The UK Internal Market Scheme – Benefits and Changes

[Note: The information contained herein is accurate at the date of this event, however please refer to the written guidance on the Northern Ireland Customs & Trade Academy (NICTA) website for the most up to date guidance.]

Good afternoon everyone and welcome to this webinar from the Trader Support Service or TSS providing further insight into the UK Internal Market Scheme also known as UKIMS. This is the third UKIMS webinar we have provided and we will today address some of the most frequently asked questions that TSS has received so far about UKIMS. On the next slide though you’ll see today’s agenda in a little bit more detail. We will begin with a brief recap of what UKIMS is.

We will then look at the benefits of UKIMS followed by information on how to use it.

Next we’ll go through some case studies and scenarios to help put UKIMS into a real life context. This is followed by a summary of the CDS changes highlighting the importance of uploading your authorisation letter and before wrapping up we will also answer some of the you’ve provided when registering and will be submitting in the live chat.

If you are new to the TSS or wish to find out more about it you can scan the QR code which is on screen at the moment and will be displayed at different points during the webinar or you can use links that we will be providing later on during the webinar or you can simply google Trader Support Service. On the next slide though to guide you through all of this it is my delight to welcome today’s speakers Shanker Singham, Maighdlin Gibson and Mark Brown. Shanker Singham is the Policy Lead of the Trader Support Service Consortium and plays a key role in supporting businesses move goods under the Windsor Framework. Shanker is one of the world’s leading international trade lawyers, a recognised author, advisor to governments and companies as well as an academic fellow of the Institute of Economic Affairs. Maighdlin Gibson is the Stakeholder Engagement Manager at the Institute of Export and International Trade. Maighdlin is a vastly experienced customs professional specialising in customs compliance and special customs procedures.

Mark Brown is the Policy Lead at HMRC NI Customs with extensive experience in both Whitehall and Brussels. Mark’s team is responsible for deciding policy aspects of the Windsor Framework including the UK Internal Market Scheme. Shanker will be explaining what UKIMS is, its benefits and how to use it. Maighdlin will then walk us through the case studies and scenarios. Then Mark will be providing a summary of CDS changes followed by the team collectively answering your questions.

However I’m now going to run a quick poll to find out a little bit more about you, our audience. So this one is asking are you currently authorised for the UK Internal Market Scheme? The answer options being yes I am authorised, no but I have applied to register, no I have not applied. While you’re answering that poll some quick housekeeping notes from me.

Firstly please feel free to use the GoToWebinar dashboard to post any questions you may have.

We will have a question and answer session at the end where we will address as many of your questions as possible and we will prioritise questions that are of relevance to the wider audience so we won’t be going into company or sector specific queries as such. If you are TSS registered and have specific questions we ask that you contact the TSS contact centre.

If you are not yet registered with TSS we encourage you to sign up for this free service so that we can support you if you have any specific questions. Finally a recording of the session will be shared on our NICTA website after today’s session over the next day or so.

So thank you everyone for answering to the poll. I’m just going to quickly close that and share the results. So well over two thirds of you are already authorised so 68%, only 5% are saying no but have not but you have applied to register while about just over a quarter of you have not applied at all. Shanker is that about what you would expect in terms of what you’re seeing in the marketplace at the moment? Yeah as we’ll go on to say I mean I think we have over 7,000 UKIMS registered traders in the TSS so I’m glad to see that number around about the 70% mark. I would and it looks like people have sort of made decisions about which category they’re in because that no number is quite low, no but applied to register is quite low.

I would ask people who are in the 27% no I haven’t applied category to really check that they can’t be UKIMS registered because I think there probably would be a few of those there who could be and hopefully at the end of the webinar we’ll pick up a few more registrations.

Absolutely well thank you Shanker. I’ll hide the poll results now and to on the next slide to get on with today’s presentation it’s my delight to hand over to Shanker. So over to you Shanker.

Well thanks very much William and so what we’re going to do on this presentation as William said is go over the UK Internal Market Scheme, the UKIMS. This is the enhanced expanded Trusted Trader Scheme which the Windsor Framework has introduced. It replaces the old UK Trader Scheme with which traders will be familiar. Basically UKIMS enables authorised traders to move goods into Northern Ireland in line with existing not at risk arrangements and to access the simplified process. We’ve talked to you previously about what is coming, the simplified process is coming from 30th of September 2024. Post command paper this is now referred to as the simplified process for movements from GB to Northern Ireland, internal market movements and we’ll tell you a little bit more about that in the next few minutes and if we go to the next slide please.

So obviously you’ve seen that we’ve had the Windsor Framework itself and we’ve had the safeguarding the union command paper which was published on the 31st of January 2024.

What we’re going to say in this presentation incorporates both of those documents.

