Publication
Trade in Goods: Brexit Readiness Action Plan
From Department of the Taoiseach
Published on
Last updated on
From 1 January, 2021, regardless of the outcome of the ongoing negotiations, the UK will no longer be part of the EU’s Single Market and Customs Union. This means any business that moves goods from, to or through the UK will be subject to a range of new customs formalities, SPS checks and other regulatory requirements, that do not apply in any form today to such trade.
The main elements of these changes are set out below but it is vital that businesses, no matter how small, take steps to understand the impacts any new rules or processes will have on your operations. Failure to engage with and implement these new requirements will prevent you from trading with the UK or could lead to significant delays in moving goods from, to or across the UK from 1 January next.
It is also important to note that these changes will not apply with respect to trade in goods between Ireland and Northern Ireland where the Protocol on Ireland and Northern Ireland will apply from the end of the transition period, regardless of the outcome of the ongoing EU-UK negotiations. Under the Protocol, the Union Customs Code will continue to apply to and in Northern Ireland. Unless otherwise stated, references to imports from or exports to the UK in this section should be read as excluding trade with Northern Ireland.
The UK government has published plans for a new range of checks and controls. Information sources on these requirements can be found below.
From 1 January 2021, all goods imported into Ireland from Great Britain or exported from Ireland to Great Britain will be subject to customs processes. The critical first step in terms of Brexit readiness is to register for an EORI (Economic Operators Registration Identification) number. Revenue has written to over 100,000 companies since 2019 including over 57,000 in July 2020 who traded with the UK but had not yet registered for an EORI number.
Over 67,000 businesses now have an EORI number (these businesses account for 96.4% of the value of exports to the UK in 2019 and 93.3% of the value of imports). Once a business has an EORI number it will need to decide if it plans to do the customs work itself or to engage a customs agent. If doing the customs work in-house, the business will need the necessary software and be able to connect to Revenue’s customs systems.
More detail on electronic customs systems and information on the technical requirements for customs is available on the Revenue website.
A business planning on undertaking this work in-house may be eligible for government support. Further information on business supports can be found here.
From the end of the transition period, and without prejudice to any arrangements that may be put in place in an EU-UK future partnership agreement, UK (including Northern Ireland) products or materials will no longer be considered as EU originating for the purposes of international trade.
Before 1 January, 2021, it is important that a business understands where its goods originate, the value of the goods, the customs classification code and invoicing currency. In considering the origin of goods, it is necessary to review both the material inputs and processing operations.
The country of origin of goods is a factor in determining the amount of duty payable and must be proven for goods to benefit from preferential treatment. Goods imported from the UK that do not meet origin requirements will be liable for customs duties even if the EU and UK agree a zero tariff, zero quota EU-UK trade agreement.
The change in status of UK origin will also impact Irish businesses who use UK inputs when availing of the benefits of EU FTAs with other FTA partner countries. Irish exporters should review and, if necessary, adjust their supply chains so that products meet the thresholds required to avail of preferential rates under EU Free Trade Agreements with non-EU countries.
This may include countries that have concluded an FTA with the UK, depending on the terms of that agreement. Furthermore, to maintain preferential originating status, goods will also have to meet any direct transport/non-alteration provisions (i.e. the goods must travel directly between the countries party to the FTA or be under customs control if they transit through a third country). Further details are available on Revenue's website.
Consideration is required on the impact that import duties may have on your cash flow. You can register with ROS (Revenue's Online Service) ROS (Revenue Online Service) in order to lodge funds into your customs account and also to apply for deferred payments until the month following import. See Revenue's website.
VAT will be chargeable on goods imported into Ireland from the UK while exporters must be able to prove that the goods left the Union in order to apply the zero rate of VAT applicable to exports. If a business uses any EU VAT simplifications such as triangulation or self-billing, these will no longer be available where part of the transaction occurs in the UK. Similarly, the European VAT Refund (EVR) system will no longer be available to reclaim VAT expended or refund VAT charged in the UK.
In order to address the significant impact these VAT changes will have on businesses Part 8 of the 2020 Brexit Omnibus Bill provides for the introduction of postponed accounting for VAT for most VAT registered companies. Under the proposed system, importers will not pay import VAT at the point of entry but will instead account for it through their bi-monthly VAT return.
Revenue will be granted powers to remove this facility from traders that pose a risk to Revenue. The VAT treatment of supplies of goods to Northern Ireland after the end of the transition period will not change.
Once the UK becomes a third country at the end of the transition period, excise duty will be incurred when excisable goods such as alcoholic beverages or tobacco are imported into the EU from the UK. As a third country, a Duty Free and VAT Retail Export Scheme may also operate between Ireland and the UK (excluding Northern Ireland). The 2020 Brexit Omnibus Bill includes a number of measures relating to duty free sales and the application of any VAT Retail Export Scheme to UK Residents. Further information on the 2020 Brexit Omnibus Bill can be found here.
