Experiences of traders moving goods between Great Britain and Northern Ireland: Full report

Question 1

Glossary of terms

Accepted Answer

Term	Definition
At risk goods	Goods moving from Great Britain to Northern Ireland that are ‘at risk’ of onward movement to the EU (in the context of this report, movement from Northern Ireland to Ireland is most relevant). ‘At risk’ goods will be charged the applicable EU duty.
Drop shipping	A shipping method whereby a retailer buys products to sell to customers from a third-party seller, but that third-party seller retains responsibility for shipping that item.
Entry Summary Declarations	A declaration made to UK customs by the business moving goods from Great Britain to Northern Ireland, containing information on the nature of the goods. The legal requirement to submit an Entry Summary Declarations declaration lies with the operator of the active means of transport (for example, the vessel, aircraft, train or road vehicle) on or in which the goods are brought into the customs territory (for example, Great Britain or Northern Ireland).
Great Britain land bridge	Refers to any route that goods travel from the island of Ireland to the rest of the EU and vice versa, via mainland Great Britain.
Grace periods	The UK Government has agreed a number of grace periods with the EU – for example, in relation to movements of food products such as chilled meats - during which the requirements under the Northern Ireland Protocol will not apply. HMRC has also adopted a temporary approach to applying declaration requirements for the movement of goods in parcels (including by the Royal Mail Group and express carriers), where in almost all cases, goods sent to consumers and businesses in Northern Ireland will not require a customs declaration for the duration of the current arrangements.
Northern Ireland Protocol	The Northern Ireland Protocol’s core objectives are to minimise disruption to everyday lives, respect Northern Ireland’s integral place in the UK’s internal market, preserve the delicate balance in the (Belfast) Good Friday Agreement in all its dimensions – East to West as well as North to South. In respect of customs processes it sets out the requirements for moving goods between Great Britain and Northern Ireland at the end of the transition period on 31 December 2020.
Supplementary declarations	A declaration made to UK customs after a movement of goods from Great Britain to Northern Ireland with full information on a shipment, all of which may not have been known before moving goods.
Tariffs	A tax or duty to be paid on a particular commodity at import.
Trader Support Service	A free service which has been set up to support businesses moving goods between Great Britain and Northern Ireland following the end of the transition period on 31 December 2020. The Trader Support Service can guide businesses through the changes and requirements and can submit declarations on their behalf.
UK Trader Scheme	Traders who want to declare their goods ‘not at risk’ and the EU tariff rate on these goods is above zero, can apply for authorisation under the UK Trader Scheme. ‘Not at risk’ goods will be charged either: no duty if entering Northern Ireland from free circulation in Great Britain; UK duty if entering Northern Ireland from outside of both the EU and the UK; or UK duty if entering Northern Ireland from Great Britain and the goods were not in free circulation in Great Britain.
XI EORI number	An EORI number is provided by HM Revenue and Customs for businesses who move goods into Northern Ireland from Great Britain or move goods to between Northern Ireland and a non-EU country, where an EU EORI is not already held. The ‘XI’ prefix is used to identify Northern Ireland for customs purposes.

Question 2

1.  Executive Summary

Accepted Answer

The UK left the EU on 31 January 2020 and entered a transition period which lasted until 31 December 2020. From 1 January 2021, the Northern Ireland Protocol took effect, which established special provisions for moving goods between Great Britain and Northern Ireland, including the need for businesses to submit different declarations when moving goods into Northern Ireland from Great Britain.

HM Revenue and Customs (HMRC) commissioned Verian (formerly Kantar Public) to undertake qualitative research to provide insight into levels of understanding and preparedness for the implementation of the Northern Ireland Protocol amongst Great Britain-based small and mid-sized businesses. The research also explored their experiences of moving goods to Northern Ireland following the end of the transition period.

A total of 45 in-depth interviews were undertaken with Great Britain-based businesses moving goods to Northern Ireland between March and June 2021. In addition, 10 in-depth interviews were undertaken with Northern Ireland-based businesses bringing goods into Northern Ireland from Great Britain, to obtain insight into their experiences and perspectives.

To support businesses moving goods between Great Britain and Northern Ireland, HMRC has introduced the Trader Support Service. This is a free service which guides businesses through the changes and requirements and can submit declarations on their behalf without them needing to engage directly with HMRC systems.