So essentially under both of these documents the government is essentially guaranteeing smooth flow of goods between GB and Northern Ireland. This will be done through the new UK Internal Market System as distinct from the UK Internal Market Scheme. The system incorporates all of the simplified processes and everything else that we will be talking about in the context of this presentation. So goods that are moved under the Internal Market System can do so on the basis of a reduced data set. So this is commercial data and a little bit more with no requirement to submit the supplementary declaration and the only checks that will be used or deployed by UK authorities will be part of risk-based or intelligence-led approaches that are designed to tackle abuse of the scheme, criminality, smuggling, disease risks, that type of thing. So the critical thing here is to make sure you are registered with the UK Internal Market Scheme. All the processes from the UK Internal Market System come from that scheme. There’s further information on the Northern Ireland Customs and Trade Academy, there is a UKIMS introductory webinar which we did which is on the NICTA website. There’s a step-by-step application form webinar which is also on the NICTA website and of course you’ve got the usual gov.uk resources. So if we go to the next slide please. So the financial benefits we talked about previously in the introductory slide on this. These are benefits available for goods that are not at risk of moving to the EU. This started on the 30th of September 2023. That’s when the UKTS scheme was replaced by the UK Internal Market Scheme and essentially there is no duty for goods applying if they’re entering Northern Ireland from free circulation in GB. The UK duty applies if they’re entering Northern Ireland from outside the EU and the UK and the UK duty applies if entering Northern Ireland from GB and the goods were not in free circulation.

In addition, what we are going to see from the 30th of September 2024 is process benefits.

So the simplified process for internal market movements for GB into Northern Ireland is what we’re talking about here. This will be deployed as of the 30th of September 2024 and you will only need to submit internal markets movement information which is based on commercial information. You will not be subject to the ordinary international customs standard process that applies to other goods movements that will apply to movements that are not on this simplified process and there will be no checks outside of risk-based and intelligence-led checks that I discussed earlier. To access these two different kinds of benefits, you must be UKIMS authorised. So if we go to the next slide please. So what you do now with regard to the UK Internal Market Scheme. As I’ve mentioned, it replaced the UK trader scheme on the 30th of September of last year. You declare goods not at risk under UKIMS. You need to hold a valid UKIMS authorisation and this is the critical point that we really want you to take away from this presentation which is that the details of your UKIMS authorisation need to be entered on your declaration from the 24th of March 2024 and the UKIMS authorisation needs to be uploaded with the TSS ASAP. So if you have your UKIMS authorisation letter and you’ve done nothing with it, you do need to upload it on the TSS and we’ll be going over how that works in the rest of the presentation. If we go to the next slide please.

You can still apply. So for those 27% of people who aren’t on the scheme, have not applied, you can still apply. HMRC is still processing applications.

Providing as much information as possible on your application will speed up the process.

Now since the scheme was launched, we have actually had over 7,000 businesses who are UKIMS authorised. That includes 3,000 new businesses who weren’t on UKTS who are now on UKIMS which is obviously a good sign and sort of in line I think with that 68% number that we saw in the poll. And of those UKIMS authorised traders, they’ve closed 373,871 supplementary declarations as of UKIMS go live date. So the process is already there, it’s already working, people are already using it. If you’re not one of those 7,000 businesses, we would strongly encourage you to really check whether you can be UKIMS authorised and to make that application as soon as possible. This application process will not close. You can apply at any time and again, strongly encourage you to check whether it’s applicable to you because there’s a lot of benefits that flow from this scheme. So if we go to the next slide please.

If you are not on the UKIMS scheme or you’re not using it for a particular movement, all is not lost in terms of duty relief. There are other options that you can use for duty relief.

One, the first one is the Customs Duty Waiver Scheme. Some of you will be familiar with this.

It has been in place since the 1st of January 2021 and it is applicable to those goods that are moving at risk into Northern Ireland which are therefore liable to import duties.

And essentially, you’re allowed to use your de minimis state aid allowance to offset any applicable duty. And the maximum allowances for each sector which were updated in January of this year are listed out there. Because this is connected to the EU state aid system, the controlling numbers are the Euro numbers there, 30,000 for three years for fisheries, agriculture, 20,000 three years for agriculture and primary production sector and 300,000 for three years for other sectors and includes the haulage sector which was previously limited to 100,000 Euros. So those are the Euro numbers but we’ve also put the pound equivalent numbers there so you can get a sense of what that means for your business. If you can’t use or if you’ve exceeded your Customs Duty Waiver Scheme and your goods are remaining in Northern Ireland, if they’ve moved at risk from GB to Northern Ireland but they remain in Northern Ireland, you can still use the Duty Reimbursement Scheme, the DRS scheme which allows traders to reclaim EU duties paid on goods that have moved into Northern Ireland even if they’ve moved at risk. Now, the important thing to remember with the DRS scheme is that you are still required to supply evidence that your goods did not enter the EU. So in the same way that you provide evidence with your UKIMS that goods remained in the Customs Territory of the UK, you need to do the same with the DRS, same sort of evidence needs to be adduced there. And if we go to the next slide, please.

So the importance of uploading your authorisation letter. So again, I’m really, really stressing this because from the 24th of March of this year, i.e. in a barely 10 days time or just over 10 days time, two weeks time, if you use the NIRMS code without declaring a valid UKIMS authorisation, duties at the EU rate will be calculated and they will be charged to you by the CDS system if duties are due. So it’s really important that you upload your authorisation letter as soon as possible. If you’re registered on the TSS, upon receipt of the UKIMS authorisation letter, we’re asking you to upload that to your TSS account. This will allow us to auto-populate your authorisation information on your goods item lines for your declaration. So the thing you have to worry about is uploading your authorisation letter, then the TSS will take care of the rest.

