Brexit and the Timber Industry

This page informs businesses of the implications for the trade in goods between the UK and EU countries and the actions they may want to consider taking to mitigate the potential impacts in the event of a No Deal Brexit which may occur on 31st October 2019.

Before you bring goods into the UK

Getting started

 

  1. Get an Get an Economic Operator Registration and Identification (EORI) number that starts with GB.
  2. Decide if you want to make customs declarations yourself or get help
  3. You may need to buy specialist software to use simplified procedures.
  4. You could be entitled to financial help to help your business complete customs declarations.
  5. If you already have authorisations to use special or simplified procedures check if they still apply.
  6. If you do not already use simplified customs procedures, find out if you can register to use transitional simplified procedures. You can also find out about making declarations using transitional simplified procedures. This can make it easier for you to import goods from the EU.

Custom Rules in a No Deal Brexit

In a No Deal Brexit, you’ll need to follow the same Customs rules if you import from anywhere outside the UK.

 

In a No Deal Brexit, UK businesses that import goods will need to apply the same procedures to EU trade that apply when trading with the rest of the world.

 

HMRC has introduced transitional simplified procedures to help businesses import goods from the EU. We’ll review them 3 to 6 months after they’re introduced.

 

This guidance does not apply to moving goods between Ireland and Northern Ireland.

Accounting for import VAT on goods imported into the UK

If the UK leaves the EU without an agreement, the government will introduce postponed accounting for import VAT on goods brought into the UK. This means that UK VAT registered businesses importing goods to the UK will be able to account for import VAT on their VAT return, rather than paying import VAT on or soon after the time that the goods arrive at the UK border. This will apply both to imports from the EU and non-EU countries.

Click here for more information.

Complying with the EU Timber Regulations in a No Deal Brexit

Exporting

To continue to comply with the EUTR, EU and EEA businesses would be required to apply due diligence to imports from the UK. As a result, it is likely that UK-based exporters would need to provide relevant documentation about the source and legality of their timber exports to EU and EEA-based importers to enable their customers to meet their due diligence obligations under the EUTR.

 

The documents will need to allow EU importers of UK products to fulfil the due diligence requirements of the EUTR given above. EU and EEA businesses importing timber from the UK that is covered by a CITES import permit will not need to conduct due diligence.

 

The TTF’s technical notice provides further detail on the impact of a ‘No-Deal’ Brexit on the timber industry.

 

Importing

In the case of a No Deal Brexit, anyone importing timber from the EU into the UK will now have to undertake full due diligence of their products to adhere to our Responsible Purchasing Policy.

 

From 31st October, importers of EU timber will be considered ‘Operators’ and will be obliged to exercise due diligence that concludes negligible risk of illegally harvested timber entering their supply chain.

 

For more information, click here.

CE Marking in a No Deal Brexit - September 2019

Executive Summary

  • UK Notified Bodies will no longer be able to support CE marking
  • UK Notified Bodies will automatically become UK Accreditation Bodies
  • Products placed on the UK market will still require accreditation
  • UK Manufacturers can choose CE marking or the new UK Accreditation mark.
  • Products exported to EU or delivered directly from outside EU must be CE marked
  • Manufacturers must transfer away from current UK Notified Body to continue CE marking
  • Manufacturers must change logo to start using new UK Accreditation mark
  • Manufacturers who mark without a notified body (level 4) can choose CE or UK marking

 

If you are currently using a UK notified Body such as BM TRADA or CATG to support CE marking for products you are placing on the market, for instance:

  • Strength Graded Timber
  • Plywood manufactured outside the EU
  • Wood Based Panels manufactured in the UK or outside the EU

 

You should speak to your UK Notified Body to discuss the options available. If you do nothing you are at risk that the construction products you are currently placing on the UK or EU market may no longer be accepted after 1st November.

 

For more information visit https://www.gov.uk/guidance/construction-products-regulation-if-there-is-no-brexit-deal and for more information about the new UK Accreditation mark, including samples, visit https://www.gov.uk/guidance/prepare-to-use-the-ukca-mark-after-brexit

Import Tariffs in a No Deal Brexit

In the case of a No Deal Brexit there will be ZERO CUSTOMS DUTY for paper and wood products.

 

Look up the planned duty rate for your product code here.

Construction Products Regulation & CE Marking

The Construction Products Regulation CPR is classified as a “new approach” regulation and so the following information comes from the government guidance paper “Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal”

 

A critical statement within this Government guidance is: “Products that meet EU requirements can continue to be placed on the UK market without any need for retesting or re-marking, including where they have demonstrated compliance with EU requirements after exit day.”

