What's next? A post-Brexit timeline

• The UK leaves the Customs Union
• Any EU trade agreements that the UK has managed to roll over will come into effect
• For countries where a trade deal has not been rolled over, the UK Global Tariff will come into effect.

Importing to Great Britain from the EU

• The new staged approach to imports from the EU comes into action; traders importing standard goods, covering everything from clothes to electronics, will need to prepare for basic customs requirements, such as keeping sufficient records of imported goods
• Safety and Security declarations will not be required on imports for the first six months; standard customs declarations will be needed from this date for controlled goods and excise goods like alcohol and tobacco products.
• There will be physical checks at the point of destination or other approved premises on all high-risk live animals and plants, and a requirement to pre-notify for certain movements, but they will not be required to enter Great Britain via a Border Control Post
• Export declarations and UK exit Safety and Security declarations will be required for all goods; traders importing and exporting goods using the Common Transit Convention will need to follow all of the transit procedures - these will not be introduced in stages
• The goods vehicle movement service will be introduced only for transit movements.
• Traders will then have up to six months to complete customs declarations after the date of import

Exporting from Great Britain to the EU

• The UK becomes a ‘third country’ and exports to the EU face the full EU Most Favoured Nation (MFN) tariffs, checks and customs procedures when it arrives at the EU border.

The Northern Ireland Protocol comes into effect

Goods entering Northern Ireland from Great Britain are subject to certain checks and/or controls:

• Any goods ‘at risk’ of onward movement to the EU (including the Republic of Ireland) will be subject to EU tariffs
• Sanitary and phytosanitary (SPS) checks will be applied at designated Border Control Posts (BCPs) in NI Ports to products of animal origin
• Goods entering or leaving NI will be subject to EU Single Market rules.
• The new Trader Support Service will be in place to assist with new administrative processes between Great Britain and Northern Ireland (see ‘Autumn 2020’ for more details)
• Goods from Northern Ireland entering into Great Britain will not be subject to checks or controls provided they meet the definition of qualifying status for ‘unfettered access’.

Regulated services

• UK financial services firms immediately lose unrestricted access to EU markets for products and services not covered by any of the UK or EU enacted contingency measures. UK financial services firms will have to ensure that assets and staff are transferred to the EU to continue servicing their contracts with EU counterparties
• The UK’s security of energy supply will initially be unaffected, but energy businesses may face supply chain difficulties at borders, as parts are caught in the same queues as manufacturers and retailers. From 1 January 2021, there will be two Day-ahead prices in the UK from the two Power Exchanges (PXs) as they will no longer be sharing their order books and therefore will not offer a common price
• From 1 January 2021, Commercial broadcasters operating in the EU using a UK license will need to ensure they have the appropriate license in an EU member state to continue operating
• The UK is no longer a participant in the European Common Aviation Area (ECAA) or the European Aviation Safety Agency (EASA) systems; this means that mutual recognition of safety certificates and licences between the UK and European systems – unless specifically outlined in the TCA – will be subject to a decision by the specialised committee on Aviation Safety
• There are now new barriers, including minimum numbers of locally resident staff for different roles; restrictions on the number of establishments; and foreign ownership rules.

Immigration

• The new points-based system has come into force
• Immigration rules apply to newly arriving EU citizens.

Aviation

• The UK has withdrawn completely from the European Union Aviation Safety Agency (EASA).

Movement of goods:

• From April, all products of animal origin (POAO) will require pre-notification and health documentation and physical checks will be conducted at the point of destination; any grace periods where EU Member States may have taken pragmatic approaches to customs compliance will fall away
• For firms trading between Great Britain and Northern Ireland, they will begin to fully access all aspects of the Trader Support Service (TSS) – however, many businesses will also find that to continue transporting goods from GB, additional checks and paperwork that cannot be completed in TSS will be required – this includes many shipments of food and animal livestock
• Goods entering Northern Ireland from Great Britain will be subject to certain checks and/or controls, on a phased basis:
  • Three month grace period - authorised traders such as supermarkets and their trusted suppliers will be given a three-month grace period from official certification for products of animal origin, composite products, food and feed of non-animal origin and plants and plant products.

Regulation:

• Month three - the grace period under REACH for UK companies importing chemicals to make initial registrations will have expired; if firms cannot import the substances they need, because of cost or complications, they may run the risk of losing contracts.

Services:

• Firms will experience higher costs and longer time periods to complete contracts; UK and EU financial markets may become more volatile and less liquid, particularly if trading venue equivalence decisions are not in place from exit day. Issues around contract continuity may also arise.

The EU Settlement Scheme deadline for registration is 30 June 2021.

Movement of goods:

• From July, the UK Border Operating Model will end, the full burden of customs declarations will become permanent, facing the full declarations at the point of importation and tariffs with additional paperwork and checks taking place.
• Northern Ireland Protocol:
  • 6 month grace period on authorised movements of restricted products such as chilled meats from GB-NI will end
  • 12 month grace period of regulatory requirements for medicines to avoid disruption to the flow of medicines from GB-NI will end

Data:

• In the event of no positive data adequacy decision by 1 July, the UK will be treated as a third country for personal data transfers, creating new legal requirements immediately and resulting in increased legal costs, interrupted data flows and reduced investment in data centres
• After six months without a data adequacy decision, more UK companies will shift jobs abroad in data-intensive areas such as HR, and increasingly invest in data centres in EU countries in place of UK ones as they see an increase in the loss of contracts with EU customers who no longer wish to deal with UK partners.

Regulation

• From 31 December 2021, the UK’s grace period on CE marking will end, meaning that firms must have switched to UKCA compliance by this date (GB products only). Temporary easements on regulated manufacturing will start to wane, creating a new rush to complete adjustments. Some exporters will be prohibited by the cost and hassle of separate UK and EU product testing, and cease to trade – reducing choice for consumers and competition that drives down prices. There are some concerns about the ability of existing UK testing houses to take on the additional load of products to be tested.

Services:

• Without an equivalence and adequacy agreement, Financial Services firms will make further transfers of staff and assets to the EU or stop some EU business and move to non-EU locations to optimise their business models and react to the requirements set by EU regulators.

Regulation

• While UK and EU rules and testing processes will remain broadly the same for regulated goods in the immediate years after no deal, in the future divergence will occur; this will increase the barriers to doing trade across borders for firms as they will have to cope with new and different requirements being introduced unevenly across the UK and the EU
• The grace period for providing all the data needed to fully register chemicals in the UK will expire. For the long-term, costs of double registration risk being unsustainable for many companies, creating potential for the UK to become a distinct market outside of Europe with a lesser offering of chemical substances.

Services

• The time-limited decision to give financial market participants 18 months to reduce their exposure to UK central counterparties (CCPs) will end in June 2022.

International trade:

• The UK will need to re-open a number of rollover deals, unless already replaced.