If you have difficulty with this, if you require assistance, again, please contact us.

One of our agents will assist and we have a little extract there of the screen where you enter it on your company profile. So if we go to the next slide, please.

It’s very important to use the correct EORI number, whether that’s an XI EORI number or a GB EORI number. The UKIMS authorisation is granted, it’s for the trader and it is granted against the trader’s specific EORI number, which will be, as I say, either an XI EORI number or a GB EORI number, depending on whether the trader is a GB supplier using GB EORI number or a Northern Ireland importer. HMRC has recently written to all UKIMS traders and they’ve confirmed the correct EORI number and the authorisation number that you should use. So if you haven’t seen that letter, please look out for it. This is where you put the EORI number in the importer field on the declaration and it has to match the EORI number that is registered with your UKIMS authorisation. If it doesn’t match, then CDS won’t accept the declaration submission, so it’s extremely important that these two things match. If we go to the next slide, please.

So I think we’re going to do a poll before I hand over to Maighdlin.

Yes, absolutely. So just on the vein of the last slide, we’re going to run this poll asking you, do you currently use the correct EORI for your UK Internal Market Scheme, not at risk movements? The options being, yes, it’s the same. Yes, I’ve changed it.

No, I need to change it or not sure I need to check. And Shanker, just while people are answering that poll, we’ve had a question on that theme. It comes from Shane who asks, does a Northern Ireland business need to start using their NI EORI or can they continue to use their UK one? Right. So if you’re an importer in Northern Ireland, you should use your XI EORI number. GB suppliers, as I said in the previous slide, one of the things about the UKIMS scheme is a GB supplier can be registered as the UKIMS trader, in which case they will be using their GB EORI number. Terrific. Thank you, Shanker. I hope that’s helpful, Shane and to everyone else on the call as well. So I’ll just give you three more seconds to answer the poll. Countdown, three, two, one. And let’s have a look at the results. So quite a mix. So 46% of you saying yes, it’s the same. 12% of you saying yes, I have changed it. So over half of you are confident you’re using the correct one. But over a third of you saying you’re not sure. 5% of you know that you’re not, but you know that you need to change it. Maighdlin, if I can bring you in at this point.

That’s quite an interesting response there. What do you say to that response from the audience in terms of the use of EORI numbers? Yeah, it is, it is. But I think that’s a good thing that people are saying that they need to check. So HMRC did send out letters to everybody as well as the TSS just to confirm that. So if you want to just have a look for those letters, but if you’re unable to find those letters, you can contact the TSS and raise a case and we can look into it for you.

And just ensure that your correct EORI is set up for the 24th of March.

Terrific. Thank you, Maighdlin. And thank you everyone for responding to the poll as well.

All right. So hello, everyone. So I just want to go over some of the real life scenarios and why UKIMS can be of benefit to your business. So this slide here, we’re just going to look at Erin and Linda. So Erin and Linda both supply sportswear based in GB. They import it from around the world and they import it into free circulation into GB and then sell it on to independent and chain retailers throughout the UK and including Northern Ireland. So if we take for example Erin, so Erin is UKIMS authorised and Linda is not UKIMS authorised. So if these two ladies were bringing in, sending over a pallet of tracksuits, so say we use 200 tracksuits, the value of them is £70 each. So whenever those goods are coming into Northern Ireland, they have to establish their at risk status. So because Erin does have her UKIMS authorisation, she is allowed to declare her goods as not at risk and including her UKIMS authorisation information on the movement.

So because Erin has moved the goods not at risk, Erin doesn’t need to pay any duty. Now Linda on the other hand, she is still selling to shops in Northern Ireland. It’s still the same situation, the exact same tracksuits from Thailand for example and she’s moving them in. Because Linda isn’t UKIMS authorised, it means whenever she sends the goods to Northern Ireland, the applicable duty rate will be charged and using the example of tracksuits, that’s actually sitting at 12%.

So between Erin and Linda, Linda is having to pay out £1,680 of duty whenever those goods move into Northern Ireland. Now through the Windsor Framework and the protection of the UK internal market, Linda does have recourse to be able to reclaim that duty paid and she can do that through the duty reimbursement scheme. But even though, as it says, the process simplifications that we’re talking about in UKIMS aren’t until the 30th of September, we still can see that Erin does have that benefit over Linda. Erin can send her goods, her UKIMS information is all on it, she doesn’t have to concern with duty. Whereas Linda will have to gather proof and make an application to the duty reimbursement scheme to get her money back. So as we can see here, it says two different traders with two different situations in how their goods are treated just by having that UKIMS authorisation. So if you move to the next slide please. So this slide, it says this is just a current overview of how the Internal Market Scheme journey is working at the minute before the 30th of September. So it says by now you’re probably all very used to this, so it says we’ll just kind of fly through this one. So we’ll prepare for the goods movement and it’s important, it says whenever you’re preparing for the movement, that you establish whose UKIMS authorisation is going to be used. Is it going to be the supplier? Is it going to be the receiver? And this is a commercial agreement that people will have to come to just as they’re doing their day-to-day business.