Brexit may also impact the logistics model used by a business. Businesses, including haulage and logistic companies, should be familiar with all documentation that will be required for moving goods between Ireland and Great Britain from the end of the transition period, and should engage immediately with their logistics provider to that end. Hauliers will not be able to board ferries to and from Great Britain from 1 January 2021 unless all documentation has been completed in advance and properly presented.
From 1 January 2021, UK notified bodies will no longer be authorised to certify the compliance of products with EU rules and standards in respect of specific regulatory controls, public safety and health. For businesses that currently rely on UK Notified Bodies for conformity assessment certificates, it is vital to source an alternative approved Notified Body established in the EU. This may involve transferring existing certificates to a Notified Body in another EU Member State or obtaining new ones altogether. The Government acknowledges that many businesses have already taken the necessary steps to address this issue. Companies that source products, requiring EU certification, from the UK should engage with their EU-based Notified Bodies.
The European Commission's NANDO also provides a list of designated EU Notified Bodies as well as a list of Irish-based Notified Bodies.
Importers of products/ingredients that require organic certification should ensure that the certifying body of the UK product has been recognised by the EU Commission.
Companies exporting to the UK should check the UK government website and the information in the UK Product Safety and Metrology Guidance in a ‘no deal’ Brexit”.
Other impacts in this area that businesses may wish to consider include:
- requirements to register products on EU databases
- requirements to be established in the EU (which will no longer include the UK) and requirements relating to the marking and labelling of goods
In relation to industrial products (including construction products), manufacturers, distributors, importers and authorised representatives must comply with their obligations and responsibilities under EU product legislation when placing a product on the EU market.
For example, an economic operator established in the EU who, prior to the end of the transition period, was considered as an EU distributor of products received from the UK will become an importer for the purposes of EU product legislation in relation to such products as of the end of the transition period. This operator will have to comply with the more stringent obligations applicable to an importer.
A number of state agencies undertake an important market surveillance role to ensure products are designed, manufactured and monitored in accordance with EU law and can provide advice in relevant sectors.
This includes agencies such as:
- the Health and Safety Authority (HSA)
- the Competition and Consumer Protection Commission (CCPC)
- the National Standards Authority of Ireland (NSAI)
- the Environmental Protection Agency (EPA)
- the Sustainable Energy Authority of Ireland (SEAI)
- the Building Control Authorities and National Building Control Office (NBCO).
Further information on market surveillance is available in the Government's Market Surveillance Plan for Ireland (2019).
Revenue has developed the Customs Roll-On Roll-Off Service, accessible via the Revenue website provides three functions that facilitate the flow of commercial vehicles into and out of Irish ports and supports the just-in-time business model preferred by many businesses.
The functions are:
- Pre-Boarding Notification: in order to move goods quickly through Irish ports customs declarations should be made in advance of arrival at the port of departure in the UK. The details of customs declarations for all goods to be carried on a vehicle/truck need to be recorded in the Pre-Boarding Notification (PBN). The PBN is a virtual envelope that links together the details of all of the goods being carried on a vehicle/truck. This enables customs to provide one single instruction to be followed by the driver on arrival at an Irish port, regardless of the number of consignments on board the vehicle, ensuring speedy and accurate channelling of a vehicle/truck through the port.
- Channel Look-Up: provides information on whether a vehicle can directly exit the port or if the goods need to be brought to customs for checking. This information will be made available via the Customs RoRo Service 30 minutes prior to arrival of the ferry into Ireland and can be accessed by anyone in the supply chain. This will facilitate the efficient flow of traffic through our ports. It will also assist business from a planning perspective knowing which vehicles and consignments are on their way out of the port.
- Parking Self Check-In: drivers whose vehicles have been called for a physical inspection will be able to remain in their vehicle and inform Revenue that the goods are available for inspection using this function. When an examination bay becomes available the driver will receive a text message advising him/her where to attend for inspection. This will minimise the need for face to face interaction between the driver and Revenue staff and speed up procedures overall.
Businesses will need to consider who will complete the Pre-Boarding Notification, this may or may not be the same person that lodges the customs declarations. A business will need to consult with its logistics provider to determine what will work best, having regard to the business model.
If you want to import or export animals, plants, or products of animal (including fish) or plant origin from or to the UK (excluding NI) from 1 January 2021 you must be registered with the Department of Agriculture, Food and the Marine. Furthermore, importers will also need to be registered on TRACES (an EU Commission system for the electronic completion of documentation required for imports of certain consignments from third countries).
Further information on the registration processes, and more generally in relation to importing and exporting animals, plants, and products of animal and plant origin (including fish) from or to the United Kingdom (excluding NI) from 1 January 2021 can be found on the Department of Agriculture , Food and the Marine website. You should contact brexitregistration@agriculture.gov.ie in relation to queries regarding registration with DAFM and TRACES.