Interviews were conducted with a mix of businesses who had used the Trader Support Service to move goods (Trader Support Service users), who had registered for the Trader Support Service but not used it to move goods (Trader Support Service non-users), as well as businesses who had not registered for the Trader Support Service (not registered for Trader Support Service). More information about sampling and recruitment approaches can be found in Section 2.

Please note that findings from qualitative research are used to gain in-depth insight into businesses’ experiences of moving goods from Great Britain to Northern Ireland; but cannot be used for statistical analysis or to generalise to the overall target population. Further, the views of participants willing to take part in research may differ from those of other businesses.

The research took place between March and June 2021 and aimed to understand the trading behaviour of businesses’ taking part in the research prior to 1 January 2021, as well as their awareness of and preparedness for the changes that would be introduced from 1 January 2021.

It explored businesses’ experiences of trading in the immediate months following the end of the Brexit transition period, including their reflections on the Trader Support Service, as well as any plans for changes to their trading behaviour in the future. It also aimed to understand the impact of communications and guidance issued by the Government and the Trader Support Service, as well as further support and information needs.

1.1 Awareness and attitudes prior to 1 January 2021

Awareness of the new Northern Ireland trading processes was shaped, in large part, by the coverage of the political discussions being held in the media. The businesses we spoke to commonly reported that these discussions drove the expectation amongst traders that processes and requirements would not change significantly for trade between Great Britain and Northern Ireland after the end of the transition period.

Simultaneously, however, businesses reported they were also receiving government communications around changes that may be introduced in 2021 for Great Britain-Northern Ireland trade.

The lack of clarity and clear guidance for businesses taking part in the research about what would happen drove a level of uncertainty amongst traders. Thus, the lead-up to January 2021 was characterised by a sense of confusion and anxiety for traders in Great Britain and Northern Ireland.

1.2 Preparedness for the new trading requirements

There were varying levels of awareness of the new requirements amongst the Great Britain and Northern Ireland-based traders in the sample. Some were more engaged and proactively looked for information while others were more disengaged. As a result, there were groups with different levels of awareness ranging from no awareness of any of the new requirements to higher levels of awareness of what would be required.

The different levels of awareness were also associated with varying levels of preparation and thus confidence amongst traders in their ability to trade after 1 January 2021. The more disengaged businesses interviewed took no action and waited to see what would happen, frequently leading to a lack of confidence about their Great Britain-Northern Ireland trade in the future.

However, many other participants had commonly undertaken some preparations, such as obtaining an XI EORI number, where this was required, and registering for Trader Support Service. They therefore felt some level of confidence in their preparedness.

Further, some businesses interviewed had undertaken more detailed preparations, such as changing their invoicing systems and checking for tariff implications, and consequently felt very confident that they were ready to trade after the end of the transition period.

Many participants interviewed had completed their Trader Support Service registration towards the end of 2020, but it should be noted that 45 out of the 55 interviews were sourced from Trader Support Service registration data. More detail about these groups and examples are provided in Section 3.

The key sources of information that businesses taking part in the research said they referred to in order to prepare for the change in Great Britain-Northern Ireland trading requirements included: GOV.UK, the Trader Support Service Northern Ireland Customs and Trade Academy website, guidance from industry bodies (such as the Road Haulage Association), and the media.

1.3 Businesses’ experiences of the new trading requirements

After 1 January 2021, many businesses in the sample reported feeling surprise and frustration at the scale of the changes required to move goods from Great Britain to Northern Ireland.

From the initial weeks after the changes, there were reports of delayed deliveries, increases in administration time required to prepare to move goods from Great Britain to Northern Ireland, and increased costs of transportation to Northern Ireland due to price increases from intermediaries. Some of these were seen as teething issues, but businesses reported they continued to experience some ongoing challenges (see Section 4).

Trader Support Service users and non-users or non-registered businesses reported having different experiences when moving goods from Great Britain to Northern Ireland. For the Trader Support Service users that we spoke to, many referred to a lack of clarity on exact requirements for declarations and the increased burden of paperwork when it came to Entry Summary Declarations declarations, but they tended to know less about the requirements for supplementary declarations.

