The transition period ends in less than three months on 31 December 2020 and negotiations between the UK and the EU on their future relationship remain unconcluded. In respect of the movement of goods between the UK and the EU (and even within the UK, between GB and NI), whilst many points have become clear, a good number are still to be resolved.
- New registrations, authorisations and licences may be required. For example, Economic Operators' Registration and Identification (EORI) previously granted by the UK will not be valid in the EU after the end of the transition period, and the same applies for EU EORI in respect of the UK.
- Additional procedures and formalities apply in respect of the trade in goods between Great Britain (i.e. England, Scotland and Wales) and the EU, but the coming-into-effect of some of the border processes on the GB side would be delayed until 1 July 2021 according to the UK government's border operating model.
- The position in respect of Northern Ireland remains complicated. The European Commission has stated that the trade in goods between NI and the EU will continue unaffected. Meanwhile, the UK government has promised "full unfettered access" for NI goods to the GB market and included provisions in the Internal Market Bill designed to safeguard against any attempt on the part of the EU to impose restrictions on the movement of goods within the UK.
The Best Friends group of BonelliErede, De Brauw Blackstone Westbroek, Hengeler Mueller, Slaughter and May and Uría Menéndez has prepared a Brexit Preparedness Check which sets out an overview of the anticipated arrangements for the movement of goods between the UK and the EU, and within the UK. Please refer to this for further details.