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No-deal Brexit: An EORI number will be essential

In the event of a no-deal Brexit, all businesses that move goods between the EU and the UK will need an Economic Operation Registration Identification number issued by the UK in order to clear those goods through customs.

5th Sep 2019
EU and British cargo containers
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The UK will leave the EU by automatic operation of the law on 31 October 2019, unless the UK Parliament does something to stop it.

If there are no arrangements in place to temporarily keep the UK within the customs union, ie a no-deal Brexit, import and export procedures will change immediately at 23.01 on 31 October (00.01 on 1 November French time).

All businesses that export to, or import from EU countries will need an Economic Operation Registration Identification (EORI) number issued by the UK, otherwise they will not be able to keep trading with EU customers and suppliers.

There are different procedures in place for moving goods between Ireland and Northern Ireland, so businesses that only move goods across the Northern Irish border will not need an EORI number.  

What is an EORI number?

Businesses that currently only trade within the EU will not be familiar with the EORI system as it is not needed when goods cross borders between EU countries.

The EORI number has 12 digits and if the business is VAT registered the EORI number will incorporate its VAT registration number. The EORI numbers issued to UK-based businesses start with “GB”.

If the business has been trading from one of the other 27 EU member states it may already have an EU EORI number. This EU EORI number will remain valid after the UK leaves the EU, but only for communications with customs authorities in those 27 EU member states.

Businesses that conduct trade from the UK after Brexit which export from or import into the UK will need to make customs declarations in the UK and to do that they will need a GB EORI number.  

Automatic allocation

HMRC is automatically allocating EORI numbers to 88,000 VAT registered traders which it knows have traded with the EU in the past and don’t already have an EORI number. The letters informing traders of their new unique EORI number should arrive this week.

However, many more businesses who are not VAT registered will also need an EORI number. If your client imports goods from the EU, or exports any goods to customers in the EU, even very small amounts, they will need an EORI number to clear those goods through customs. Those businesses need to apply for an EORI number as soon as possible. Most EORI numbers are allocated instantly but some may take up to five days to be approved if HMRC needs to undertake additional checks on the business.

VAT payments

In addition to clearing customs, UK businesses will have to pay VAT on any goods imported from the EU into the UK. A trader can register for transitional simplified procedures (TSP), which is an additional process to the EORI number. There may also be tariffs to deal with on certain goods, and health and safety certificates.

There is a lot to understand about importing and exporting post-Brexit, but fortunately the French Customs authority has provided a useful guide, written in English.

Replies (6)

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By mkowl
05th Sep 2019 09:38

Can we not just export 650 idiots that currently work in Westminster

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David Ross
By davidross
05th Sep 2019 10:44

"businesses that only move goods across the Northern Irish border will not need an EORI number"

Big surprise - we do have a unique relationship with Southern Ireland that pre-dates the Superstate and Project Fear has been scaremongering

"HMRC is automatically allocating EORI numbers to 88,000 VAT registered traders" - as it should

Thanks (1)
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By SteveG0
05th Sep 2019 11:52

Hi Rebecca
A very interesting article and associated PDF. Thank you very much for these.
I do have a question - as a non-Accountant - relating to Services. I deliver a small amount of training / consultancy in Europe - through my own Limited Company - charging VAT in line with "Supply liable to VAT in the customer’s country under the reverse charge rules". EORI appears to apply to Products rather than Services. In November I have a piece of work in Germany, however I'm confused as to how I will invoice them? Does EORI apply to 'me'? Should I be doing something else?
I'm not sure if I should be asking this question on this forum, however I'm unsure who I should be speaking to? Any help or 'pointing me in the right direction' would be greatly appreciated.
Kind regards
Steve

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By Graeme G
05th Sep 2019 13:07

Very informative article, thanks.

One thing I would add: don't forget to talk to your suppliers and customers in the EU to ensure they have an EORI.

Brexit is high on the agenda for many of us as UK importers/exporters, it may not be so for our EU-based suppliers and customers especially if they are only used to dealing with other EU countries...

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By martinengland
05th Sep 2019 18:38

davidross wrote:
Big surprise - we do have a unique relationship with Southern Ireland that pre-dates the Superstate and Project Fear has been scaremongering

Unfortunately, all of those arrangements - every single one of them - have been superseded by the Treaty of the Functioning of the European Union ("TOFU") et seq, the European Economic Area Agreement ("EEA") and the European Common Aviation Airspace Agreement ("ECAA"). Even the old three-country horse transport arrangements between Ireland, France and UK now comes under the European rules relating to the transport of livestock.

Unless the UK somehow convinces EFTA to accept UK's membership, then signs the EEA and then adopts ~120 protocols to sew EFTA law into UK law, then immediately upon the UK leaving the EEA (implied by its "no-deal" departure from the EU), there will exist a hard border between Eire and Ulster. No ifs. No buts. No exceptions. No magic wands. No walls, barriers, fences or gates, either. While still in the EU, UK cannot join EFTA, sign the EEA or incorporate the protocols, unless such moves had been sanctioned by a Withdrawal Agreement (which the current draft does not). And incorporating the protocols is about 18 months of work for a competent civil service (you can see the problem here, too). In addition to EFTA/EEA/protocols, UK will also need to sign the ECAA to ensure flights between Ulster and Eire after the first few months of the "no-deal" departure.

The EU spells all of this out very clearly in its notice to stakeholders. Although you do need to have read the TOFU to understand just how raw the notices actually are (without such knowledge, the notices seem like innocuous words). Note that the UK fakestream media saw fit to airbrush these inconvenient truths of out existence.
https://ec.europa.eu/info/brexit/brexit-preparedness/preparedness-notice...
Summary: page 4 of http://www.douane.gouv.fr/Portals/0/fichiers/douane/brexit/brexit-custom... But REMEMBER, the douane are only interested in customs. For third-country importers into the EU, conformity assessment happens FIRST, long before the goods ever get as far as customs.

As to the article, well, it's just propaganda. Only EU member nations can issue EORI numbers. So the UK can currently issue EORI numbers because it's an EU member nation. But on Brexit day, UK ceases to be an EU member nation. So the UK-issued EORI number is immediately, instantly, overnightedly void. Only with a Withdrawal Agreement in place would there be a transitional period during which EORI registrants would migrate from an EORI-based working method to alternatives applicable to third-country importers into the EU. The chances are, the UK exporter would need to incorporate an EU company to act as the responsible party for imports into the EEA and thereby apply for an EORI number in its home state. See also:
http://eureferendum.com/blogview.aspx?blogno=86387
http://eureferendum.com/blogview.aspx?blogno=87320 (towards the bottom)
http://www.eureferendum.com/blogview.aspx?blogno=86251 (a critique of the "mutual recognition of standards")

However, don't panic, because Brexit probably isn't going to happen anyway. Also airbrushed out of existence by the UK fakestream media is the continuing integration of UK military forces into the prototype European Defence Force. It's as if the Withdrawal Agreement is being implemented without Parliament's approval. See also:
https://www.ukcolumn.org/series/eu-military-unification

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By EnglishRose
11th Sep 2019 08:52

I had read elsewhere that if we crash out on 31 Oct then UK issued EORI numbers are invalid as we are no longer part of the EU.

Separately a lot of people want to know about services as lots of UK businesses provide services not goods these days so an article on services would be useful too.

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