While these issues were promptly resolved for some businesses, those using hauliers to transport goods and dealing in multiple product categories or complex products (such as those with multiple components) continued to find the declarations a challenge. Those who contacted the Trader Support Service help centre for assistance recalled that they were able to help with straightforward queries such as filling out forms but struggled with more specific or technical queries.

The businesses that had not used or registered for Trader Support Service that were interviewed also experienced some lack of clarity on requirements for moving goods from Great Britain to Northern Ireland in the initial few weeks. However, since many businesses in this group reported that they had used Royal Mail or other couriers, or had relied on intermediaries to submit declarations for their goods movements, they reported not getting involved in the detail of it.

Thus, despite their initial lack of clarity on the requirements, many Trader Support Service non-users and non-registered businesses found the experience of trading with Northern Ireland in 2021 to be relatively straightforward.

However, it should be noted that HMRC has adopted a temporary approach to applying declaration requirements to the movement of goods in parcels. This means that, in almost all cases, goods sent to consumers in Northern Ireland will not require a customs declaration and this approach may have contributed to the ease experienced with moving goods. In addition, the lack of understanding of the requirements and reliance on intermediaries has continued for many of the businesses that participated in the research.

With the exception of some who had experience in importing and exporting goods between EU and rest of the world countries, most businesses we interviewed expressed a lack of clarity on the tariff implications that the Northern Ireland Protocol would have on their Great Britain-Northern Ireland trade.

Amongst businesses that expressed a lack of clarity on tariff implications, there were questions around whether and when tariffs would be payable by them. Some of these businesses reported difficulties in finding information on the Trader Support Service and HMRC websites about tariffs. Awareness of the concept of ‘goods at risk’ was also limited, with many businesses in the sample unclear about how it would work and the situations in which it would apply.

However, those that had some awareness of the tariff implications assumed that their business or industry sector would not be affected. This was on the basis of their experience of trading with other EU countries where their goods did not attract any tariffs or their knowledge of the World Trade Organisation rules. Some also assumed that it was their Northern Ireland-based customers’ responsibility.

A very small number of the businesses interviewed were also aware of initiatives such as the UK Trader Scheme and had registered for it. No other specific schemes were mentioned.

In terms of the impact of the new requirements on levels of Great Britain-Northern Ireland trade in the first half of 2021, on the Northern Ireland side, a few of the businesses in the sample reported a decline in their Great Britain trade. They reported that some of their partners in Great Britain were not willing to trade with Northern Ireland-based businesses on account of the increase in administrative burden and paperwork. Some businesses in Great Britain also reported that the new requirements had impacted their orders from Northern Ireland and they had witnessed a decline. Some food businesses in Great Britain in the sample were particularly impacted by courier companies not transporting food to Northern Ireland as a result of the changes.

1.4 Looking to the future

Although many of the Great Britain businesses that took part in the research felt that their future trading plans with Northern Ireland were uncertain, few of these businesses reported feeling anxious about their Northern Ireland trade. This is reflected in the fact that most Great Britain and Northern Ireland businesses interviewed did not have any concrete plans for change at the time of fieldwork. However, some were exploring options such as increasing stocking capacity in Northern Ireland and finding alternative trading routes to bypass the Great Britain land bridge.

A small number of both Great Britain and Northern Ireland businesses in the sample also mentioned considering a reduction in their Great Britain-Northern Ireland trade over the longer term as a result of the changes.

In terms of their information needs, the businesses we spoke to reported an ongoing need for clear information on processes at a high level, but also more detailed and technical information specific to their industry or sector. Most expected that this information would be made available to them by HMRC via direct letters or emails.

Question 3

2. Introduction

Accepted Answer

2.1 Background

The UK left the EU on 31 January 2020 and entered into a transition period which lasted until 31 December 2020. From 1 January 2021, the Northern Ireland Protocol took effect, which established special provisions for moving goods between Great Britain and Northern Ireland, including the need for businesses to submit different declarations when moving goods from Great Britain into Northern Ireland.

The Northern Ireland Protocol’s core objectives are to minimise disruption to everyday lives, respect Northern Ireland’s integral place in the UK’s internal market, preserve the delicate balance in the (Belfast) Good Friday Agreement in all its dimensions (East to West as well as North to South). In respect of customs processes, it sets out the requirements for moving goods between Great Britain and Northern Ireland at the end of the transition period on 31 December 2020.

