CE Int ConsultingWelcome to Customs & Excise Intl. Consulting Limited (CEICL).

CEICL is a boutique Customs and Excise Consulting Service to industry, established in 2015 by Chris Byrne to provide unique services in the area of customs and excise and trade advice to businesses in Ireland, the EU, and third countries. Chris, who previously worked with PwC and also served nationally and internationally as a Customs and Excise Official with the Irish Revenue Commissioners.

The CEICL is supported by a team of experts in customs, industry, and large practice experience to bring to the business sector. CEICL is part of a network of Legal, Tax and VAT professionals in Ireland, the UK, other EU Member States, USA, and other third countries. Due to the wealth of experience, we have extensive contacts in Customs Authorities throughout Europe, the US, Australia and also in the EU Commission and World Customs Organisation.

As an independent practice, there is no restriction or limitation on the services CEICL can provide such as those restrictions resulting from US Sarbanes Oxley and other similar regulations in other territories.

United Kingdom and EU Rules in the field of Customs, including Preferential Origin


UK – EU Border Model

The Border Target Operating Model sets out new controls to better protect the UK against security and biosecurity threats and create a world-class border system for trade in goods. Published29 August 2023

The Border Target Operating Model for trade in goods, published today, 29th August 2023, sets out when new controls will be introduced to better protect the UK against biosecurity threats and create a world-class border system.

Delivering on the 2025 Border Strategy to create the most effective border in the world, the model introduces a new global regime for security and biosecurity controls, including bringing in controls on imports from the EU for the first time and using Brexit freedoms to simplify import controls on goods from across the globe. Many businesses will already be familiar with similar requirements already in place for exporting to the EU.

These controls will keep the UK safe by defending against plant and animal diseases from abroad, protecting our vital agricultural industry and food supply chains, and assuring our trade partners of the quality of our exports. It will also protect against illegal imports, including firearms and drugs.

The Border Target Operating Model makes smarter use of data and technology to ensure a more efficient trading experience for businesses. By taking an intelligent, risk-based approach, it removes duplication and reduces the volume of data and paperwork required from businesses when importing goods. This will save businesses around £520m per year compared to the original import model that would have been introduced in 2022.

The model has been developed following extensive engagement with the border industry and businesses across the UK, and in collaboration with the Scottish and Welsh Devolved Administrations. Having listened to the views of industry, the Government has agreed to a delay of three months for the introduction of remaining sanitary and phytosanitary controls, as well as full customs controls for non-qualifying Northern Ireland goods, which will now be introduced from January 2024. To give stakeholders additional time to prepare for the new checks, further controls have a revised timetable. These include checks on medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU, implemented in April 2024, and safety and Security declarations for EU imports, implemented in October 2024.

The Government has also worked with industry to test new technologies in a border setting, including distributed ledgers for sharing data, smart seals and GPS trackers. Pilot testing found these technologies could simplify processes across the supply chain, transforming the UK border through reduced costs and administrative burdens, making importing and exporting easier and cheaper for businesses.

In addition to the Border Target Operating Model, the Single Trade Window is another flagship border development which makes smarter use of data and technology. It will simplify and streamline import and export trade processes and provide a single gateway through which businesses can supply trade data to the government. Under this system, information will only need to be submitted by traders once and in one place, removing complexity and duplication from the system.

Notes to editors:

  • The Border Target Operating Model incorporates feedback from the Draft Border Target Operating Model which was published in April 2023
  • The Border Target Operating Model confirms implementation of controls through three major milestones:
    • 31 January 2024 – The introduction of health certification on imports of medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU
    • 30 April 2024 – The introduction of documentary and risk-based identity and physical checks on medium risk animal products, plants, plant products and high risk food (and feed) of non-animal origin from the EU. At this point Imports of Sanitary and Phytosanitary goods from the rest of the world will begin to benefit from the new risk based model
    • 31 October 2024 – Safety and Security declarations for EU imports will come into force from 31 October 2024. Alongside this, we will introduce a reduced dataset for imports
  • Importers and their supply should already be preparing for the first milestone which we confirmed would go ahead in April. They should now begin to prepare for the following milestones. HMG will continue to work with them, ports, and the wider border industry to prepare for these
  • The final Border Target Operating Model also confirms that new checks and controls will be introduced for Irish goods moving from Ireland directly to Great Britain. In accordance with the Windsor Framework, Northern Ireland businesses will retain unfettered access to their most important market in Great Britain, whether moving qualifying NI goods directly from Northern Ireland or indirectly through Irish ports. A full timeline for introduction of these controls is set out within the Border Target Operating Model.
  • In developing the Border Target Operating Model the Government has been mindful of the small potential impact on food inflation and has taken into account its firm commitment to bring the rate down. The estimated impact of the Border Target Operating Model on food inflation is expected to be minor, standing at less than 0.2% across three years.

Are you ready for ICS2?

On 15 March 2021 the European Union will launch a new EU customs pre-arrival security and safety programme, supported by a large-scale information system called ICS2 (Import Control System 2).

The programme will help establish an integrated EU approach to reinforce customs risk management framework. It is a core delivery of the Union Customs Code, the EU customs risk management strategy and action plan adopted by the Council in year 2014. It will support effective risk-based customs controls whilst facilitating free flow of legitimate trade across the EU external borders. It will do this through improved data-driven customs security processes, adapted to global business models.

Its implementation is an essential EU customs instrument for managing entry security and safety border controls. It is the first line of defence in terms of protecting the internal market and EU citizens.   The programme involves a complete overhaul and reform of the existing regime from IT, legal, customs risk management/controls and trade operational perspectives. As a result, the existing Import Control System (ICS), will be phased-out and replaced by the ICS2.

As an advance cargo information system, ICS2 will collect data about all goods entering the EU prior to their arrival. Economic Operators will have to declare safety and security data to ICS2, through a so-called Entry Summary Declaration. The obligation to start filing such declarations will not be the same for all Economic Operators. It will depend on the type of services that they provide in the international movement of goods and is linked to the three release dates of ICS2 (15 March 2021, 1 March 2023, and 1 March 2024).

All Economic Operators involved in handling, shipping and transporting of cargo, express or postal consignments will be affected by ICS2, and need to start getting ready for it. How? By adapting their business processes, taking steps to ensure high quality and precise data is provided, developing or updating their IT systems for exchange of information, and providing training and support to their staff.

If the different Economic Operators are not ready in time and the necessary data has not been submitted to ICS2, consignments and cargo will be stopped at EU Customs borders, and customs will not proceed with goods clearance. It should also be noted that poor quality declarations will either be rejected or subject to unnecessary interventions, and may result in sanctions for non-compliance.

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The United Kingdom left the European Union on 31 January 2020. Currently there is a Withdrawal Agreement in place which provides a window until 31st December 2020. The current period is known as a transition period.
This time-limited period was agreed as part of the Withdrawal Agreement and is currently planned to last until 31 December 2020. Until then, it will be business as usual for citizens, consumers, businesses, investors, students and researchers, for instance, in both the EU and the United Kingdom.
The EU and the United Kingdom will use these months to negotiate a new and fair partnership for the future, based on the Political Declaration agreed between the EU and the United Kingdom in October 2019.

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