 

This means that as a UK Manufacturer or Importer placing CE marked goods for construction on the UK market your business can, in the event of a deal or a no deal scenario, continue to operate legally without significant change.

 

Members are advised to check with their Notified Body to confirm they have the necessary arrangements in place.

 

As a consequence of leaving the EU, there will be changes in the longer term principally because the UK will no longer be able to participate in the EU structures developed for implementation of the Construction Products Regulation. This means to pursue the stated objective of “frictionless trade” the UK is developing a parallel system in which:

  • The Construction Products Regulation will become UK law.
  • Existing harmonised standards such as – EN.14250 for Trussed Rafters (used to demonstrate conformity with EU essential requirements) will become UK ‘designated standards’, used to demonstrate conformity with UK essential requirements. Which, immediately following exit these will be identical to EU essential requirements.
  • Notified bodies based in the UK will be granted new UK ‘approved body’ status and listed on a new UK database.
  • Approved bodies will be able to assess products for the UK market against UK essential requirements. Which, immediately after exit day in a ‘no deal’ scenario, will be identical to EU essential requirements.
  • A new UK conformity mark is being developed by the UK government which manufacturers selling goods on to the UK market will then be able to affix before placing a product on the UK market.

 

For UK manufacturers wishing to export and place CE marked goods for construction on the EU market, your business can, in the event of a deal or a no deal scenario, continue to operate legally provided the notified body you are using is registered in an EU member state or has a partnership arrangement with such a body.

 

Click here for more information.

Trading & Moving Endangered Species Protected by CITES

This includes both endangered animals and plants. Find the government’s paper here.

 Resource Library

Resource Library

Download the latest TTF and Government guides on Brexit 

 TTF Brexit Posts

TTF Brexit Posts

Read our posts on Brexit 

TTF Advice

1. If you’re not already doing so, start establishing your product supply chain risk profile

1.a. For all EU products, find out about your product’s:

1. Country of Harvest

2. Country of Production/Supply

3. Species

4. Certification Status

 

1.b. Identify products and supply chains that carry higher risks, i.e. products from non-EU forests, or products from countries with high prevalence of illegal logging or uncertified products

2. Request due diligence information from your product’s supplier

3. Contact TTF for guidance and tools on how to carry out standard due diligence for your timber products

No Deal FAQs

When we leave the EU, will the UK have its own regulations to replace the EU Timber Regulation (EUTR)?

Yes, the UK government will implement its own UK Timber Regulation which will have the same requirements as the EU Timber Regulation (EUTR) and Forest Law Enforcement Governance and Trade (FLEGT).

In a No Deal scenario, what will be the additional requirements placed on UK business?

If you are importing into the UK from the EU or the EEA, you will become an operator. You will need to carry out due diligence confirming your timber has been legally harvested.

 

According to the UK Competent Authority – Office for Product Safety and Standards (OPSS) – there will be a 12-month period of awareness raising to allow businesses to identify and adjust to any new obligations.

 

Workshops will be provided targeting businesses who may not have previously been required to carry out due diligence on timber products. However, in the case where non-compliance is identified, businesses’ previous experience applying due diligence will be considered.

 

If you are exporting to the EU or EEA , you may need to supply documentation about the source and legality of your timber. This is so your EU and EEA-based customers can meet the EU Timber Regulation (EUTR) due diligence rules.

How will the UK Timber Regulation be enforced?

The way in which the regulation is enforced would stay similar to now but will apply to more companies who will have the responsibilities as operators. The Office for Product Safety and Standards (OPSS) would continue to check that appropriate records are maintained by businesses.

 

The enforcement will be mostly likely focus on high risk product and supply chains.

For businesses currently importing from outside of the EU, will there be changes to the current process?

There will be no changes to the current process. You’ll still need to carry out due diligence to confirm the timber is legally harvested if you’re a business importing from non-EU or EEA countries.

 

There will also be no changes if you are a UK producer placing timber on the market for the first time, or, carrying out internal UK trade.

Will the UK continue to recognise FLEGT licensed timber as meeting the requirements on EU/UK TR?

The government is working to ensure FLEGT licenses continue to be recognised in the UK in a ‘no deal’ scenario. The licences will continue to be verified by the Office for Product Safety and Standards.

I am currently using a due diligence system developed by a Monitoring Organisation (MO), can I continue to use them to help meet the regulation?

Monitoring organisations established in the UK would automatically continue to be recognised by the UK. The UK will not automatically recognise EU or EEA monitoring organisations if there’s no deal. The EU has indicated it will no longer recognise monitoring organisations based in the UK if there’s no deal.