Since the research was conducted, the Command Paper ‘Northern Ireland Protocol: The way forward’ was published in July 2021 and provides new details of the UK’s proposed approach on the Protocol in light of the experiences of traders since the end of the transition period.

To support businesses moving goods between Great Britain and Northern Ireland, HMRC has set up the Trader Support Service. This is a free service which guides businesses through the new requirements for moving goods between Great Britain and Northern Ireland and it can submit declarations on their behalf. Businesses need to register to use the service, but they are not obliged to use it.

2.2 Research Aims

The research aimed to provide insight into levels of understanding and preparedness for the implementation of the Northern Ireland Protocol amongst Great Britain-based small and mid-sized businesses, as well as their experiences of moving goods to Northern Ireland following the end of the transition period. A small number of interviews were also undertaken with Northern Ireland-based businesses who move goods from Great Britain, as a secondary audience for the research.

Specifically, the research aimed to:

understand awareness of and preparedness for changes post 1 January 2021 among Great Britain businesses moving goods to Northern Ireland (and Northern Ireland-Great Britain traders)
explore experiences of trading after the end of the transition period, from 1 January 2021
where businesses had used the Trader Support Service, to understand their experiences of doing so
where businesses had not used the Trader Support Service, to understand how businesses had gone about moving goods, and why had they decided not to use the Trader Support Service
understand and explore businesses’ views on communications and guidance provided by HMRC on GOV.UK and via Trader Support Service, as well as other sources of information and support
explore any potential changes to future trading arrangements under consideration and businesses’ ongoing information needs

2.3 Method and sample

A qualitative approach was used to gain in-depth insight into businesses’ experiences of moving goods from Great Britain to Northern Ireland. Qualitative research is the process of gathering non-numeric information from sources (in this case businesses) in order to understand views or experiences around a certain topic. Qualitative findings cannot be used for statistical analysis and cannot be generalised to the overall target population. Please also note that the views of participants willing to take part in research may differ from those of other businesses.

The findings are based on 55 one-hour telephone interviews completed with businesses who had moved goods between Great Britain and Northern Ireland since 1 January 2021 (45 Great Britain traders and 10 Northern Ireland traders). The 3 categories of businesses interviewed were:

those who had used a Trader Support Service to move goods: 27 businesses
those who had registered for a Trader Support Service and used it for information and guidance but not to move goods: 18 businesses
those who had not registered for Trader Support Service and thus had not used it for information and guidance or to move goods: 10 businesses

Fieldwork was undertaken between 29 March and 14 June 2021; with a pause between 14 April and 6 May (25 March and 6 May for Wales and Scotland sample) to accommodate the pre-election period.

Table 1 – Achieved sample

Sample recruitment	Trader Support Service: users	Trader Support Service: non-users	Trader Support Service: not registered
Great Britain businesses	23	13	9
Northern Ireland businesses	4	5	1
Total	27	18	10

The Trader Support Service users and non-users were recruited from a sample of Trader Support Service registrations data provided by HMRC. This data was matched to the VAT mainframe, so all businesses in this sample were VAT registered. To capture the experiences of those who had not registered for Trader Support Service or used it to move goods, 10 businesses who had not registered for Trader Support Service were recruited with a free-find method using a business panel.

Businesses were selected to include a range of business sizes, sectors, regions, trading patterns, and frequency of trade with Northern Ireland in the sample. This ensured that a broad range of experiences were captured. More detail on the sample can be found in the Appendix 1 of this report.

Question 4

3.  Great Britain to Northern Ireland traders’ understanding of and preparations for the implementation of the Northern Ireland Protocol

Accepted Answer

This section explores:

Great Britain based businesses’ levels of awareness of the Northern Ireland Protocol and their understanding of the changes
what preparations businesses made before 1 January 2020 in order to trade under the requirements of the Northern Ireland Protocol
what sources of information and support businesses consulted to prepare for the changes

3.1 Great Britain to Northern Ireland trading patterns pre-2021

Overall, businesses that participated in the research reported that moving goods between Great Britain and Northern Ireland before 1 January 2021 had been a straightforward process with no issues. Sending goods to Northern Ireland was seen as exactly the same as sending them to anywhere else in the UK and there was no paperwork to complete.

