Addressing the challenges of a no deal Brexit takes place at a number of levels and requires responses at EU level, responses by Government, responses by citizens and responses by businesses and affected sectors.
While extensive Brexit preparedness and contingency planning has already been undertaken across Government, it is only by working together with businesses and our citizens that we can aim to mitigate the impacts of a no deal Brexit and ensure that we are prepared to the greatest extent possible.
As part of our preparedness and contingency plans, the Government identified those operators and businesses engaged in importing, exporting or moving plants and plant products from or through the UK as a key sector impacted by Brexit.
The following is the latest advice that we can give you to help minimise any disruption to your business if you operate in this sector.
In a no deal scenario, the UK will become a ‘third country’ for trading purposes. This will mean that new rules will apply to operators and businesses importing from, exporting to or moving goods through the UK.
These include a range of sanitary and phytosanitary checks for plants and plant products. Furthermore, there are specific rules applying to wood packaging used in the movement of goods.
It is important that businesses undertake the necessary preparations to be ready for compliance with these changes, as incomplete documentation, inaccurate information or late submission of documentation will lead to delays, with knock on impacts for your business.
- All businesses need to review their supply chain to assess how it may be affected, and build this into their business planning and cash flow management.
- All operators and businesses that trade with or move goods through the UK need to register with Revenue for an Economic Operators Registration and Identification number - see link to customs number. This applies irrespective of the volume or value of trade undertaken. Operators and businesses also need to register with the Department of Agriculture, Food and the Marine (DAFM) – see below.
- If your products are transported using wood packaging or pallets, check that the wood is International Standard for Phytosanitary Measure No. 15 (ISPM15) compliant.
- Engage with any trade representative body of which you are a member. They can assist you in preparing for Brexit.
Businesses trading with the UK
- Businesses need to prepare for any new customs arrangements and regulatory checks and the impact they will have. This includes any customs obligations or formalities that may be required by UK authorities. Businesses exporting food, plants, animals or animal products to the UK are advised to refer to the UK central government published information.
- Businesses should consider how they will handle these customs and regulatory formalities. These can be managed in-house or by customs broker/agent. Either option requires planning and time.
Specifically for businesses importing plants or plant products, including regulated wood and wood products
- The person responsible for importing the consignment must register with the Plant Health and Horticulture Division of the Department of Agriculture, Food and the Marine.
Specifically for businesses exporting plants and plant products
- After the UK leaves the EU, the UK will determine its requirements for the import of products, plants and animals into the UK.
- While the UK have published some guidance papers UK Preparedness Notices regarding their requirements, they are subject to change with limited notification. Therefore the Department recommends that you check the UK Government websites for the latest information.
- However, based on the current UK Preparedness Notices it should be noted that regulated plants and plant products will require a phytosanitary certificate in respect of each consignment. You need to register with the Plant Health and Horticulture Division of the Department of Agriculture, Food and the Marine to apply for this certificate. In the case of regulated wood and wood products, specifically, you will need to register with DAFM Registration. Please check the UK Government websites for the most up-to-date position on this matter.
- If you are exporting wild caught fish or fishery products, a Catch Certificate will be required – see Sea-Fisheries Protection Authority for further information.
All businesses transporting goods through the UK
- Businesses that move animals and goods between Ireland and other EU countries by road through the UK landbridge will need to ensure compliance with the customs transit procedure and with the SPS requirements.
- Animals and goods must be moved through the UK in accordance with Customs transit procedure. This requires the use of the New Computerised Transit System. There are simplifications available such as registering as authorised consignors/consignees. Please note that a financial guarantee is required.
- If transporting animals or animal products, you must be registered on TRACES.
- You must complete and submit the relevant part of the Common Veterinary Entry Document (CVED) in TRACES in advance of the consignment’s re-entry into the EU. Current intraCommunity rules continue to apply in relation to documentary and sealing requirements, with the exception of bovine and ungulate animals for immediate slaughter.
Businesses can sign up for Enterprise Ireland’s Customs Insights, a short online programme that aims to give businesses a good understanding of the key customs concepts, documentation and processes required to succeed post-Brexit.
The department of Agriculture, Food and the Marine has a dedicated call centre for Brexit Queries which can be contacted at 076 106 4443 or to BrexitCall@agriculture.gov.ie
Latest advice on gov.ie/brexit:
Further information is available from www.gov.ie/brexit. This website is regularly updated with the latest developments so do check back regularly.