The trade of certain seafood products is also subject to additional requirements – more information on this can be found on the Sea-Fisheries Protection Authority’s website.
You may also need to register with/notify the the Environmental Health Service (EHS) of the HSE in relation to the import and export of food products of non-animal origin.
If an export certificate is required for foods of non-animal origin or a food business wishes to notify the HSE, this facility is available through the EHS online services.
On 13 July 2020, the UK Government published its Border Operating Model, outlining plans for the introduction of border controls on exports to Great Britain from the EU. These plans indicate that controls will be implemented in three phases, from 1 January 2021 and with full controls implemented by July 2021. In addition to outlining the various elements that come on line in each phase, the paper also provides details of the models that will be used at border locations, various IT platforms for the RoRo Freight sector such as the new Goods Vehicle Movement Services and the Smart Freight System, as well as details for moving excisable goods and VAT.
It is important that businesses trading with Great Britain, or using the landbridge across Great Britain, make themselves aware of their responsibilities in relation to UK customs and regulatory checks and controls. In particular, it will be necessary to be aware of the introduction of controls on a phased basis in January, April and July.
Because of the Protocol on Ireland and Northern Ireland separate arrangements apply on the island of Ireland and no new checks or controls will apply to goods moving between Ireland and Northern Ireland in either direction.
Government will:
- work with our EU partners, to continue to ensure EU readiness and contingency planning addresses the needs of businesses and citizens
- remain actively engaged in promoting Irelands’ interests in relation to the Brexit Adjustment Reserve
Businesses and stakeholders should now:
- review any relevant European Commission readiness notices, and take the necessary action ahead of the end of the transition period. Where stakeholders need further guidance, they can also consult www.gov.ie/Brexit
Businesses should now:
- give urgent priority to examining your supply chains and knowing the origin, customs valuation and commodity codes of the goods you trade.
- If you are a manufacturer using originating and non-originating materials in your processes, make use of accounting segregation where permitted.
Businesses should now:
- understand the obligations if trading in animals, plants, animal products or plant products subject to SPS controls
- Understand the obligations if trading in fish and fishery products subject to Illegal, unreported and unregulated (IUU) fisheries controls.
Businesses should now:
- source an EU-based Notified Body legally designated to carry out conformity assessments. A list of Notified Bodies is available on the European Commission's NANDO website
- engage with the NSAI for support and guidance on standards and certification
- carry out a risk assessment of your product supply chain to highlight any materials that may be impacted and identify potential alternative certified sources within another Member State.
- engage with your UK suppliers to satisfy themselves that product supply continuity is resilient and will be maintained
- review licensing and compliance requirements and engage with the relevant authorities and notification bodies
- importers and suppliers should carry out a risk assessment of their product supply chain to highlight any materials that may no longer be authorised for sale on the Single Market after the end of transition and identify alternatives as necessary
- importers, exporters, distributors, manufacturers and authorised representatives for the sale of specific products, including construction products, in the EU should ensure that they hold certificates from an EU Notified Body
- entities seeking Notified Body status in Ireland for the purposes of the Construction Products Regulation should apply in the first instance to the Irish National Accreditation Board.
Businesses should now:
- consider the cashflow implications of having to pay import duties (customs duty, VAT and excise).
Engage with your logistics provider to understand the essential information the person who moves your goods will need and when they will need it.
The European Commission’s Readiness Notices in relation to Customs and VAT for goods are available on the Commission website.
The European Commission has also published a wide range of Readiness Notices in relation to animals, plants and SPS, to help stakeholders to prepare for the changes Brexit will bring, including Notices on the breeding of animals, the transport of live animals and animal health and welfare. These notices are complemented by further guidance from the Department of Agriculture, Food and the Marine.
The European Commission Readiness Communication provides guidance on the certification requirements that apply to the sale of products on the EU Single Market. There is also a specific Readiness Notice that provides general readiness guidance in respect of Industrial Products.
The UK landbridge refers to the route that connects Ireland to the EU Single Market and wider international markets via the UK’s road and ports network. Maintaining the landbridge as an effective route to market has been a key priority of the Government’s Brexit planning. The Irish Marine Development Office estimate that there are approximately 150,000 landbridge movements annually with an estimated value of this trade of €18.2 billion.
A significant proportion of goods using the landbridge are agri-food goods, such as fresh fish, with a short shelf life, making the UK landbridge the most viable route to market.
Post-transition, operators will still be able to move goods via the landbridge but the way they use the landbridge will change. The UK’s accession to the Common Transit Convention (CTC) is welcome. This allows EU goods to move under transit through the UK without undergoing full customs import and export formalities on entry and exit.
However, to avail of the benefits of the CTC, there will be certain new requirements including new paperwork as well as the need for each consignment to have a financial guarantee in place to cover the potential customs duties and other taxes at risk during the movement. In addition, operators should be aware that customs and border controls on wider goods traffic using the same port infrastructure along the landbridge brings the risk of significant delays and increased transit times.
