Brexit Bulletin - 26 April 2021



Dear Bettina


Political focus remains on resolving issues related to the Northern Ireland Protocol, with Cabinet Office Minister, Lord Frost visiting Brussels for talks with EU Commission Vice-President Maros Sefcovic. With eight days to go before the expiry of provisional application of the EU-UK Trade and Cooperation Agreement (TCA), the EU Parliament announced that a plenary vote will take place on 27 April 2021. This should provide more certainty and allow for continued discussion on matters yet to be resolved.


Next month, as part of our Managing Brexit activity, ADS is joining up with the Aerospace Technology Institute to hold an information day focused on European funding opportunities. The online event will cover R&D funding post-Brexit and focus on opportunities for aerospace through Horizon Europe, as well as funding that will be provided by the European Partnership for Clean Aviation. The event will take place on 20 May 2021 and is open to UK as well as European delegates. Registration is now open, and we will be in touch with members to ensure they can secure a place.







Last week’s Managing Brexit webinar focused on new rules around the mobility and movement of workforce between the UK and the EU. We were joined by a key experts to discuss the rules for workers. Highlights from the webinar are below and we encourage members who may have missed this event to watch the recording on the ADS Members site.


Elaine McIlroy, Immigration Partner at ADS member Brodies LLP, set out the new rules for workers moving between the EU and UK.  The UK has been added to the Schengen Border Code list of countries exempt from visa requirements for short stays (90 days in any 180 days) but visits for any purposes count towards the limit. This calculator will allow you to check whether a visa is needed. There are penalties for overstaying these limits applicable to both the business and the individual.  Elaine also provided information on the EU Settlement Scheme and Frontier Worker Permits as two ways for EU citizens to protect their rights to remain in the UK from 1 July 2021, although employers may have to provide supporting paperwork.


Dr Numa Isnard, a French expert with experience in the space sector, gave an overview of new requirements relating to GB citizens working in France. If staying longer than 90 days, there are several long stay visas available for British citizens. From 1 January 2021, British citizens seconded to France will need to register with the French social security system and that businesses engaged in a public tender contract in France will need to check contractual conditions for HR and dedicated provisions of services.


Francesca Tironi (Partner, PWC Italy), talked through issues related to transnational employment law. During EU withdrawal negotiations, the UK wanted to remain part of EU conventions on jurisdiction in civil and commercial matters, but this was refused by the EU. As such, UK businesses will need to seek legal advice on local employment laws in EU counties before signing contracts to establish which country will have jurisdiction.


Finally, Paolo Lucarini (Partner, PWC Italy) set out the impact on mobility for UK citizens working in Italy, stating that whilst there has been minimal impact on social security and tax obligations, there has been the introduction of additional immigration procedures. British citizens living in Italy on 31 December 2020 can apply for a Stay Permit, whilst those moving over for work after this date have a few different visa options.


For more information on any of these topics, please access the webinar on demand or visit the ADS Brexit Hub.




ADS was able to bring you last week's webinar, and the expertise of our European contributors, thanks to the support of colleagues in DIT. You can find out more about the team in France and in Italy below:


The UK’s Department for International Trade (DIT) helps UK businesses export, drives inward investment, negotiates market access and trade deals, and champion’s free trade.


DIT is the Government department charged with:

  • Supporting and encouraging UK businesses to drive sustainable international growth
  • Ensuring the UK remains a leading destination for international investment and maintains its number one position for international investment stock in Europe
  • Opening markets, building a trade framework with new and existing partners which is free and fair
  • Using trade and investment to underpin the government’s agenda for a Global Britain and its ambitions for prosperity, stability and security worldwide.


To follow up on specific opportunities in France and Italy, please contact:


Sebastiao Golding –
DIT France Advanced Manufacturing, Aerospace and Space Specialist

British Embassy Paris - Department for International Trade

35, rue du Faubourg Saint-Honoré, 75008 Paris, France


T: +33 6 07 50 50 66


Claudio Rosa –

DIT Italy Security & Defence Specialist

British Consulate General - Department for International Trade

Via San Paolo 7, 20121 Milan, Italy


T:+39 335 138 6873






As businesses navigate the new relationship between the UK and EU, there may be issues and new experiences facing members, ADS are keen to hear from members via the dedicated  email address on all your experiences including:

  • Ease or challenges related to moving goods from GB to EU from 1 January 2021
  • Experiences with Customs Agents
  • Experiences with new customs systems
  • Ease or challenges related to moving goods in and out of NI from 1 January 2021 
  • Concerns with regards to regulation or certification of your goods and products





Update on the UK Border


Last week the UK Government announced that Brexit Traffic management measures in Kent stood down as trade returns to normal. Hauliers no longer need a Kent Access Permit to travel between the UK and the EU, as of last week and the moveable barrier on the M20 was removed over the weekend.  Reports that these measures were being removed due to high compliance and few issues.





The UK Civil Aviation Authority (CAA) and aviation update


The CAA last week confirmed that it has provided regulatory approval to the US-based airline, JetBlue, to operate transatlantic routes between London, New York and Boston. This approval marks the first scheduled foreign carrier permit that has been issued to a new operator since the UK's exit from the European Union.


The aviation safety Technical Implementing Procedure is currently with the European Commission and EASA for review. ADS looks forward to seeing the TIP when it is published, following positive feedback from the CAA on the content. It is expected that conclusion of the review and sign off will take place by the end of May. ADS will keep members informed as this develops.






Last week ADS NI and Invest NI hosted a webinar with HMRC focused-on Navigating Tariffs for goods moving from Great Britain to Northern Ireland. Below are links to the Trader Support Scheme event, the Trade Tariff look up page and the NI Customs & Trade Academy mentioned by HMRC during the event:


A second event is scheduled for this week, 28 April 10:00-11:00 and will aim to provide advice on apportionment for goods ‘at risk’. Invest NI will host and there is more information as well as a sign-up link on the Invest NI site linked here.


Government have recently updated their webpage guidance on Northern Ireland with links below:






HMRC are providing a range of support to customs and international trade customers. ADS has collated a series of slide packs provided by government as part of our useful resources page on the ADS Brexit hub and the also has a page dedicated to webinars and videos for organisations that trade with the EU.


Customs & International Trade Helpline – 0300 322 9434

The helpline is the main route in for customers with general customs queries. Capacity has been scaled-up following the end of the transition period.






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