New NI Customs Requirement
Background
To meet the requirements of the Windsor Framework retailers moving goods from Great Britain to Northern Ireland will need to ensure they comply with a new customs declaration by 1 September 2025. Currently the requirement only applies to goods coming into Northern Ireland by air or directly by sea, this will mean all road and ferry transport will be covered in future.
What are the new requirements?
The EU has introduced a new system for safety and security declarations called the Import Control System 2 (ICS2). ICS2 requires enhanced declarations about products being carried which is submitted before departure port and a presentation of goods notification before the lorry leaves the port. If there is a problem with the form the goods can be rejected at the port. HMRC has shared some slides on operation of ICS2 which you can read here
What is the problem with ICS2?
The main problem is the level of detail and accuracy required in the initial declaration. The declaration requires 6 digit HS codes for all goods and accompanying descriptions. Too simplistic descriptions are not permitted, eg clothing is not sufficient it would need to be more specific eg mens’ shirts. This means multiple loads will require multiple, accurate codes and descriptions which will be a significant additional burden for typical, regular retail consignments.
There are also concerns that awareness of ICS2 is poor and hauliers may not be preparing for the change.
What are we doing about it?
We raised the issue with HMRC earlier this year as a concern and held a call for members with them in May. Members were able to explain the practical problems with the new requirements, concerns about awareness amongst hauliers and the need for more detailed, accurate guidance. We are also raising this with Government as another challenge to retailers operating in Northern Ireland as part of our ongoing lobbying to address the burdens of the Windsor Framework.
Next steps
HMRC has agreed to prepare and share more detailed guidance. It has also set out a communication plan to ensure all businesses, including hauliers, are aware of the requirements and understand how they can comply.
We will share new guidance when it is available. We also have our next regular meeting with HMRC on 3rd June where we will discuss updates and assess progress with their communication plan.