So once the goods are being moved away from movement, the haulier is going to raise your safety and security exit summary declaration or your ENS as it’s shortened to. And it’s very important there at the ENS stage that the haulier uses the correct EORI for the UK Internal Market Scheme authorisation that’s going to be used in the movement. So if it is the GB suppliers, if their UKIMS authorisation is registered to their GB EORI, then they must ensure that their EORI is in the importer field on the ENS whenever it goes, it’s being created by the haulier.

So again, this is when we go into, we’ve created our ENS and SFD if required and then we create the GMR in order to move the goods on the ferry over to Northern Ireland. So the goods move into Northern Ireland and then post movement, a supplementary declaration is completed with before the 10th calendar day of the following month. So this is our current process and if we can go to the next slide, this is what the UK Internal Market Scheme journey is going to look like from September. So we have two options for the internal market movements from September and this first one here is where the information is shared up front. So we’re still on the same, you know, establishing who’s using the UKIMS and then we also then create the ENS as normal.

Now at the time when the ENS has been created, if the commercial information that’s required, so if that says if it’s available or it says it’s available in your Trader’s Goods profile within the TSS, all that information can be submitted at the same time as the ENS. So at that point then, it’s all submitted, the MRN is added to the GMR, you get your ferry over and then finally when we get to the post movement, if Phil you can just hit, no action is required, there’s just no further action, it’s all handled up front. So once the goods have left, if the data entry is being completed, they don’t need to be thought about again. So there’s no need to keep track of things for further supplementary declarations that can all be done up front. So if we go to the next slide, so this says is also people will have the ability to use the simplified data set but post movement.

So this is very similar to our current journey where it says you prepare your goods for movement, you create your ENS, you get your GMR. Now it says post movement though, it says then at that point the commercial information is uploaded onto the TSS. So it says it can either be by the sender or the goods or the receiver depending on the commercial agreement, it says who’s responsible for uploading that and who’s UKIMS authorisation that they’re being or they’re going to be used.

So as it says if you have all your information on there, TSS is going to populate, auto populate a lot of fields as well and again it’s just the ordinary commercial information that you need to apply post movement. So this is if you know maybe you do already have the established system and you’re just happy enough moving a post movement way, you know this could be either because you know maybe the invoice isn’t available or there’s some other documents not available or maybe you’re just not sure exactly if they are at risk, if they’re not at risk, you know if you if this information is known post movement you still can avail of the specialised or sorry the simplified process. I think we’ll move on to the next one please. So here again we you know under the UK Internal Markets Scheme and this is the new processes, you can move goods as mixed loads.

So consignments don’t have to be you know 100% UKIMS or 100% non-UKIMS qualifying, you know there can be that mix, you know so say for example you were selling to some goods and say 80% remained in Northern Ireland or 20% then went on to Ireland, you know you can still move them it says just as that mixed load. So again but you can prepare for your goods movements and you can create your ENS. Now again if you have the commercial information for the UKIMS qualifying goods that again can be entered at the ENS stage if you have that already or alternatively after the goods are authorised for movement and are then in to arrive in Northern Ireland then for the goods that qualify for the simplified process then you enter just in the commercial information into TSS but then you will need to complete the normal standard process then for the goods that don’t qualify. So you can as it says you can have the mixed goods through the UK Internal Markets Scheme and it says as well that’s also for group each consignment so you know you can also have from different number of different suppliers it’s not all required to have you know one simplified load and one standard load you know they can all be it can just work to what your business wants what your business needs are. And if we can move on to the next one.

Oh sorry I think that’s me. So yes so it just says one let you know that there are it says there’s the process benefits that you can avail now by having your UKIMS until you don’t have to go through the duty reimbursement and then in September you can have everything up front and you don’t have to think about the movements then after the fact. So I believe I’m going to be hanging handing over to my colleague Mark Brown from HMRC.

Hello thanks Maighdlin and hello everybody. So over these next two slides I wanted to draw attention to the specific changes that are being made to the customs declaration service for movements into Northern Ireland from the 24th of March. We have as has been mentioned already directly contacted around about 13,000 traders who currently move goods to Northern Ireland to notify them of the changes but we are keen to ensure that the changes are noted and understood. The main change as we’ve been saying is that if you use the NIRM code without declaring valid UK Internal Market Scheme authorisation duties at the EU rate will be will be charged it will be calculated and may be charged to you by CDS if duties are due.

On this table so the table you’ve got in front of you and the first point I wanted to note and it relates to how you declare goods not at risk using your UK internal market system UK Internal Market Scheme authorisation. If you are currently using the TSS portal to do so and you’re selecting the NIREM option from the drop down menu and there should be no change and you will continue to be able to do so in the same way. However as we’ve been saying due to the kind of new changes for the 24th of March to get that correct UKIMS treatment you will need to ensure firstly that you have updated the TSS portal with details of your authorisation, secondly that you’ve uploaded your UKIMS authorisation letter and thirdly check that you are using the EORI number which is associated with your UKIMS authorisation and as we’ve been saying we have been contacting UKIMS authorisees in recent weeks with the details of the EORI number that’s associated with the particular authorisation. The second point to note relates to when goods are not at risk due to the applicable duties. In the case of movements from Great Britain to Northern Ireland that’s where the applicable rate of duty is zero and on movements into Northern Ireland from a country outside of both the UK and the EU, what we would call rest of the world, that can be the case where the EU rate is equal to or less than the UK rate. From the 24th of March CDS will automatically check the applicable EU rates of duty and take into account any claims for preferences or reliefs. So for instance if you are claiming preference under the UK EU trade and corporation agreement, if you intend to make any claims for preference or reliefs you must ensure that you include these when you’re making your declarations to CDS or through the TSS portal. We do have guidance on Gov.uk which sets out the different types of preference or relief which mean you might be able to bring goods into NI from Great Britain without paying duty. Final point to note on that is that because the calculation of whether goods are not at risk there is not being automated. You should no longer use the NIREM option on the TSS portal for goods that don’t meet the criteria to move under UKIMS.

