Brexit Bulletin - 13 April 2021



We recently welcomed the good news that the postponement of import declarations is to be extended for six months. Full implementation of import declarations will be in place from January 2022, which will hopefully avoid border disruption in July.  There has not been too much substantial change or progress on Brexit trading issues in recent weeks. However, the major changes that were implemented at the start of the year are still causing challenges for industry, Government and EU counterparts. 


ADS remains engaged with Parliamentarians and officials on various trade issues, such as ‘at-risk’ goods and other new costs facing businesses in Northern Ireland. We will keep members updated on any mitigations or easements introduced or removed, as well as any new procedures agreed or implemented.







The next webinar in our Managing Brexit series is on 22 April at 14:00-15:00. We will be joined by experts from legal teams in the UK, France and Italy who will talk about the new rules and requirements related to the movement of workers between the EU and the UK.


Joining us from Brodies, a UK based legal firm, is Elaine McIlroy, who will provide an overview on the new rules for businesses who want to hire EU nationals to undertake work in the UK.


We will also hear from Francesca Tironi, a labour law expert from PWC, who will give specific insights to transnational employment in relation to the European legal framework.


Dr Numa Isnard, an expert in France, with experience in the Space sector, will offer perspectives on the new legal framework for UK nationals to work in France.


Paolo Lucarini, a leading expert on Brexit for PWC Italy, will then provide insight with respect to immigration and movement of workers into Italy.


The event will close with a Q&A and you can find out more information or sign up to attend here.






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


The UK  border

Inbound and outbound traffic flows have broadly returned to 2020 levels with very few issues reported.


Suez Canal disruption

As it stands, we have not heard of any major disruptions to our sectors’ supply chains as a result of the recent disruption in the Suez Canal. However, UK ports are anticipating that there will be a displacement, shortage of containers and high demand for UK port capacity over the coming weeks as trade recovers. Please see a letter from the UK Major Ports Group and British Ports Association to trade associations colleagues outlining the expected issues.


Transit and National Computerised Transit System (NCTS)

HMRC has now started to inform businesses of a change to the temporary measure of guarantee estimates input to the National Computerised Transit System (NCTS);which is used when goods are using the Transit procedure. When making a declaration into NCTS for Transit movements, it is a requirement to provide an accurate guarantee reference amount in NCTS declarations, in line with the Common Transit Convention (CTC).


The UK NCTS system will be upgraded on 4 May so that if traders do not enter a value, the NCTS system will enter a “default” amount in their declaration. This was temporarily adjusted to £1 to enable traders to continue to move goods through transit for an interim period. However, the guarantee amount is set by the Common Transit Convention, and so will revert to the sterling equivalent of 10,000 euros for each transit movement from 4 May 2021.


Traders must now ensure that they are able to enter accurate Guarantee Reference Amounts in all of their transit declarations. If they do not enter a value, NCTS will automatically add a value of 10,000 euros in sterling and will hold 10,000 euros of their guarantee against the movement, traders may need to increase their guarantees to accommodate for this. Guidance can be found on





Subsidy Control Consultation


Last month, ADS submitted a response to the Department of Business, Energy and Industrial Strategy’s consultation on the creation of a new subsidy control regime for the UK, which can be viewed in the ADS members area.


The consultation invited views on the best way to design a bespoke approach to subsidy control following Brexit. ADS welcomes the Government’s intention to create a domestic subsidy control regime that supports, not hinders, strategic interventions by the Government in support of national priorities.





House of Lords EU Goods Sub-Committee Report


The EU Goods Sub-Committee published its report on what the EU-UK Trade and Cooperation Agreement (TCA) means for trade in goods, following an inquiry that ADS submitted to. The report concludes, “While most trade is tariff-free, it is not simple.”


ADS has written a blog outlining the key findings and recommendations, which can be found on the website here.





The UK Civil Aviation Authority (CAA) and Aviation update


CAP 553 consultation

On 1 April The UK CAA launched a consultation on proposed changes to CAP 553 (BCAR Section A) with some minor amendments reflecting the UK’s withdrawal from the EU and EASA but the majority reflecting changes across chapters where there are additional privileges. For further details on what the proposed changes are and how to respond, members should visit the CAA website.


EASA-to-UK pilot licence conversion process

The UK CAA has launched a simplified process to allow pilots who transferred their licence and medical certificate to an EU member state in preparation for the end of the transition period to get their UK licence back. Pilots are able to hold both a UK and European licence and the new process is available to any pilot who held an EASA flight crew licence before the end of the transition period. More details can be found on the CAA website.




Over the coming weeks there are a couple of targeted webinars to help support companies in Northern Ireland:


The first takes place on 22 April 12:00 - 13:00 and is focused on Navigating Tariffs for goods moving from Great Britain to Northern Ireland. ADS is delighted to be hosting this webinar in partnership with Invest NI and the Department for the Economy. Members can find out more information and sign up here.up here.


The second event is scheduled for 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.







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..  


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.


Technical support

For support with specific systems there are specific email addresses which are monitored Monday- Friday 9am-5pm.






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