Operators using the UK landbridge will need to be aware of and implement the provisions set out in the UK’s Border Operating Model. While some controls under the model will be introduced on a phased basis, traders moving goods using the Common Transit Convention will need to follow all of the transit procedures from 1 January 2021 as these will not be introduced in stages. The UK’s goods vehicle movement service (GVMS) will be introduced from January for transit movements.
Ireland has undertaken substantial engagements at political and official level across the EU to ensure that EU goods moving under transit via the landbridge are not subject to additional and unnecessary checks and controls. In particular, we have worked closely with our French, German, Dutch and Belgian counterparts to understand each other’s operations and plans post transition. The overarching aim has been to ensure that, once the correct paperwork is in place, the necessary controls are completed, and transit goods will be “green lighted” and permitted to leave ports.
To facilitate this, transit declarations will need to be submitted electronically by traders in advance and the required financial guarantees will also have to be in place. Any checks that are carried out today (such as on live animals) will continue. Ireland supports appropriate checks to ensure the integrity of the Single Market and public health. We will also continue to work with the European Commission and Member States to address SPS challenges that arise in light of the introduction of the new Official Controls Regulation (OCR).
The solution currently proposed by the Commission helps to address the concerns arising for Ireland and other Member States. From an Irish perspective, the positive and solution-oriented approach taken by the Commission is very welcome.
As new systems and processes are brought on line in ports across the EU and UK, the risk of queues and delays, some of which may be very substantial in busy ports is high. The DoverCalais crossing has been identified as a particular bottleneck. It is also possible that Holyhead will experience similar congestion in the initial period after transition ends. In order to benefit from the work done to mitigate delays in EU ports, it will be important to have the appropriate administration work, including the requirement to have a financial guarantee in place. More traders and hauliers with correct paperwork will reduce delays in ports. Traders should also familiarise themselves with any changes underway in ports of transit in the UK and at destinations including Dublin Port and Rosslare Europort.
Traders may also wish to look at direct route options. The process for moving goods directly between Ireland and other EU Member States will not change nor be subject to the new procedures highlighted in this section.
Government will:
- enhance its outreach programme to ensure that businesses, haulage companies and ferry operators are aware of the requirements that will apply to moving goods under transit across the landbridge after the end of the transition period
- continue to work with the European Commission and other EU Member States to ensure that the movement of Union goods under the transit procedure avoids unnecessary checks
- monitor available capacity on shipping routes to and from Ireland after the end of the transition period to ensure that the needs of the economy are met
- continue to engage with our UK counterparts to have clarity on UK processes for consignments transiting the landbridge.
Businesses should now do the following to use the UK landbridge efficiently after the transition period:
- Visit Revenue for for further details on the Customs Transit Procedure, the NCTS and to apply to use transit simplifications, including how to become an authorised consignor/consignee.
- Work with your bank or a customs agent/logistics provider to ensure you have the necessary financial guarantee in place.
- register via the Department of Agriculture, Food and the Marine (DAFM) on the EU’s TRACES system if you are moving animals, animal products, hay or straw. More information is available online from DAFM. More information for traders moving animals or products of animal origin is available on the on the DAFM website.
- if not availing of the simplified customs transit procedure, familiarise yourself with the location of the appropriate offices of departure/destination for opening or closing the intra-community transit movement - many offices may not be open 24/7.
- be aware of any routing and procedural changes within ports
- familiarise yourself with new UK customs and transit requirements
- compare the expected transit times and compliance costs associated with using the landbridge after the end of the transition period against alternative direct shipping routes to EU ports
- consider moving, in advance of the end of the transition period, to direct route options for the movement of goods from Ireland to the Continent to avoid potential delays and the new procedures associated with using the UK landbridge
Operators may also find the following external resources useful:
- The European Commission lists all transit offices online
- French authorities have useful Brexit-specific customs and transit resources
- Dutch authorities have useful Brexit-specific customs and transit resources
- Belgian authorities have useful Brexit-specific customs and transit resources
The following ports all have have Brexit resources available online:
The agri-food and fisheries sector is one of the most exposed to the impacts of Brexit. This is due to a number of factors, but primarily its exposure to the UK market and the requirement for sanitary and phytosanitary (SPS) controls to be conducted on movements of animals, plants and products of animal and plant origin between the UK and Ireland from January 2021.
The sector is a primary driver of rural and coastal economies, and data shows that rural areas, including the border region, are more exposed to a slowdown in the agri-food sector. Ireland exported €5.47 billion of agri-food produce to the UK in 2019, which represents 38% of the total Irish agri-food exports in 2019. Our agri-food sectors are highly exposed, particularly the beef sector; 43% of our beef exports in 2019 went to the UK.
