Brexit – what are the implications for Swedish trade?

After Brexit, the UK is a non-EU country and the same customs rules apply as for other non-EU countries.

The UK is a non-EU country and when it comes to customs matters, the same rules apply as for other non-EU countries. The EU and the UK have a trade and cooperation agreement. Here you can read about what it means.

What does the Trade and Cooperation Agreement mean?

For customs purposes, the Agreement means that the UK is now treated as a non-EU country. In other words, the Union Customs Code is applied to trade with the United Kingdom and customs formalities therefore need to be completed, such as the submission of customs declarations for imports and exports. The Withdrawal Agreement is also applicable in this respect. This lays down, among other things, special provisions governing, for example, transport operations that started before but finish after the end of the transitional period on 31 December 2020.

According to the Trade and Cooperation Agreement, no customs duties are levied if the goods fulfil the conditions for being considered as originating goods under the Agreement and this can be confirmed. The proof of origin to be used is a statement on origin written on an invoice or on another document describing the goods in sufficient detail to enable them to be identified.

You need a REX number

Companies exporting originating goods from the EU need to apply to become a registered exporter (REX) and obtain a REX number in order to make out statements on origin for consignments to the UK if the value of the goods is above the threshold of EUR 6,000.

If you have already registered your company in order to export originating goods to Japan, for example, you do not need to register again.

Ensure the origin of the goods

Before you make out a statement on origin for your goods, you need to ensure that they meet the criteria for being originating goods under the Agreement. The chapter concerning rules of origin can be found on pages 40–55 of the Agreement and the product-specific rules are on page 440–495. You can see how the statement on origin should be worded on page 507–508.

If you are unable to make out a statement on origin at the time of export, you can do this afterwards. Under the Agreement, preferential treatment can be requested up to three years after the date of importation.

Mutual recognition agreement (MRA)

The EU and the UK have signed a mutual recognition agreement under which each party recognises the status of any entity that has an authorised economic operator (AEO) authorisation. There will be more information about this at a later date.