Brexit Bulletin - 13 December 2021



In this final Brexit Bulletin of 2021, we set out several key deadlines coming up for members and launch our new ‘UK-EU Status Report’ infographic. Check out our In Focus section for more detail on what to watch out for in crucial areas and information on our next Managing Brexit webinar, which will look at the UK-EU Trade and Cooperation Agreement one year on.


At the time of writing, discussions on Northern Ireland are still rumbling on. While Brexit Minister David Frost says suspension of the NI Protocol is still an option, officials on both sides say they will keep talking about how to manage trade flows between the U.K. mainland, Northern Ireland, and the Republic of Ireland.


We’ll be back in touch in the new year but in the meantime, you can keep up to date on the latest issues through our Brexit Hub.





Nearly one year on from the agreement of the UK-EU Trade and Cooperation Agreement (TCA), ADS has launched a ‘UK-EU Status Report’ infographic, setting out the key areas members need to watch out for as we move into 2022.





Upcoming Webinar: Managing Brexit: The UK-EU TCA One Year On

We are also pleased to announce that we will be hosting another webinar in our Managing Brexit series on Tuesday 18 January, focused on the TCA: One Year On. ADS policy experts will be joined by Christopher Burns from the Department for Business, Energy and Industrial Strategy to talk through the TCA’s implementation, how it has impacted members and what the next steps are as we move into a new year. There will also be specific updates focusing on aerospace, as well as customs, trade, and the UK border. You can find out more information and register for the event here.









Aviation Safety


The TCA included a two-year exemption period whereby EASA-issued licenses and organisational approvals would be valid in the UK. Pending any further negotiations, these extensions will expire on 31 December 2022. The Government has been clear that there will be no further annexes to the TCA negotiated in the near future; this means that many non-UK licenses and organisational approvals that are currently recognised in the UK will no longer be valid in the UK after 31 December 2022. It is therefore important that any holders of EASA approvals and personnel licenses begin the process of obtaining their UK equivalent by applying to the CAA as soon as possible.


This exemption however does not apply to EASA Form 1s. The recognition in the UK of an EASA Form 1 will end on 31 March 2022. For EASA Form 1s to be recognised in the UK after that date, the organisation issuing the EASA Form 1 must have applied to the CAA for an equivalent UK approval via the CAA before 31 March 2022.


Please get in touch with if you have any further questions on recognition of EASA licenses in the UK.





UK Trade Policy Update


Comprehensive and Progressive Agreement for Trans-Pacific Partnership CPTPP

The House of Lords International Agreements Committee published a report scrutinising the Government’s published Negotiating Objectives for accession to the CPTPP. It stated that there are potential economic benefits to the UK joining the CPTPP, though much depends on how successfully the agreement can serve as a platform for UK influence in the region. The committee also noted potential intellectual property challenges. The International Trade Committee has since launched an inquiry on the UK-CPTPP accession negotiations, which members can respond to here.


Singapore Digital Trade Deal

Last week, the UK secured agreement in principle with Singapore for a Digital Economy Agreement (DEA). This will be the first digital trade agreement signed by a European nation and will overhaul trade rules that affect both goods and services exporters, making it easier for UK businesses to target new opportunities in Singapore and other Asian markets. 


UK Export Finance Forum

This week, UK Export Finance held a forum in London. ADS attended and has blogged about some of the key messages of the event including changes to the risk appetite of UK finance and lenders and expansion of the Export Development Guarantee (EDG). UK Export Finance is the UK’s export credit agency and a government department, working to support the Department of International Trade and UK businesses.







Customs and Border Update


1 January 2022 UK Integrated Tariff codes

The full UK integrated tariff schedule incorporating changes from World Customs Organisation (WCO) is still being finalised. In the meantime, the 2021 to 2022 UK correlation table is available to see the 8-digit changes.


The Border Operating Model

Last month, the Government published an updated version of the Border Operating model for UK trade with the EU. This latest version provides an updated timetable for introducing import border control processes, as announced in September. Other relevant updates include border infrastructure at ports, with maps and funding announcements.


UK Single Trade Window

At the start of December, the Government launched a policy discussion paper on the UK Single Trade Window. This comes as part of the 2025 Border Strategy in which a UK Single Window is a key commitment, with an allocated budget of £180m. It would allow for a single point of entry for border data, which should ease burdens on businesses. Questions within the document will form the basis for further engagement with border industry and users of the border. Members are encouraged to respond or reach out to to participate in discussions.


Goods Vehicle Movement Service (GVMS)

The Government has agreed to allow early arrival for unaccompanied goods at temporary storage locations from 1 January, through both inventory systems and GVMS integration. In the second half of 2022, this will be legislated to rationalise the change for both accompanied and unaccompanied goods. Two options have been identified, with both requiring ports and carriers to work with IT systems to operationalise:

  • Early arrival through inventory
  • Extending GVMS to facilitate unaccompanied movements at temporary storage locations

For more details on how these options will work in practice and the requirements to use them, we have provided a link to some HMRC policy guidance and the relevant pages.


Relaxing the temporary storage requirement for authorised consignees

Following discussions over the summer, HMRC have decided to relax the temporary storage requirements for Authorised Consignee status in the new year. The means businesses will no longer be required to have an external temporary storage facility (ETSF) as part of an authorisation if they store goods for less than six calendar days from the end of the transit movement. There will be a move towards formal legislation in the new year too and in the meantime, a change in policy guidance document has been made available to support businesses.





Horizon Europe


The Government has stated that it will provide a financial safety net for successful Horizon Europe applicants to provide certainty as association delays continue. This means that successful applicants who have been unable to sign grant agreements with the EU will be guaranteed funding regardless of the outcome of the UK’s efforts to associate to Horizon Europe.


The funding will be delivered through UK Research and Innovation, which will publish further details about eligibility, scope and how to apply in the coming weeks. You can read the open letter from Science, Research and Innovation Minister George Freeman to the research and development sector.





UK Reach


The Government has announced that is going to consult on extending UK REACH deadlines. The system has been in place since the UK left the European Union, and chemical businesses operating within Great Britain should have already provided initial information under the UK REACH transitional provisions.


The Government will now consult on extending the deadlines for providing the full registration data. Alongside this, it will engage with industry and other stakeholders to explore whether there are opportunities to reduce the need for industry to replicate existing EU REACH data by placing a greater emphasis on understanding how chemicals are used in GB. The consultation will take place in 2022 and more details will follow discussions with stakeholders.





HMRC is 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 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.

  • For GVMS – (details to be published online soon)






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