These are also the sectors that are exposed to the highest potential trade tariffs that could arise in the post-Brexit trading environment if negotiations prove unsuccessful. In such a scenario, in addition to the application by Ireland of the EU’s Common External Tariff Regime to UK imports which were worth €4.6 billion in 2019, the UK’s Global Tariff Schedule (published in May 2020) would apply to Irish exports to Great Britain. Based on an analysis of 2019 agri-food export data, this would see a total estimated tariff cost of between €1.35 and €1.5 billion.
Although all sectors will be impacted, the magnitude of that impact of the UK Global Tariff Schedule will result in beef, dairy, pigmeat, poultry and cereals incurring the highest cost in absolute terms. The reliance of each sector on the UK export market varies with beef the most exposed. Accordingly, the Government strongly supports the European Union’s objective to agree a tariff-free and quota-free trading arrangement.
A range of financial and budgetary measures for the agri-food and fisheries sector over the last four years were aimed at enhancing competitiveness and market and product diversification. These included low cost loan schemes, supports for Bord Bia and Teagasc, direct aid for farmers, capital funding for the food industry, and an intensified series of Ministerial-led trade missions to develop and grow new markets in light of Brexit. Further targeted measures to support businesses and the most-affected sectors will be considered in the context of Budget 2021.
Bord Bia provides a range of tailored supports and analysis for the food and drinks sector, including a Customs Readiness programme, supply chain workshops and a bespoke Mentoring Programme. Bord Bia's Brexit Action Plan provides useful advice and assistance, while further guidance on business supports more generally can be found here.
Regardless of the outcome of the trade negotiations, change will arise for the Irish agri-food industry from 1 January 2021.
The UK’s status as a third country brings new customs and regulatory requirements for importers and exporters of agri-food products. As required by EU legislation, new SPS requirements in the form of documentary, identity and physical checks on imports of animals, plants and products of animal (including fish) and plant origin will be applied to trade with Great Britain.
While SPS checks are important to ensure food safety and protect consumers, they will also increase the cost of trade and result in delays in the movement of goods, although every effort will be made to ensure the minimum possible disruption to trade flows.
Export certification and other requirements in respect of movement of goods to Great Britain will also arise, and the Irish Government will closely monitor the evolving UK position in this area and ensure necessary contingency measures are in place.
Irish fishing vessels that land directly into ports in Great Britain will be subject to additional IUU requirements from 1 January 2021. Vessels will only be able to land into ports designated by the UK for third country landings and will have to notify the UK competent authorities at least four hours in advance for fresh fish and at least 72 hours in advance for frozen fish.
Details of these ports will be made available on gov.uk.
In addition, and depending on the outcome of negotiations between the EU and UK on an agreement in the area of fisheries, the seafood sector in Ireland could be especially significantly impacted by Brexit.
Ireland strongly supports the EU’s position on fisheries as set down in the negotiating mandate which calls for the existing reciprocal access conditions, quota shares and the traditional activity of the Union fleet be upheld in respect of fisheries. In line with the Political Declaration, agreed between the EU and the UK, and with the EU mandate, an FTA will only be concluded with an agreement on fisheries.
The Government recognises the importance of agriculture and fisheries, in supporting balanced regional and coastal development and employment. We will continue to work closely with the EU and fellow Member States to identify options for the fishing industry, including a common framework to manage potential tying-up of boats in a situation where no agreement is reached with the UK.
In accordance with the Protocol on Ireland/Northern Ireland, Northern Ireland will remain aligned to a limited set of Union rules, notably related to goods, and the Union Customs Code.
Northern Ireland must fully comply with relevant EU rules and standards, for example on food products and live animals to ensure adherence to SPS and IUU requirements.
Government will:
- work to achieve the best possible outcome for the agri-food sector from the EU-UK negotiations, in the form of continued tariff-free and quota-free access to the UK market, with minimal additional customs and administrative procedures, and minimisation of the risk from UK trade agreements with third countries
- work closely with the EU Task Force and other Member States on fisheries to uphold existing reciprocal access conditions, quota shares and the traditional activity of the EU fleet, while ensuring that any fisheries issues are dealt with as part of an overall trade deal
- consider further supports and programmes needed to support the agri-food and fishing sector in light of Brexit, including as part of the preparation of Budget 2021
- have resources in place to address additional regulatory and certification requirements for Irish-UK trade
- engage extensively with the sectors and stakeholders over the coming months, as part of the overall Brexit Communications campaign, to ensure industry is aware of the changes and preparations they need to make to be ready for 1 January 2021
- continue to engage constructively with the European Commission to explore the full range of State aid flexibilities and supports for sectors impacted by Brexit
- work with the Commission to ensure Irish businesses and affected sectors benefit from the €5 billion Brexit Adjustment Reserve, to the maximum extent possible.
- work closely with the EU and fellow Member States to identify options for the fishing industry including a common framework to manage potential tying-up of boats, the possible risk of displacement of EU vessels into the Irish EEZ, and short-term and longterm funding for the sector, including through the Brexit Adjustment Reserve, to the maximum extent possible.