Our process for exporting to Northern Ireland was the same as sending to Birmingham or London.

(Great Britain business, small business, manufacturing, Trader Support Service non-user)

In terms of the transportation of goods, most businesses interviewed said they used a courier or haulier to manage this, and it was also commonly left to them to decide the most efficient way to move the goods.

The type of transportation or intermediary used sometimes depended on the nature of the goods, especially their size: for example, large shipments of multiple units would use a pallet network, whereas it sometimes was more cost efficient to send smaller packages directly through Royal Mail. Businesses based in Northern Ireland were not usually involved in the transportation process, with this being the responsibility of the supplier.

3.2 Business awareness of and attitudes to the changes before 2021

The primary underlying expectation across businesses in the sample from Great Britain and Northern Ireland was that the requirements for trade between Great Britain and Northern Ireland would not change significantly, if at all, because Northern Ireland remains a part of the UK.

I think we all thought, because [Northern Ireland is] part of the UK there’d be some kind of simplified process

(Great Britain business, mid-sized business, professional and scientific activities, Trader Support Service user)

However, prior to 1 January 2021, awareness of the changes in requirements varied, and businesses interviewed could be categorised into four groups, which are outlined below. Most businesses interviewed fell into the ‘basic awareness’ category.

3.2.1 No awareness

These businesses assumed that trade between Great Britain and Northern Ireland would not change at all. Because of this, businesses ignored communications from HMRC and others (for example, other government departments, trade bodies, intermediaries), assuming that it was not relevant to them. Some businesses, whilst not deliberately ignoring the plans for the Northern Ireland Protocol, were more focused on preparing for trade with the EU, which was a much more important part of their business model.

3.2.2 Basic awareness

These businesses had some knowledge of requirements such as the benefit of obtaining an XI EORI number, where required, and the existence of the Trader Support Service. However, they were dismissive of other changes (for example, in relation to the need to make declarations and specify commodity codes) thinking that these wouldn’t apply to them.

This was often because they assumed they would only be required for larger businesses or because they didn’t want to invest time in familiarising themselves with regulations that they perceived to be constantly changing.

3.2.3 Moderate awareness

These businesses were aware of key requirements, such as the need to submit declarations, but had no in-depth knowledge on how they would work in practice. Like businesses with basic awareness, they were reluctant to spend a significant amount of time learning about changes that they perceived were not yet finalised.

3.2.4 High awareness

These businesses reported stronger levels of awareness and understanding of the changes, including understanding requirements relating to tariffs and commercial invoices. They reported feeling clear on what action they needed to take to prepare, and they therefore tended to have had lower levels of anxiety. Whilst there were no themes across size and sector, the higher levels of awareness in this group were often driven by previous export or import experience and knowledge or access to external expertise.

3.2.5 Areas of confusion

For Northern Ireland businesses, there were a few specific areas of confusion and worry at this stage:

there was an assumption that their Great Britain partners would need to make more changes than they would
there was a lack of clarity around how responsibilities would fall between their Great Britain partners and themselves
there was an underlying sense of nervousness about the impact of the changes on their Great Britain partner and what this might mean for their trading patterns

There were no clear links between the size or type of businesses and the levels of awareness. Rather, the key factors were the attitudes of the people within the business who had control of the trading process, and the internal structures and processes in place (for example, whether they had good internal communications and specialist members of staff).

3.3 Preparedness for the new trading requirements

In terms of action taken by businesses, there was a spectrum of levels of preparedness, shown by the four categories below. The preparedness level was largely driven by awareness, reported across the Great Britain and Northern Ireland traders in the sample.

‘No action businesses’ assumed there would be no changes in requirements or didn’t want the hassle or cost of preparing for changes which were not yet finalised. Therefore, they did not make changes before 1 January 2021.

‘Some action businesses’ obtained an XI EORI number, where required, to facilitate trading with Northern Ireland and some also accessed training guidance on the Northern Ireland Protocol.

‘Sector-specific action businesses’ made specific changes required by the sector they operate in. In one example, food and drink businesses made sure they were aware of new phytosanitary rules. In another example, businesses supplying goods to large, national retailers were informed by their buyer what protocols they needed to follow so as not to affect supply and negatively impact the buyer’s reputation.

