather than at a customs office.

CFSP Customs Freight Simplified Procedure

CHIEF Customs Handling Import & Export Freight, the computer system of the United Kingdom’s revenue and customs services, HMRC.

Clearance Agent/Broker An entity, such as Harbour Shipping Ltd, that specialises in Customs paperwork and processes that can act on your behalf for relevant Customs processes.

Designated Export Place. This is a location, such as a warehouse, designated by an Authorised Consignor/Consignee where goods can be approved rather than at a
DEP
Customs location.

EAD Export Accompanying Document

EORI Economic Operator Registration & Identification

GVMS Goods Vehicle Management System

HMRC Her Majesty’s Revenue and Customs

MRN Master Reference Number

NCTS New Computerised Transit System that allows you to submit electronic Union Transit (UT) declarations.

Safety/Security declaration ENS Entry Summary Declaration

Safety/Security declaration EXS Exit Summary Declaration

T-Form This allows non-EU goods to Transit across other EU countries before it reaches its destination that prevents the goods from incurring duty or VAT liability on the way.

TSP Transitional Simplified Procedures. This was put in place in 2019 but has since been discontinued. The next closest alternative would be CFSP.

www.starcargo.co.uk 17 |
 Thank you for
reading this document.
“With our valued Clients support, patience and
assistance we will adapt and thrive together.”

www.starcargo.co.uk

The enclosed information is provided in good faith and as a guide for our clients based on the Directors experience gained over the past 50 years.
Star Cargo PLC cannot accept responsibility for any consequences arising from the use of this Brexit guide.