The British Woodworking Federation Group
Brexit and the Timber Industry

This page informs woodworking 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 the extended deadline day of 31st January 2020.

Brexit and the Timber Industry

Key Information – Brexit and the Timber Industry

 

On Monday 28th October EU leaders agreed in principle to extend Brexit until 31st January 2020 – meaning that the UK will not leave as planned on 31st October 2020.  Whilst the Government are working hard to secure a deal, there is the possibility that the UK will leave the EU without a deal.

This page has been specifically designed to help BWF members prepare for a ‘No Deal’ Brexit scenario. We will update this information as soon as we are made aware of developments by the Government. However, we would urge all members to also visit the Government’s own website regularly – click here for more details.

Q1. If we leave the EU with a ‘No Deal’, what will be the impact on manufacturing / product marking legislation?

CE marking enables a ‘construction’ product to be placed legally on the market in any Member State under the Construction Products Regulation (CPR). If the UK leaves the EU with a ‘No Deal’ scenario, all existing European harmonised standards will become UK ‘designated standards’. This means that goods legitimately affixed with CE marking already in the UK market before the UK leaves the EU on 31st January 2020 will be able to continue to circulate in the UK.

Additionally, goods which are made and assessed against EU harmonised standards and legitimately carry the CE marking can continue to be placed on the UK market. It is intended that these arrangements will be for a time-limited period which is to be confirmed by the government.

Q2. Will the role of Notification Bodies remain the same?

– Notified bodies operating under the Construction Products Regulation (CPR) and 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 undertake conformity assessment activity for UK designated standards. Where a UK approved body has undertaken the assessment, the manufacturer must affix the new UK marking. Rules around affixing the new UK conformity marking will remain the same as current CE marking.

– After exit day under a ‘No Deal’ scenario when an Approved Body (previously a UK-based Notified Body) carried out conformity tasks for a product before exit day, that work may be used to support UK marking.

– After exit day when an EU based Notified Body carried out conformity tasks for a product before exit day that work will continue to be used to support CE marking.

Q3. Will I need to use the new UK Mark immediately?

– Manufacturers will not need to use the new UK mark immediately if they have complied with the EU requirements and have CE marked their products.

– In the scenario whereby the conformity assessment was carried out by an EU notified body, those manufacturers will only be permitted to use the CE Mark for a limited time after exit day. This ‘permitted time’ is yet to be agreed by the Government.

– After exit day manufacturers will only be able to rely on work by a UK Approved Body for UK Marking.

– For AVCP system 4, where there is no requirement to use a Notified or Approved Body for any conformity tasks, the manufacturer can choose to apply either the CE mark or the UK mark or both. But this would be for a limited time after exit day. Please note, or exporting to the EU the CE mark would be needed.

Q4. Will UK manufacturers exporting to the EU be able to use a new UK Approved Body?

If a manufacturer has had conformity tasks for CE marking undertaken by a UK based Notified Body before exit day and they plan to continue placing the product concerned on the EU market after exit day they should either:

1.  apply for a new assessment by an EU based notified body, OR

2. transfer their file from the UK based notified body to an EU Notified Body, who would then take over the responsibility for that work.

Products must be placed on the EU market by a legal entity established in the EU, and UK manufacturers will be required to work with an EU-based importer or distributor.

Q5. What will happen to Technical Assessment Bodies?

Similar arrangements as detailed above, will be applied to Assessment Bodies who carry out assessments on construction products which are not fully covered by a UK designated standard.

Q6. Will the process of importing EU products into the UK change?

Distributors who bring products in from the EU to the UK will be classified as ‘importers’ bringing in products to the UK from a third country. This change in status will bring new obligations such as a requirement to label their products with their name and address, ensuring the manufacturer has met all their requirements for CE marking.

With regards to the physical movement of goods into the UK, if the UK leaves the EU without a deal, then you will still need an Economic Operator Registration and Identification (EORI) number. However, you will need an EORI number that starts with GB. If you already have an EORI number that starts with GB, you can continue to use it. It will be 12 digits long. If you’re registered for VAT it will include your VAT registration number.

For more information on the transport of physical goods in the event of a No Deal Brexit, click here to visit the Government website. The types of information you will find includes details on:

– Obtaining an EORI number that starts with GB

– Customs Declarations and any financial support

– Specialist software to help with your planning

– Making declarations using transitional simplified procedures

– Import Tariffs in a No Deal Brexit – Currently, in the case of a No Deal Brexit there will be ZERO CUSTOMS DUTY for paper and wood products. You can look up the planned duty rate for your product code

Q7. Will there be a change to Custom Rules in a No Deal Brexit?

The HMRC has announced Transitional Simplified Procedures (TSP) for customs, should the UK leave the EU without a deal, by writing to 145,000 VAT registered businesses trading with the EU.

The purpose of TSP is to make importing easier for an initial period of one year to allow businesses time to prepare for usual import processes.

Once businesses are registered for TSP, they will be able to transport goods from the EU into the UK without having to make a full customs declaration at the border, and will be able to postpone paying any import duties.

Find out more by visiting the Government website – click here.

Q8. Accounting for import VAT on goods imported into the UK

The Government has issued a notice to inform UK businesses of the implications for VAT rules for goods and services traded between the UK and EU member states, in the event of a No Deal scenario. The notice (that can be accessed here) outlines the impacts and gives information for businesses to take into consideration.

It is proposed that 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.

Q9. Complying with the EU Timber Regulations in a No Deal Brexit

We advise all companies that import timber into the UK to look at the advice provides by the Timber Trade Federation – access this advice here.

To help BWF members easily interpret the proposed changes to the current CE Marking and Notified Bodies way of working in the event of a No Deal Brexit scenario, we have summarised key points in the table below.

Click here to download the PDF

More on Brexit

Visit the Construction Products Association website to find out more on Brexit.

More on Brexit
Member of Construction Products AssociationNational Specialist Contractors CouncilPassive Fire Protection FederationCITBTrade Association ForumThe Alliance for Sustainable Building ProductsConfederation of Timber Industries