‘High level of action businesses’ reported making all the preparations they could, such as checking tariff implications, obtaining commodity codes and making changes to invoicing systems. This was often driven by trying to be as prepared as possible for all eventualities before a trade deal was finalised at the end of 2020.

At the end of 2020, businesses across the sample felt quite differently about their ability to meet the new trading requirements with Northern Ireland and had varying levels of confidence. As with awareness, while no strong patterns emerged in the profile of organisations at different action or confidence levels, internal business structure and the attitude of the person leading the trade process appeared to be driving factors.

If the individuals tended to be proactive and organised it was more likely that the business had taken action to prepare, and therefore they were more confident. However, it should also be noted that confidence did not always necessarily correlate with preparation. For example, some businesses, often with lower levels of awareness, reported having a high level of confidence, until they actually came to moving goods and realised they were not as prepared as they thought.

Businesses that were more familiar with exporting and importing as a result of their existing international trade tended to be more aware of requirements, but the level of preparation (and thus confidence) varied. Some businesses ‘piggy-backed’ on their preparations for trade with the EU after 31 December 2020 and made preparations for trade with Northern Ireland at the same time.

On the other hand, other businesses deprioritised Northern Ireland trade, as business with the EU was more important to their business model and they wanted to focus solely or more on that.

3.3.1 Discussions with trading partners

As part of their preparation, some businesses interviewed reported having discussions with their trading partners, but this was mainly to exchange information (especially to make them aware of the benefit of obtaining an XI EORI number where required) rather than plan in detail for 2021. Businesses who got in touch with their trading partners before 1 January 2021 were usually those for whom Northern Ireland was a key part of their business model or had a more established relationship with their trading partner.

Where relationships with trading partners were not so well established, businesses did not consider discussing trade post-31 December 2020 with them.

We had no discussions with hauliers and customers beforehand – we may have underestimated the need for going to them in order to prepare.

(Great Britain business, micro business, rental and manufacturing, Trader Support Service non-user)

3.4 Barriers to taking action

Businesses in the sample reported a range of barriers to taking action to prepare before 1 January 2021. Some businesses wrongly expected there to be no changes, and therefore did not take any action. Other businesses said they were confused by guidance that they felt was shifting. Final requirements were not confirmed until the final week of 2020, and some businesses were reluctant to commit a significant amount of time preparing before they knew exactly what they had to prepare for.

Some businesses found that the guidance was not relevant to their business size or trading patterns. They found it difficult to adapt guidance to their situation (for example, if goods were imported into Northern Ireland from the EU via the Great Britain land bridge, or if customers were individuals rather than businesses.) Many businesses were busy with preparations for changes to EU trade and prioritised this over preparing for trade with Northern Ireland.

3.4.1 Gathering information about changes

Businesses interviewed reported gaining information about the upcoming changes to trade between Great Britain and Northern Ireland from a variety of sources. Government sources, such as emails from HMRC and the GOV.UK website, as well as the Trader Support Service portal and Northern Ireland Customs and Trade Academy website, were seen as reputable and useful sources of information. However, businesses also expressed frustration at the volume of information they had to sift through.

Some found the GOV.UK website was hard to navigate, with several layers of links proving particularly challenging. Some participants felt that a lot of the guidance was too long and unwieldy and thus difficult to engage with. Some of the smaller businesses felt that the information they received from HMRC or Trader Support Service had limited relevance to them and their trading situation and that it was geared towards larger businesses.

There was also discontentment across the sample about the lateness of confirmed changes, as final agreement was only reached at the end of 2020, a week before the changes came in on 1 January 2021.

Businesses in the sample also mentioned obtaining information from their industry networks, such as customs agents, their local Chamber of Commerce, or their buyer. While these agents were useful for getting information which was customised to their sector, they were not always updated with all current information, and this was especially the case with some intermediaries.

Question 5

4.  Great Britain to Northern Ireland traders’ initial and on-going experiences of moving goods in 2021

Accepted Answer

This section explores:

the initial challenges experienced by Great Britain based traders moving goods to Northern Ireland at the beginning of 2021
the key themes that emerged regarding traders’ overall experiences of trading under the new arrangements in 2021

4.1 Initial experiences of moving goods in 2021

Overall, a high degree of frustration was expressed by businesses interviewed about their experience of moving goods to Northern Ireland in the first few weeks of 2021, following the introduction of the new requirements. The following key themes were reported by businesses across the sample.

