The effects of Brexit on exports

Current situation

The European Commission has reached 24th December 2020 an agreement with the United Kingdom on the terms of its future cooperation with the European Union. The agreement is applied from 1 January 2021. The new relationship between the EU and Britain is clearly more distant than before, which means, among other things, increased paperwork and new costs in trade between the EU and Britain. Although the TDCA is comprehensive and provides, inter alia, duty-free and quota-free access to the Parties' markets for certain products, it does not replace the internal market. Trade between the EU and Britain will therefore change significantly, despite the conclusion of the agreement.

General information on the situation after the transition period

The new border controls on imports coming into GB will enter into force gradually, in three stages according to the UK’s Border Operating Model published in October 2020. The European Commission has published in July 2020 its own communication on readiness at the end of the transition period. Below are excerpts from both the Commission Communication and the British guideline.

Excerpts from the Commission communication of 9.7.2020:

  • Northern Ireland continues to be subject to Union rules on goods and the Union Customs Code. The VAT and excise rules apply to all goods entering or leaving Northern Ireland.
  • Goods lawfully placed on the market before the end of the transitional period may continue to move freely on the EU or UK market until they reach their end-users, without the need for re-certification, re-labelling or product modifications.
  • EU companies wishing to import from or export to the UK must ensure that, from 1 January 2021, they have the EORI (Economic Operator Registration and Identification) number required for customs formalities.
  • UK content (both materials and processing operations) will become 'non-originating' under Union preferential trade arrangements for the determination of the preferential origin of the goods containing such UK content. In practice, this means that EU exporters will have to re-evaluate their supply chains. They may have to relocate their production or change suppliers for some inputs in order to continue to benefit from the Union preferential arrangements with current Union preferential partners.
  • Goods exported from the Union to the United Kingdom will be exempt from VAT if the supplier of the exported goods can prove that the goods have left the Union.

Excerpts from the UK’s Border Operating Model issued in October 2020:

January 2021

The first changes will take effect from the beginning of January. New control procedures will apply e.g. to the exports of plants and plant products, fishery products, by-products, live animals and germinal products.

  • Exports of high-priority plants and plant products require a phytosanitary certificate, pre-notification and checks. These products include: plants for planting, ware potatoes, some seeds and timber. The requirements also apply to used agricultural and forestry machinery.
  • The wooden packaging material must be treated and marked in accordance with the ISPM 15 standard.
  • Exports of fishery products to the United Kingdom are subject to import controls. In addition, the export of marine-caught fish is subject to a catch certificate.
  • Exports of live animals and germinal products to the GB require a health certificate. The health certificates are in TRACES Classic system. The importer has to make a pre-notification via the Importation of Products, Animals, Food and Feed System (IPAFFS). Importation through the border control post will not become mandatory until July 2021.
  • Exports of high-risk animal by-products from the EU to the UK require pre-authorization and a commercial document that can be made in TRACES Classic system. In addition, the IPAFFS notification system must be used. A commercial document is required for most other by-products as well.
  • For live animals, germinal products, and products of animal origin (POAO) subject to safeguarding measures, the importer obtains a Unique Notification Number (UNN) from APHA (Animal & Plant Health Agency) which must be put in the box No I.6 in TRACES health certificate.

April 2021

From the beginning of April, new control procedures will apply to most of the products. For example, various foods of plant and animal origin are now subject to pre-notification and a health certificate.

  • Products of animal origin, as well as all regulated plants and plant products, must be notified in advance through the IPAFFS system when they are imported from the EU into the GB. Exports of these products also require health certificates. It is the responsibility of importers to notify the arrival of the products at the border control post. At the same time, it can be ensured that the border control post is suitable for inspecting the product in question.
  • All regulated plant products must be accompanied by a phytosanitary certificate. Imports must be notified in advance and import consignments will be subject to possible import controls. In addition to high-risk products, regulated products include certain fruits, vegetables, certain cut flowers and certain cereals.

July 2021

At the beginning of July, all products and animals imported into the UK are subject to a border control at a border control post. In addition, imports must be notified in advance and the products must be accompanied by a health certificate.

  • The entry via an established point of entry with an appropriate border control post and physical checks at border control points will only become a requirement in July 2021.
  • All regulated plants and plant products will be subject to import requirements. Physical checks are carried out at border control posts. A complete list of regulated plants and plant products is not yet available. More information on the UK’s website.


Page last updated 1/8/2021