Next slide please. Thank you and then the next change concerns when you are declaring goods that will be subjected processing in Northern Ireland and which do not meet the additional criteria which were agreed under the Windsor Framework for them to be considered not at risk.

From 24th of March you must select the new code NIPRO from the drop down menu. As I say this is a new code that is being introduced as part of the new release and the reason for that is because goods that will be subject to processing in Northern Ireland are automatically at risk unless they meet the additional processing criteria and you must not use the code NIREM on those goods because NIREM is for not at risk goods. And then the fourth change, fourth and final change here to note relates to tariff rate quota goods which at this moment in time sort of means movements of steel. It’s quite an important change so kind of keen to underline it for those traders who it applies to. So from the 24th of March you or your agent should no longer use the code NIREM for the steel goods but instead select the code NIQUO when using the TSS portal.

And this is as is but if you use the code NIQUO to move steel subject to safeguard charges from countries outside the UK or the EU to Northern Ireland you need to provide the relevant UK quota order number as well. We are contacting steel traders directly over the next days with specifics of the changes.

Before I hand back I’m aware there was a question asked ahead of the webinar about whether it was useful for steel traders to apply for UKIMS particularly where they cannot are able to guarantee that the materials will be for final use or used as part of construction in Northern Ireland. I think it’s fair to say that I’d advise that UKIMS authorisation isn’t required in order to claim quota under the steel arrangement. So maybe the UKIMS authorisation isn’t particularly useful for those movements but the changes we are making does make it all the more important to ensure the NIQUO code has been used in the 24th of March and I wanted to make that point. For all traders there may be other goods that are moving that offer end use in Northern Ireland that being moved across where the traders could benefit from the UKIMS authorisation. So notwithstanding what I’ve said I’d definitely urge everybody as Shanker has been doing to consider their eligibility and the usefulness of a UKIMS authorisation and with that I’m happy to hand it back. I think that was the end of my slides.

Terrific thank you, thank you Mark and if we go to the next slide.

Yes we’re on to the Q&A. So thank you to Mark, to Shanker and to Maighdlin for providing all that detail on UKIMS. We’re now going to answer some of your questions over the next few minutes and thank you everyone for sending in so many questions. We’ve had loads come through so we’ll try to get to as many as we can. We’re going to broadly group questions together and ask things which have been commonly asked by lots of people and so apologies if we don’t get to every single specific question there just isn’t going to be time so I’ll leave you to the number of questions we’re getting. But the first question I’ll put to Maighdlin comes from Natalie and a few people are asking this. So Natalie’s asked how do we as the sender sending goods DAP to the customer in Northern Ireland know whether the goods will travel in the red or the green lane and I should say that we’ve been getting this question from quite a few different types of people including freight forwarders, hauliers so quite a spread there. So Maighdlin over to you. Okay so it’s really important that you know you’re having your conversations with your suppliers and your having conversations with your recievers, it says if you have to ask them you know what is the end use of the goods. Now it says if you’re providing that on the DAP basis as says you’re you know as the NI receiver is the one going to be responsible for completing the supplement for the completing any information for the movement.

So in those situations what you can do is if we go back then to the kind of the post-movement journey that we talked about earlier. So this is where you kind of the first stage of the journey you would follow this the current process where we are at the minute where there will be an ENS raised and then there will be either well as says SDE or EIDR record made either in your own or with TSS.

So as a supplier you can do that and then it’s still you still have then up to the 10th working day of the following month for the NI receiver then to put that information up on the TSS portal.

So even though as says at the time of movement it’s not known whether the goods are going to be at risk or they’re not at risk you follow the first the first couple of steps and then the NI receiver then is able to make that decision and give that information post-movement.

So again within the TSS you know if that if as I said you send something out and follow oh yeah we’re not too sure and then the goods are found to be at risk either because of you know physical at risk or they maybe don’t qualify under some of the UKIMS exceptions.

It’s no problem as we in the TSS we can help support those different types of journeys and support the end receiver in completing their declaration or submitting their commercial information.

Thank you thank you Maighdlin hope that’s helpful Natalie and to the various other people asking that question. One following that from Benjamin who asks what other responsibilities of a company based in England selling to customers in Northern Ireland? I think that’s for you again Maighdlin.

