@4_bathrooms wrote:
@ojewellery wrote:
When the Windsor Framework is introduced goods being moved to NI will have to be shipped by TSS registered traders and TSS registered couriers.
The couriers will handle the bulk of paperwork/ submissions to TSS. Traders will have to complete some form of contents information digitally to couriers including their TSS number and will require to be registered with TSS to show UK operations and business goods movement falls under the Windsor Framework.
Entry Summary Declarations will be required for all goods under Windsor Framework - see below. These will most frequently for online sellers like ourselves using carriers, be carrier completed.
The role of the TSS is to submit an entry summary declaration (ENS) which is a relatively short form. Royal Mail, parcel couriers and most hauliers will be making the declaration using information supplied to them by the trader. I can't see any reason a B2C retailer would also need to register with the TSS as they are not going to be able to provide any more information than the carrier already has.
I think carriers are unable to verify that UK business' are registered UK business'. Thats a required element of the Windsor framework. Chinese/ other country sellers can't use UK fulfilment as a way into NI/ EU via UK carriers. The trading business shipping to NI using TSS and the Windsor Framework needs to be UK registered hence have a UK gov TSS number.
@ojewellery wrote:
As NI is part of UK, goods shipped within the internal UK market are not subject to EU laws. Goods shipped under the Windsor Framework are acknowledged to be traded solely within the UK internal market.
No, that isn't correct. The Windsor Framework is intended to prevent a hard land border between Northern Ireland and the Republic (Eire). Part of the solution was to effectively leave Northern Ireland in the EU's customs union meaning goods sold in or to Northern Ireland must comply with EU harmonisation (including safety) legislation. The only products this doesn't apply to are those that fall under the remit of the Northern Ireland Retail Movement Scheme (NIRMS) which covers agri-food products.
The "green lane" allows goods to be sent to consumers in Northern Ireland with no customs checks, duties nor EU VAT being applied as these goods will not be deemed at risk of passing over the border. However, the green lane system does not preclude the GPSRs - eBay and all other online marketplaces will still be required to obtain the product compliance information required under those regulations.
The following is from: https://www.nicustomstradeacademy.co.uk/overview-of-windsor-framework/
I can't get my head around if we are declaring low checks on goods from not at risk categories the EU has any jurisdiction. Everything UK side I read implies that the TSS and UKIMS are all about keeping trade open between GB and NI.
This is also written in the NICTA (Northern Ireland Customs and Trade Accademy)FAQ on UKIMS (UK Internal Market Scheme):
This is closer to what @4_bathrooms talked about many moons ago when things were about as unclear as they are now!
If the TSS are our indirect customs representative solely for NI doesn't that circumvent the appointed person NI for GPSR for goods shipped solely to NI? If it does - I can't even work out if thats a stretch anymore, then for low risk products like our poster right at start of thread there aren't a lot of other things needed to meet the documentation requirements and trade can continue.
I'm now having the, prescribed by the TSS representative I spoke to this morning, glass of wine and sitting on the fence on registering for UKIMS.
@ojewellery wrote:
I think carriers are unable to verify that UK business' are registered UK business'. Thats a required element of the Windsor framework.
When a business sends goods to Northern Ireland they will be required to supply their (GB) EORI number to the carrier; that is how the carrier will confirm the sender is a business.
@ojewellery wrote:
Chinese/ other country sellers can't use UK fulfilment as a way into NI/ EU via UK carriers.
They can. The UK-established operator of the fulfilment house is obliged to register for VAT. As far as a carrier would be concerned the fulfilment house operator would be just another UK-established business.
@ojewellery wrote:The following is from: https://www.nicustomstradeacademy.co.uk/overview-of-windsor-framework/
I can't get my head around if we are declaring low checks on goods from not at risk categories the EU has any jurisdiction. Everything UK side I read implies that the TSS and UKIMS are all about keeping trade open between GB and NI.
The checks relate to goods not at risk of crossing the Irish border; they have nothing to do with EU product safety. The section that states "Goods being moved under the UK internal market system can do so on the basis of a reduced dataset with no requirement to submit a supplementary declaration and with no checks" is due to goods being moved for final sale to an NI consumer only requiring an entry summary declaration (ENS). Where a GB business ships something to an NI consumer the ENS will be completed by the carrier using the information given to them; there is no further information the GB business could supply.
The Northern Ireland Retail Movement Scheme (NIRMS) was introduced for the agri-food sector as it was realised that supermarkets (for example) could not legally import things like meat products, dairy products, fish, alcoholic beverages etc. into Northern Ireland as they would not meet EU requirements. Under the NIRMS agri-food products only have to comply with UK regulations; not those of the EU. That's why you will see prominent "NOT FOR EU" labelling on bulk supermarket packaging even in GB. Everything else (that isn't exempted by Annexe IX) is subject to the EU's GPSRs.
@ojewellery wrote:
If the TSS are our indirect customs representative solely for NI doesn't that circumvent the appointed person NI for GPSR for goods shipped solely to NI?
No, the TSS are only completing the ENS; they won't be anybody's responsible EU representative. As mentioned, all the "safety & security" information they have published relates only to the ENS which has nothing to do with the GPSRs.