- review your supply chains
- ensure you are prepared for the requirements for importing and exporting to GB, including in relation to customs, rules of origin, registering for an EORI number, and registering with the Department of Agriculture, Food and the Marine to move animals, plants or animal (including fish) and plant products (including fish) and food of nonanimal origin;
- ensure you are ready for all your regulation, licencing and certification requirements;
- for trade of seafood products, familiarise yourself with the information on Sea Fisheries Protection Authority
- review your contracts and data management
- manage your cash flow, currency and banking
- take advantage of Government Brexit programmes and supports
The European Commission has published a wide range of sector-specific Readiness Notices to help.
EU law has provided a shared framework allowing Ireland, France and the UK to agree a specific arrangement for the movement of registered high-health equine animals; the so-called Tripartite Agreement (TPA). This agreement will lapse at the end of the transition period thereby removing the free movement of high-health horses between Ireland, UK and France.
This will bring about significant change for the industry, as extra certification and controls will apply to movement of horses between Ireland and Great Britain.
A successor agreement to the TPA may be agreed in respect of North/South movement of horses if Northern Ireland continues to provide the necessary guarantees on maintaining high-health status, and if the UK can continue to guarantee all other controls are carried out – including on horses coming from Great Britain into Northern Ireland.
In order for movement of equine animals between the UK and the EU to continue after the transition period, the UK will need to be listed by the Commission as a third country eligible to export horses to the EU.
After the transition period ends, equine animals entering Ireland from Great Britain may only enter Ireland via an EU Border Control Post (BCP) approved for that species. The BCPs approved for both registered and non-registered horses are Dublin and Shannon airports, Dublin Port and Rosslare Port.
Specific controls for movements from Great Britain to Ireland, including blood testing and residency requirements will also apply, depending on the sanitary group (health status category) the Commission assigns to the UK and the purpose and duration of the equine movement. This categorisation will only be confirmed closer to the date on which the transition period ends.
Equine animals moving to, and through UK, will be subject to UK Government requirements. Customs controls will also apply to equine movements between Ireland and Great Britain.
Government will:
- continue to provide guidance to assist operators moving horses between Ireland and the UK ahead of the end of the transition period.
Businesses should now:
- prepare for the movement of horses between Ireland and Great Britain, or between Ireland and another EU Member State transiting via the UK landbridge, to take place in accordance with EU customs procedures.
- prepare to route horses moving from Great Britain to Ireland through one of the Border Control Posts designated for the entry of equines, at Dublin Port, Rosslare Europort, Dublin Airport or Shannon Airport
- prepare for horses moving from Great Britain to Ireland to undergo new documentary checks, identity checks and physical health checks.
- prepare for horses moving from Ireland to the UK to do so in line with UK government requirements
- breeders with horses registered only in UK breeding books should consider whether also to register these horses in the relevant breeding book or register in Ireland
Individuals should now:
- contact the Department of Agriculture, Food and the Marine to ensure that transporters for horses comply with the relevant authorisations and certificates.
The European Commission has published sector-specific Readiness Notices on:
Non-commercial pet movements refer to dogs, cats and ferrets travelling accompanied by their owner. When the transition period ends the rules on non-commercial pet movements between Ireland and Great Britain will change. The nature of these changes are not yet confirmed and may not be decided until close to the end of the transition period. Depending on the final shape of these changes, there is a risk of significant disruption to those bringing pets from Great Britain to Ireland, including potential delays or quarantines of up to four months.
Once requirements have been clarified, the Government will engage further with stakeholders to ensure they are aware of the changes.
The Protocol on Ireland and Northern Ireland ensures that pet movements between Ireland and Northern Ireland will continue on the same basis as they do today.
Information on the requirements for bringing a pet dog, cat or ferret from the UK to Ireland can be found on the on the DAFM website.
Anyone wishing to bring a pet dog, cat or ferret from Ireland to the UK should check the the UK government advice on pet movement between the UK and the EU.
Government will:
- continue to provide, and update, guidance to assist pet owners planning to move pets between Ireland and Great Britain
- continue to provide, and update guidance for veterinary practitioners assisting pet owners in their preparations for travel.
Individuals should now:
- prepare to route pets entering Ireland from Great Britain after the end of the transition period through a designated Travellers’ Point of Entry (TPOE) so that compliance checks can be made. Dublin Port, Rosslare Europort, Ringaskiddy Port, Dublin Airport, Cork Airport and Shannon Airport will all be listed as TPOEs by 1 January 2021.
- prepare for pets moving from Great Britain to Ireland to require, at a minimum, a pet passport, a rabies vaccination, micro-chipping and treatment for tapeworm for any travel after 1 January 2021. Pet owners should speak to a veterinarian at least four months before any pet travel from Great Britain to Ireland to ensure that the requirements for travel are met
- prepare for pets moving to Great Britain and returning to Ireland after the transition period by arranging with their veterinary practitioner for their pet to have the rabies vaccination blood sample and test before travelling to Great Britain, to avoid the 3 month wait period required if the blood sample is taken in GB
- review updated UK Government requirements ahead of any movement of pets to Great Britain from Ireland
The European Commission has published a Notice on travelling which contains detailed guidance on pet travel.