Yeah so again this comes down to a commercial arrangement between the GB business and the NI business. So yeah you’re not under any you know legal responsibility to do anything it says you can agree that okay my Northern Ireland receiver has UKIMS will sell the DAP they’re responsible for everything or alternatively as a GB supplier if you wanted to offer that customer experience where they can order from you move the goods under your UKIMS authorisation so the Northern Ireland receiver doesn’t have to do anything as this all comes down to the individual business arrangement. Now one thing that I do want to say though is if you are a GB supplier just again make sure that the haulier is aware that it’s going to be your UKIMS that’s going to be using and that you know to ensure the correct EORI is put on the ENS and then anything else is the importer.

Terrific thank you thank you that’s helpful Benjamin and one more for Maighdlin now question from Gavin who says we sell from GB to distributors in NI unless goods are project specific how can any distributor guarantee they are not at risk?

Well it says you can’t it says really guarantee that they’re not at risk but again it’s the importance of having these conversations you know try and find out what is the end use of the goods so under the UKIMS scheme you can make a sale to one subsequent entity so if we’re using this example then it would be a GB supplier sends to a Northern Ireland distributor that can move under UKIMS and the Northern Ireland distributor can then sell that on to other retail businesses within Northern Ireland that’s fine so it says again it’s important that you have these conversations and you know where you’re going to be with your , you dont just send something out, you still have to actually ask what is the end use but it says always do consider that one additional step that is required because you could be selling something to a wholesaler who does maybe serve both Northern Ireland and Ireland and you know maybe not they’re not 100% sure but they can as says they can then still move those goods under UKIMS it’s not always going to be at risk it says it’s again just checking what is going to happen to your products because it could be your products are only sold in Northern Ireland and they maybe sell some other products in Ireland you know so it’s important that you have those conversations with the people that you’re doing business with. Terrific thank you Maighdlin so I think it’s know your goods and know where they’re going to end up things are big things to know in this context. To bring Mark back in so we’ve had a question from Andy who says when will we know the exact details of what extra or different information will be required pre-movement? Yeah thanks Andy so I think this is a reference to the sort of simplified processes that will come into place from the end of September and we agreed the data set with the EU sort of as part of the Windsor Framework negotiations and it significantly reduces the number of information items required from a sort of standard declaration to which is around about sort of 80 fields to less than half of that in most cases you know it’s me in all cases to it so and that creates a sort of new data set which as Shanker was saying is drawn from ordinary commercial data and that was a key point in the negotiations but there will be slightly different requirements according to the sorts of sorts of goods being moved and we recognise that there is there is interest and understanding exactly what the requirements for in each of the you know each of the different cases and to date while our focus is on getting UKIMS sort of up and running and that’s been our focus and that’s kind of the focus here we know we need to provide some detailed guidance on that in the coming months and will do to help traders prepare so they know what the information points are compared to what they may be providing now through standard declaration processes.

So thanks Mark and it should always be said that obviously there’ll be plenty more information being posted across our things like NICTA and on Gov.uk as well. Question bring Shanker back into the fold I think so we’ve had a question from Atif who says do we have to ask our customer regarding the final destination of each item and Atif supplies fasteners to Northern Ireland?

Yes so I think this question sort of highlights what we’ve been talking about before the importance of talking across the supply chain and figuring out who is responsible for what. So yes you do need evidence that the goods do stay in the UK customs territory you are able to make sales can be made to one subsequent entity so you can have GB NI wholesaler NI wholesaler selling to retail but it is really important the end user has to provide that evidence so it’s super important that if you’re buying from a GB supplier that you and the GB supplier talk to each other about the requirements that need to be fulfilled and you decide who and this also goes to the issue of when we have the simplified process in place and remember Maighdlin’s slides about when that information is provided suppliers and receivers of goods need to have agreed who is providing that information and when.

So thank you thank you Shanker I hope that’s helpful Atif. Question in from Paul we often get questions on templates so Paul says is there a template that can be used as evidence that our sold to customers in Northern Ireland are remaining within the territory?

Yeah I mean so we do get this question a lot and is there an available template I mean I just want to stress that this is a trusted trader scheme the UKIM scheme and you do need to actually provide evidence that you know the goods are staying in the customs territory it isn’t a you know tick box exercise it’s a real thing you know so and that’s why you know there isn’t really a template there’s also no particular type of evidence that is required you know you can use whatever evidence you have that satisfies the question so there’s no template per se but at the same time you know HMRC will allow you to use whatever evidence that you have available to you to prove this.

Thank you thank you Shanker. A question from another Gavin who’s asked we’re just a Haulier. I don’t think just Haulier is a thing but we’re just a Haulier but do submit ENS declarations on behalf of our customer how important is UKIMSA to us?

Shanker I think that’s for you. That’s for me okay yes just to just to repeat there’s no such thing as just a Haulier. Hauliers are incredibly important in this whole arrangement. I would say if you’re a Haulier and I think I presume that the person’s talking about the UKIMS UK Internal Market Scheme we’d say that first of all there’s a general principle the UKIMS UK Internal Market Scheme is for the trader so it’s the trader’s authorisation number so it’s not required for a Haulier but as Maighdlin said hauliers may want to offer a service to their traders where they use their own UKIMS number to offer that service. The only thing I would say in that case is if you are going to do that then you need to recognise that you’re becoming the importer of record and you have all the obligations of the importer of record in that case so you have to have that kind of relationship with your customer where that is appropriate. The only other thing I’d add is that hauliers may also want to remember that you also have your own sort of consumable items so whether it’s stationary, pallet blankets, all kinds of things you might want to register with UKIMS for those reasons and that would be entirely appropriate. So you can do it if you want to provide that service to your customer but it’s not required that you do.

