There has been a change to the legal definition of an exporter. This means that companies who are not registered in the UK and who do not have any staff permanently based in the UK can no longer be the exporter of record for goods moving from the UK.
Many CILT members will be affected by this change if their clients are based outside the EU. At the time of writing the new law has only been operative for six weeks so companies are only just beginning to discover that their ability to trade under their current model is no longer legal.
The change will mean that companies must re-examine their trade flows and will most likely alter where they warehouse their goods and where they carry out logistics operations.
On the other hand, UK warehouse keepers and logistics providers may decide they need to become the exporter instead of their clients taking on many liabilities such as goods ownership and VAT accounting that were unthinkable at the beginning of the year.
If you are affected by this change you need to act now to limit the damage to your business and to work out if it presents you with other interesting opportunities.
In tandem with this is the government lead, HMRC crackdown on those seen to be abusing the ‘fulfilment house’ model in order to recover more than £1.5 billion in lost VAT and import duty.
The public consultation on this new set of regulations is open and CILT members are strongly advised to take part using this link
https://www.gov.uk/government/consultations/fulfilment-house-due-diligence-scheme
Further legislation and red tape is being drafted under the guise of the creation of a new business standard for those who undertake customs work for other companies e.g. freight forwarders, customs brokers etc. This new business standard expects in depth knowledge of customs legislation. The Standard will not be mandatory in the UK but how long will it be before commercial pressure from competitors and clients makes it ‘mandatory’ in order for your business to survive?
CILT members are entitled to take part in a consultation on the terms of the new Standard (it is not open to wider public consultation) and are strongly advised to make their thoughts known before it is too late. Access to the consultation document can be obtained by emailing CITC@ciltuk.org.uk.