Similar to the situation with human medicines the sale and supply of veterinary medicines is carefully regulated to ensure animal safety and welfare.
Post-transition, the UK will no longer participate in the EU system for the regulation of veterinary medicines, therefore it is possible that a limited number of veterinary medicines currently manufactured, quality controlled or batch released in the UK may no longer be made available for sale in Ireland for commercial reasons.
The Government and the Health Products Regulatory Authority (HPRA) have continued to engage with industry manufacturers, marketing authorisation holders, wholesale distributors, farming and veterinary stakeholders over the past two years to ensure a stable supply of veterinary medicines post-Brexit.
Government will:
- conduct updated exercises in Q3/Q4 2020 to seek further assurance on veterinary medicines used in Ireland and identify potential vulnerabilities.
- review the impact COVID-19 has had, and will have on the ability to maintain buffer stocks of medicines.
- continue to engage through the recently established VMP Shortages Protocol to identify any potential veterinary medicinal shortages
- engage and collaborate with industry, the HPRA and the Veterinary Council of Ireland on mitigation measures such as alternative sources, alternative transport routes, and alternative medicines or treatment regimes.
- ensure that the regulatory authorisation or product certifications required for specific veterinary medicines are transferred to EU regulatory authorities or notified bodies
- prepare for new customs and regulatory procedures, including batch release testing of medicines produced in the UK, to apply to the import of veterinary medicines from the UK
- ensure that product labelling for products manufactured in the UK conforms with EU law
Individual animal owners, veterinary practices, and pharmacies should now:
- continue to fill prescriptions as normal so as not to disrupt existing stock levels and hamper the supply of veterinary medicines and medical devices. The European Commission has published a Readiness Notice on Medicinal products Readiness Notice on Medicinal Products (including Veterinary) to help stakeholders prepare for the changes from the end of the transition period
The introduction of new import and export processes along with enhanced checks and controls on trade between the EU and UK may lead to disruption in the supply chains of Irish-based retail businesses. Substantial Brexit preparations were undertaken by these firms in 2019. Further work on understanding and strengthening supply chains also took place in response to the COVID-19 crisis.
As substantial changes will take place for this sector regardless of the outcome of the EU-UK future partnership negotiations, it is important that these preparations are intensified to mitigate disruption to supply chains for essential goods due to lack of business readiness, and/or congestion at ports.
The Government will continue to work closely with the Retail Forum and with stakeholders in the grocery retail and distribution sector, to ensure that preparations are being undertaken by businesses to manage potential impacts on supply chains from the end of the transition period, so as to minimise risk of disruption.
While e-commerce flows may well continue after the end of the transition period, the operating environment for online retail will change, including for consumers buying from UK traders operating from/through websites in the UK.
Consumers should be aware that from 1 January 2021 purchases from or through websites in the UK will incur additional import charges, duty and VAT, just as for any other third country.
Administrative costs of export and re-import declarations in relation to returns for retailers will arise. Products of animals or plants subject to SPS checks will have to undergo such checks and fees may be payable. In certain instances, EU consumer protection legislation may no longer apply to or in respect of the UK, removing the legally enforceable guarantees currently available in EU law to both retailers and consumers. The CCPC website has extensive information for consumers and businesses.
It also sets out the changes to consumer rights for those purchasing from the UK including through shoppin g online. It also has information on extra taxes and charges consumers may need to pay when ordering online from a country outside the EU.
Government will:
- continue to engage with sectoral and representative groups on readiness issues and to communicate to them the supports that are available. It will also continue to provide updated information to consumers about how their rights may be affected at the end of the transition period.
- continue to bring together relevant Government Departments, State Agencies and industry representatives through the Retail Forum, who will engage on key readiness and contingency planning issues, including in relation to the grocery and retail distribution sector
- through Bord Bia, Enterprise Ireland, Údarás na Gaeltachta, and the Local Enterprise Offices continue to work with Irish businesses that supply into the UK retail market to ensure they are undertaking appropriate preparations
- as part of its overarching Brexit communications strategy, the CCPC will run a further public awareness campaign on the potential changes to consumer rights as a result of Brexit. The CCPC and other stakeholders will also work to inform consumers regarding customs requirements that may apply to online purchases from the UK.
Businesses should now:
- intensify preparations for the changes that will occur on 1 January 2021
- prepare for new customs arrangements and ensure you register with the relevant authorities
- ensure that your supply chain partners are prepared for new customs arrangement
- consider applying for the Call 2 COVID-19 Online Retail Scheme, which supports indigenous Irish retailers to sustain their business through the crisis and into the future, by the closing date of 28 September 2020.