Thank you, thank you Shanker and thank you Gavin as Shanker says Hauliers is very important in all of this and apologies for not catching the typo there it was obviously UKIMS.

Question from Gillian which I think is also for Shanker, Gillian has asked business to business parcels what information will be required from who and when? So business to business will be regarded like a freight movement so UKIMS will apply and if you want to for a business to business movement you want to use the simplified process then you can in the normal way. So UKIMS applies, everything we’ve said about UKIMS here for the traders applies to those B2B movement. Oaky doky, thank you very much.

One more for Shanker at this stage, question from Albie, as a GB based wholesaler exporting B2B via DPD is it our customer’s responsibility to apply for UKIMS and make declarations?

Yeah so very much as I said before the importer is the UKIMS authorisation holder so you need to think about what agreement you have between the parties about who’s actually completing what and then the actual movement the B2B movement is going to be analogous to a freight to a freight movement. There’s one last question on this theme and I’ll maybe bring in Mark at this stage, it’s a question from Jackie who asks how does it work if you use an intermediary parcel company for business to business trade from GB to Northern Ireland? Mark. Yeah I mean I think so in that in that case if it’s business to business trade I think it is the same as Shanker was saying just now so the process will apply in the same way. There are different schemes, different rules that apply for sort of C2B and B2C freight with the UK carrier scheme and then also you know the C2C freight and there’ll be a different process with individuals moving goods much the same way as they do now. In this case it should be the same yeah it should be the same. So UKIMS kind of authorisation is potentially extremely useful to people using freight in that in that way. Perfect thank you, thank you Mark. Another question for you, one and we’ve got about five or so minutes more of questions so I’ll rattle through these at a bit of a pace. Question from Noel, what benefit does UKIM’s have for business with a turnover greater than two million pounds although most of our imports will remain in Northern Ireland?

Thanks that’s a good question. So it’s an important point for us to recall so the turnover threshold is only relevant if you are moving goods that are subject to processing in Northern Ireland and all other goods so whether that’s machinery, office materials that are moved by manufacturers can benefit from the full UKIM’s criteria. There isn’t a kind of turnover limit there provided it can be demonstrated that the goods will remain in NI or I mean in certain cases they move back the other way somewhere within the UK. Can add as well for businesses who are involved in processing even if they’re above that two million pound threshold that they’re able to move goods which are subject to processing if they’re in particular sectors so animal feed, healthcare, construction, not-for-profit but yeah definitely value potentially for businesses with a higher turnover. Thanks Mark I hope that was useful Noel.

Let’s bring back Maighdlin for a few quick questions. So Maighdlin a question from Dinesh who says we currently run an API process to complete SDIs, can we continue to use the same even though we are registered under UKIMS? Yes so that’s one of the things I know it’s maybe sometimes it can be a bit overwhelming because we’re you know we’re giving you lots of journeys but really what this is about and what’s coming in September is the flexibility for your business so it’s not mandatory to update your API you can still continue you know if what if how you’re working is working well for you then you know you can still continue to use that and so we do have it could be upfront, it could be post-movement, it could still be as the reduced data sets or you can still use the SDIs there’s a lot of flexibility built within the process so it’s not mandatory as it says at the minute I would say at the minute that sounds like it will be mandatory but yes it’s not mandatory to change to any of these processes as this flexibility has been built so businesses can really avail in the best way that they can for their business and how their business runs. Thank you thank you Maighdlin and a question in from Arthur who says are there plans for enabling bulk uploads for larger traders? Yes so this is our API service so we do have a currently API service who says you can bulk upload your information for your supplementary declarations and there will be a new API for the reduced data set come September so any current API customers will be contacted by the TSS in the coming months if you’re currently not an API user and you could be interested in it maybe this is as part of your UKIMS application you’re doing a revamp and maybe you want to get under the API if you want to contact the trader support service then the API team can speak to you. Terrific thank you thank you Maighdlin a question from Jonathan can we submit using TSS entries for goods to Northern Ireland ourselves or do we have to use an agent? So again it says it’s up flexibility is up to you as the business so you know if maybe you’re only moving a handful of movements every month you know it might be easier for you to use it on the do the TSS entry yourself whereas you might have lots of movements and it may be easier to do avail of an agent services maybe if you don’t have that in-house expertise to use an agent but it says it’s not mandatory it can be you it can be your it can be your agent who enter the information on TSS. Thank you Maighdlin let’s have another question for Shanker just around TSS this comes from Beth, Beth asks is UKIMS replacing TSS or do UKIMS and TSS run at the same time? Yeah so TSS is there for traders to support all of their movements GB NI. UKIMS is just a one of the schemes that applies so they’re not UKIMS is not replacing TSS it’s just one scheme we can help you with UKIMS as we can help you with all the other elements of GB to NI trade.

