Should the EU and UK government reach a deal, then Westcoast is assuming that there will be a two year transition period which will tie the UK to a customs union for this temporary period and allow free movement of goods during this time. The government has then published a number of advice papers in different business sectors regarding “Planning for a ‘No Deal’ Brexit”. One of these papers specifically refers to the supply chain.
In summary, the paper focuses on 5 areas
- Likely changes to customs and excise procedures
- Advice on engaging with existing supply chain
- Trade will be on WTO terms
- Procedures for importing from outside the EU
- Customs declarations for EU trade – how will it be managed?
- If there is no deal, Westcoast will assume that border controls will be quickly erected and goods will have to pass through such borders.There will be inevitable delays in such procedures whether Westcoast are importing directly or vendors taking responsibility. Westcoast has recently written to all its major suppliers to ask them whether they will be responsible (as the vast number are now in the EU) for importing goods into the United Kingdom. At this stage, Westcoast is assuming that all major vendors will assume this responsibility and Westcoast will not be responsible for such imports (unless we are already). If any vendors do not assume such responsibility when contacted, we will publish this on this site and provide further guidance on Westcoast’s next steps.At this stage no such confirmation has been received from any major vendor.
- Many customers have written to Westcoast, clearly following the government’s advice. A summary of the main FAQ’s is below and should be taken as Westcoast’s latest position. Clearly, the company’s answers may change over time and we may receive new questions.Please keep reviewing this site to gain an updated view.
- World Trade Organisation terms on Information Technology which will govern all but the most obscure of Westcoast’s products, are governed by the WTO’s Information Technology Agreement of 1996. This is now signed up to by 82 countries including the EU which promote zero tariffs on all IT products. Whilst the UK is not yet able to sign up to this WTO agreement as it is still part of the EU, Westcoast assumes that the UK will agree to be part of this widespread international agreement and hence products imported into the UK will initially carry a zero tariff. Westcoast’s own terms and conditions currently allow for all tariffs and taxes to be passed onto customers in the event of any change and as a result no updates will need to be issued in Westcoast T’s & C’s.
- Westcoast currently imports approximately 2% of goods for resale from outside the EU and hence has procedures in place to manage such imports. If any major vendors force Westcoast to manage its UK imports, Westcoast will only have to increase its workforce to cope with increased volumes. Westcoast already has expertise in exporting to the EU and beyond the EU. Again this would require increased headcount to manage.
- Westcoast will employ a freight forwarder to manage customs declarations. The process of final selection of Westcoast’s partner is underway.
Other key considerations
- Westcoast is currently considering the impact on Ireland and would look to increase staffing levels in our Dublin warehouse if required.Vendors are being asked to deliver directly to Ireland in the event that a trade border is created between the two countries. Westcoast will increase headcount if required. Northern Ireland can be served by the UK if a trade border is created with the Irish Republic.
- Trade between the UK and mainland Europe may have to be done through Westcoast’s already extensive network of European warehouses if trading from the UK becomes uneconomic.
Cut-off around 29th March
Clearly all goods despatched before 29th March will still be under EU regulations and subject to free movement.Goods being despatched to the EU should be despatched before 28th March to ensure there are no restrictions.Whilst Westcoast will continue to ship in the UK on Saturday 30th March, no goods will be received over that weekend.
Any tariffs and taxes imposed after 29th March will be passed onto customers and hence all quotes outstanding will be subject to change. Any significant exchange rate fluctuation on goods not bought in sterling (eg print consumables) will also be passed onto customers and again quotes will be subject to change. Finally, any vendor price changes will be passed on to customers in full as normal. Customers will be given as much notice as possible.
Origin of goods
Most products sold by Westcoast are manufactured in China, imported into the EU by the vendor, and completed and sold in the EU. No change from any vendor is anticipated.
The 2018 Data Protection act incorporates the EU’s GDPR regulations in full. No divergence of this law is anticipated and hence there are unlikely to be any restrictions in transmission of personal data outside those currently in place.
Timeliness of deliveries
Westcoast anticipates increasing stock levels before 29th March in the event of a no deal Brexit and discussions with vendors are underway. This may help smooth any immediate issues experienced in supply to customers but clearly this increase will only be temporary.
Plans to manage customs
Westcoast is currently investigating the advantages and need to register to AEP (Authorised Economic Operator) and/or EORI (Economic Operators Registration and Identification).
Westcoast does not generally undertake remote professional services from the UK for EU customers. Westcoast is currently assessing the impact of any product enhancement services (eg asset tagging, software loading, etc) to ensure they can be offered without restriction.
Countries in the EEA would be treated in the same way as those countries in the EU.
Timeliness of deliveries post Brexit
As the UK’s position becomes clearer over the coming months, it will be possible to provide further guidance to customers on any likely delays in any particular product areas or vendors after 29th March. Specific delivery information will be available on individual orders as normal but a no deal Brexit will almost certainly lead to some delays.
For any questions or queries contact our Westcoast Brexit committee at firstname.lastname@example.org