Purpose

This document sets CRYOPDP plans in the event of a “no trade deal” Brexit in December 2020. The assumption of a “no trade deal” Brexit is that the UK would be treated as a non-EU country in terms of custom arrangements and World Trade Organisation tariffs would apply. It is assumed in this document that customs/border procedures in January 2021 would exactly mirror the arrangements for non-EU countries without concessions. CRYOPDP considers this as the worst-case scenario as there are likely to be some form of concession around shipments related to healthcare.

Background

With the current indecisions about a Brexit trade deal, all possible final scenarios may provide some challenges for Pharmaceutical and Life Sciences Industry supply chains. 

What is clear is that regardless of a trade deal, trade between the UK and EU countries will be subject to customs and border checks.

From January 2021, border procedures would correspond with arrangements of non-EU countries without concessions which would put pressure on supply chains in terms of customs arrangements and application of world trade organization tariffs.  

Shipments between the UK and EU countries account for approximately 30% of total shipments handled by CRYOPDP. A significant proportion of EU shipments relates to the UK operating as an EU hub for shipments originating outside of the EU. 

Since the majority of CRYOPDP shipments have origins or destinations outside of Europe, CRYOPDP has the processes, systems and detailed knowledge to manage shipments to and from the UK under non-EU border/customs arrangements. However, the application of non-EU arrangements to the UK will inevitably result in additional costs, temporary increased transit times and unpredictable delays. The biggest impact is likely to be over the first six months of 2021 as the UK and EU borders cope with the increased clearances between the UK and EU. 

 

Likely Operations Impacts and Mitigations

Additional Costs

CRYOPDP will work with individual customers to develop the most cost-effective routes to meet customer’s requirements and service levels. It is difficult to quantify the additional costs associated with a “no trade deal” Brexit but they will fall into the following categories:

• Additional resources and costs to expedite clearances at Feltham, new EU hub and through CRYOPDP partners (agents).
• Potential EU import duties especially around pharmaceuticals.
• Incremental air freight costs from switching shipments from UK hub to European hub.

 

Must have checklist

• Customs Clearance formalities will have to be undertaken in both theUK and in Europe
• All shipments will require both Export Customs Clearance from the Seller’s Country and Import Customs clearance in the Buyer’s Country.
• CRYOPDP can facilitate the UK Customs procedures but we will need to advise if clearance is required at the other end (destination).
• If you require CRYOPDP to make an Import declaration on your behalf we need you to have signed a Letter of Direct Representation.
• We will require you to sign a legal letter of indemnity making you responsible for any Customs debt. Direct Representation Document
• You must understand your company’s responsibilities when Customs declarations are made on your behalf and if possible to obtain indemnities
• All Importers and Exporters MUST HAVE an EORI Number.
• YOU MUST be able to provide the following information a minimum of 72 hours prior to your freight being loaded. This enables CRYOPDP to have prepared your Customs documents. For shipments from the UK to the EU “Permission to Progress” will be gained and the freight can be collected. For shipments from the EU to the UK CRYOPDP can lodge your import entry prior to the freight arriving in the UK. This will only apply where a vehicle is used to import or export by road via the channel tunnel or channel ferry.

 

Additional Resources

BREXIT – Information and updates

Import goods from outside the EU: step by step

List of goods imported into Great Britain from the EU that are controlled from January 2021

Delaying declarations for EU goods brought into Great Britain from 1 January 2021

The Brexit transition period is set to expire on December 31, 2020. If you have questions regarding possible outcomes and effects on transporting goods across international borders, please contact CRYOPDP at contact@cryopdp.com