Thank you, thank you Shanker, thank you Beth another question for Shanker, this one comes from Jan or Jan if we are bringing a mixed load over including some NIREM some at risk do we tell our transporter to use our XI EORI number? Yeah so in general terms you should always use your the EORI number that’s connected to your UKIMS authorisation that is the if you’re using UKIMS that is what takes priority so in that case you would advise the person who’s submitting the ENS for you to use your XI EORI number in this case.

And just to another question just on XI EORI’s we’ve had a few one from Iman who says do we start using our XI EORI number now? Yes yeah I mean you should have had a letter from HMRC if you need an XI EORI number you can get an XI EORI number and use it if you cannot get an XI EORI number because you’re a GB supplier for example you can use your GB your GB EORI number but if you’ve not heard from HMRC then certainly you can ask the TSS to help you and we can connect you and so on.

Thank you, thank you Shanker. I’ll do two more questions so one from Teresa has just come in might be one from Maighdlin. Teresa has asked should we add disclaimers on our invoices as I’m in England selling to you in Northern Ireland as far as we are aware the goods are staying in Northern Ireland and hence you will be liable for any back duty claims should the goods leave Northern Ireland. Maighdlin?

Yeah no this is that’s a it’s a good one to have on your commercial and it says on your on your commercial documents that this is what you’re doing and this is as well this is what you’ve been told as well from your from your receiver that you know you have to do this and you can have that on your paperwork so it says yeah it’s a good idea to have that on your paperwork so it says especially if you are doing the mixed you know you can indicate yes this is a UKIMS movement on the paperwork as well and this is yeah it says although it’s maybe not really very good for the proof you know if it was ever to come up updated it is good it’s still proof for you and it says if you can combine that with the POD you know you’re you’re definitely meeting your criteria to prove that the goods remained in Northern Ireland. Thank you, thank you Maighdlin and we’ll do one last question this one comes from Andrew who asks we have suppliers not wanting to supply us because of the additional paperwork involved in registering for UKIMS what should we say to them to make them change their mind? Mark do you want to come in on that?

Yeah I mean there may be other maybe other views on the line as well I think I think we would say we’ve tried to keep the process itself of applying for UKIMS more streamlined I think I appreciate we can be it can be quite an intimidating process potentially if you’re not used to it but certainly we in HMRC are keen to help and I’m sure TSS colleagues are able to kind of help as well or offer advice and clearly yeah clearly we think there are significant benefits of being UKIMS authorised that we’ve tried to point to and through this call and yeah hopefully as we say more you know if they’re not budging that we as we say more about kind of how the process will look well you know people will see and find that to be you know an attractive much easier and more commercial looking process and but yeah appreciate them yeah that some of this is things that people aren’t doing a huge amount of at the moment. Yeah I mean I would just add one thing to that which is the for most cases it’s the Northern Ireland receiver who is going to be the UKIMS registered trader so you can tell your GB supplier that they don’t actually have to do anything that the Northern Ireland receiver will do that and if your business terms are different then you know and that is creating a problem for you then you can always change them so the aim of all of this is to make this as flexible as possible and provide as much optionality as we can so whatever your business model your supply chain is it works it works for you and conversely there may be also cases where the GB supplier wants to do everything and that’s also that’s also fine. Shanker, Mark, Maighdlin thank you so much for answering the questions there I think we’re gonna have to wrap up now we are quickly running out of time so just before we do one final poll and this one is just asking you have you uploaded your UKIMS scheme authorisation to TSS and the options are there on the screen just while you’re answering my poll let’s say thank you everyone for asking so many questions we hope we’ve been able to cover a decent range of those please do remember that if you are TSS registered and have further specific questions we ask that you contact the TSS contact centre if you are not yet registered with TSS we will encourage you to sign up for this free service so that we can support you if you have any specific questions I’ll give you a little bit longer to answer that poll but it’s quick notes as well but I have shared some links in the chat to TSS to Northern Ireland Customs Trade Academy and also to UK government’s advice around UKIMS as well and so hopefully those links are also helpful so I’ll just give you three more seconds to answer that poll three two one and here are the results so over half of you say yes and you’re ready fantastic just under a fifth of you saying no you do not have UKIMS authorisation or you’re not sure I need to check and six percent of you say no but you’re going to do this now so thank you everyone for responding to that poll. If you can have the slides back up we’ll just do a couple more very quickly so yes just a reminder that if you still have not applied for UKIMS it’s not too late and there’s plenty of support available on Gov.uk on the Northern Ireland Customs Trade Academy and on TSS as you can see in the slide and as you can also see in the chat. On the last slide you’ll see some information about how you can get further support on things like UKIMS, including the QR code which takes you to the TSS website and as said those links are in the chat, for further information do you keep an eye on the TSS website or refer to the website of the Northern Ireland Customs Trade Academy which is often shortened to NICTA or call the TSS contact centre for advice on the number provided the TSS bulletin also contains important information for TSS users and that’s sent via email and can also be found on the NICTA website we do have a upcoming series of webinars over the coming months covering the other aspects of the Winsdor Framework in more detail including the new process so yeah keep an eye out for webinars which are coming up over the next few weeks and months, remember that this webinar has been recorded and we will be uploading it to the NICTA website shortly but for now that’s all the stuff for me to say is thank you everyone for attending for asking questions and to the speakers for presenting so well as well so thank you everyone and have a great rest of the day. Bye.