Brexit, a guide for the UK timber industry
After Brexit, whether a deal is signed or not, the UK will see a fundamental shift in its relationship with the EU. It is essential that every businesses in the UK timber supply chain is prepared.
To help you better prepare for the end of the Brexit transition period, when the UK leaves the EU Customs Union on 1 January 2021, the Timber Trade Federation has created a comprehensive document (TTF Brexit Guide: preparing for 1 January 2021, a guide for the UK timber industry), available to download here. We have condensed this information below but encourage you to make the time to read this document in full. Should you need advice or have any questions, we urge you to contact the TTF directly.
The TTF will be also be hosting an online event on Tuesday 24 November (Brexit and the timber supply chain), which will focus on the regulatory, operational and market impact. This will include an update on the economic impact of Brexit from Noble Francis, Economic Director of the Construction Products Association.
Getting started
In short: whether a deal is signed or not, the UK will see a fundamental shift in its relationship with the EU. It is essential that every businesses in the UK timber supply chain is prepared.
As with any industry which imports and exports goods, the timber industry is facing new processes, including:
- The introduction of custom checks on goods coming from EU countries
- The UK Global Tariff replacing the EU Common External Tariff
- The need for most timber firms to complete Due Diligence
- The introduction of UK Conformity Assessed (UKCA) mark.
Customs entry
From 1 January 2021, 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. This means that goods will need to be declared, VAT paid on the goods and excise procedures completed. Northern Ireland will have a unique set of arrangements and will remain a part of the EU Customs Union. Further detail on these procedures will become apparent when the trading relationship with the EU is agreed ahead of the UK’s withdrawal.
Finance
From 1 January 2021, if businesses are registered for VAT in the UK, they will be able to account for import VAT on your VAT Return for goods imported from anywhere in the world. This means they will be able to declare and recover import VAT on the same VAT Return, rather than having to pay it upfront and recover it later. To account for import VAT on your VAT return businesses must ensure:
- The goods you import are for use in your business
- You include your EORI number, which starts ‘GB’ on your customers declaration
- You include your VAT registration number on your customers declaration, where needed
CE marking
EU Construction Product Regulations (CPR) are designed to harmonise construction product technical standards across EU member states to ensure that construction products sold within the EU meet certain safety and technical standards. One of the key changes for merchants as a result of Brexit will be that the UK will no longer be a part of these harmonised standards, with the UK setting up a parallel system which will mean new marks and approved bodies. The technical requirements will remain the same:
Development of Factory Production Control (FPC)
- In-house factory testing
- Involvement of a third party body to oversee FPC
- Involvement of a third party body to oversee FPC
- Product marking
- EU-wide common product standards
- Initial Type Testing
- Declaration of Performance
There will however be three notable differences:
1.) The CE mark on products will be replaced by a new UK mark
2.) Third party bodies to oversee the new UK mark will be called approved bodies rather than notified bodies
3.) The common product standards used by the UK mark will be called designated standards rather than harmonised standards.
Businesses must prepare for the end of recognition of the CE mark in Great Britain and affix the UK marking using a UK-recognised ‘approved body’ on 1 January 2022.
Any manufacturer using UK notified bodies to CE mark their goods, and which wishes to continue to sell into the EU, should take action now, as these bodies will no longer be able to oversee CE marking at the end of transition period on 31 December 2020.
Manufacturers which wish to continue placing goods on the UK market should talk to their current notified body about UK Conformity Assessed (UKCA) marking. Businesses should note that in Great Britain both the UK CA marking and the CE marking will be recognised until the end of 2021.
The TTF is advising all members to check with their current notified body to see what actions they should take. For more detailed information, click here.
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 Conformity Assessed (UKCA) mark
- Products exported to the EU or delivered directly from outside the EU must be CE marked
- Manufacturers must transfer away from current UK-notified body to continue CE marketing
- 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 CA 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
- Trussed Rafters, Metal Web Joists, I-beams manufactured in the UK
Duty rates
The UK will replace the EU’s Common External Tariff on 1 January 2021 at the end of the transition period with the UK Global Tariff (UKGT). The new tariff will be in pounds (£), not euros. Most wood products (154 codes of 200 codes) are duty free. For the other products (46 out of 200 codes), ‘No Deal’ means UK Global Tariff rates will be imposed on all EU trade and all goods from outside of the EU.
Under these rules, the majority of sawn and PAR products coming from the EU will not attract duty, however some panel products from the EU will, where previously they did not. The TTF is, however, currently advocating for this to change.
For more information, please click here.
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