- continue to engage with stakeholder outreach delivered via the relevant Government Departments and State Agencies as a means of underpinning informed and appropriate decisions
- familiarise yourself with the relevant supports available. Individuals should now:
- understand the implications (including additional costs, delivery issues, after sales complaints, withdrawal rights and refunds) of making online purchases after the end of the transition period from traders whose operations are based in the UK.
- familiarise yourself with how your consumer rights may be affected by the end of the transition period, including through the information available on the CCPC website.
The European Commission has published a Readiness Notice on Consumer Protection providing guidance on how consumers’ rights will be affected by the end of the transition period.
The Department of Health is working closely with the Health Service Executive (HSE), and the Health Products Regulatory Authority (HPRA), along with stakeholders throughout the supply chain, at national and EU level to ensure that regulatory issues and any potential supply issues arising from Brexit are addressed, in so far as is possible, to protect the continuity of supply of medicines and medical devices.
The Government will also continue to work with the European Commission and relevant stakeholders to ensure that patients in Ireland will continue to have access to high quality, safe and effective treatments.
As a result of measures undertaken at industry, national and EU level, Brexit is not expected to have any immediate impact on the supply of medicines. Any emerging supply issues, due to disruption at ports, for example, will, in the first instance, be dealt with from existing supplies held within the domestic supply chain.
There are already additional stocks of medicines routinely built into the Irish medicine supply chain, which is different to the wholesaling model in the UK. Through collaborative engagement with medicines manufacturers and wholesalers, they have assured us that they are confident that they will have sufficient stocks to bridge any initial issues at ports, should they occur.
Medicine shortages do arise from time to time and the Irish health sector has an established national, multi-stakeholder, Medicine Shortages Framework in place to prevent and react to any potential medicine supply issues in Ireland. This multi-stakeholder mechanism will be used to address any potential medicine supply issues that may emerge.
Nonetheless, given the size of the Irish market, Brexit may cause those with a small share of a particular medicine market to consider the ongoing viability of supply to Ireland. However, as a result of the medicines criticality assessment exercises carried out in 2019, there is no evidence to suggest that any products that may be affected would be likely to be critical to continuity of care as there are, and will be, alternative suppliers or therapeutic alternatives available.
A further criticality assessment exercise will begin in October to refresh our assessment of the supply of medicines in the context of the ongoing COVID-19 pandemic. All available measures will be taken to ensure continuity of treatment for patients in Ireland.
Manufacturers with medical devices that are currently certified by UK notified bodies but placed on the EU market, need to transfer certificates to an EU27 notified body in advance of the end of the transition period.
While one of the key issues regarding Brexit preparedness for medical devices previously was the relocation of UK notified bodies to the EU post-Brexit, significant progress has been achieved in this regard in recent months, with the final remaining UK notified body of key concern now accredited in Belgium, and it is understood that the transfer of certificates has progressed significantly.
A refresh of the criticality assessment exercises carried out in 2019 by the Department of Health, the HSE, and the HPRA to identify and assess any issues which may affect the supply of medical devices to Ireland after the end of the transition period, including regulatory issues, will be carried out in advance of the end of the transition period. As with the work on medicines, this refresh will also include an assessment of the impact of COVID-19 on the supply of medical devices.
Government will:
- refresh criticality assessment exercises before the end of the transition period, to seek further assurance on medicines and medical devices used in Ireland and identify potential vulnerabilities
- review the impact COVID-19 has had, and will have on buffer stocks of medicines and medical devices and further develop contingency measures where necessary to ensure continuity of treatment for patients in Ireland
- engage through the established national multi-stakeholder Medicines Shortages Framework to seek to address any supply issues that do arise
- engage with industry (including marketing authorisation holders, wholesalers and pharmacists) and relevant clinical leads on mitigation measures such as alternative sources, alternative transport routes, and alternative medicines or treatment regimens to ensure continuity of treatment to patients in Ireland
- continue to work with the European Commission on the issue of the supply of medicines post-Brexit
Businesses should now:
- put in place necessary mitigation measures to ensure continuity of supply of medicines and medical devices. This should include reviewing stock levels and mapping supply routes to identify and resolve outstanding Brexit exposure issues.
- complete remaining necessary regulatory changes to ensure that all medicines and medical devices on the Irish market meet EU regulatory requirements in advance of the end of the transition period including relocation of batch release and QC testing sites of medicines from the UK to EU/EEA and transfer of medical device certificates to EU27 notified bodies.
Individual patients, hospitals, and pharmacies should not:
- order extra quantities of medicines and doctors should not issue additional prescriptions. Doing so could disrupt existing stock levels and hamper the supply of medicines for other patients. Patients should continue to fill their prescriptions as normal. Any such actions would cause greater disruption to the supply chain.
The European Commission has published a Readiness Notice to help stakeholders in the area of medicines and medical devices to prepare for the end of the transition period.