4.1.1 An increase in the administrative burden

This was caused by the increase in paperwork required, as well as the general uncertainty around what was required and how to get the right information. These were key points of frustration for many businesses interviewed. This led to an increase in the time required to be spent on Northern Ireland orders. This frustration continued beyond the initial weeks for many businesses.

The first shipment was difficult. The need for more information was an unpleasant surprise. Went on to the parcel operator’s website to book a delivery but it asked for new information, needed three copies of an export invoice. I was blindsided and had to get the information very quickly. I was chasing my tail to get it.

(Great Britain business, micro business, wholesale and retail, not registered for Trader Support Service)

Northern Ireland based businesses echoed similar frustrations with paperwork requirements and reported challenges with documentation received from their Great Britain trading partners, where information provided was inaccurate or incomplete. Examples of this included forms without XI EORI numbers, where these were required, and the inclusion of incorrect commodity codes.

The first order in 2021 had many problems…our Great Britain supplier had problems obtaining the consignment number/product code attached to the delivery. Our individual customers receiving goods in Northern Ireland did not have their own EORI numbers so had to use our EORI number.

(Northern Ireland business, micro business, manufacturing, Trader Support Service user)

4.1.2 Delays in shipments through hauliers and couriers

Delays in shipments through hauliers and couriers in this period caused frustration for many Great Britain and Northern Ireland businesses in the sample. Northern Ireland based businesses also reported cancelled orders during this period. These delays and cancellations were reported to have been caused by courier companies shutting down operations in the first few weeks of January to deal with the paperwork requirements, and slower than usual processes as intermediaries got to grips with the new requirements which caused delays at ports.

We had some delays in delivery in the first few weeks. The account manager at our parcel operator said slower deliveries were due to what was described as ‘teething problems.

(Great Britain business, small business, wholesale and retail trade, Trader Support Service non-user)

Whilst some of these issues were described as teething issues and resolved themselves as traders became more experienced, others persisted and continued to present challenges. This is discussed in the section below.

4.2 Common themes defining the experience of moving goods to Northern Ireland

Beyond the initial teething issues reported in the first few weeks of January 2021, there were some broader and ongoing challenges faced by Great Britain and Northern Ireland traders that help us to understand their overall experience.

4.2.1 Sense of surprise at changes

There was a widespread sense of surprise and frustration underlying the way Great Britain and Northern Ireland traders felt about the new requirements and processes. Many had expected there would be no significant changes. Thus, when faced with the new requirements, there was disbelief at the scale of change and frustration that trading with Northern Ireland was now like trading with an international destination.

4.2.2 Issues with administrative burden and lack of clarity

Businesses across the sample also reported that they continued to experience an increased administrative burden caused by additional paperwork. As a result, they were spending increased amounts of time on their trade with Northern Ireland.

There was a continued lack of clarity around new requirements (beyond the initial few weeks) and many Great Britain and Northern Ireland businesses continued to feel unsure about the new requirements well into 2021. Even businesses that had more experience in imports and exports through their trade with EU and rest of the world countries and those that had felt confident in 2020 found adjusting to the new requirements challenging.

Our experience in trading across the rest of the world made it easy to understand tariff regimes and be aware of the sorts of information necessary for declarations. However, we have found that the changes related to trading with Europe after Brexit have been easier than with Northern Ireland as we knew what to expect in terms of Europe due to experience with declarations for the rest of the world. With Northern Ireland it wasn’t clear because of a lack of timely information around specific declaration requirements.

(Great Britain business, mid-sized business, manufacturing, Trader Support Service user)

This uncertainty around the new requirements also led to a certain level of apprehension around Northern Ireland orders, amongst both smaller and larger businesses, as there was lack of clarity on whether they were doing the right thing or not.

[…]We ship to Northern Ireland and I just feel stress because I don’t know if I’m fulfilling my legal obligations with regard to the paperwork.

(Great Britain business, micro business, manufacturing, Trader Support Service Non-user)

There was a lack of flexibility caused by an increase in paperwork. Some Great Britain participants felt their ability to respond quickly to Northern Ireland orders, as they had done in the past, was restricted because of the paperwork.

We are finding a little bit of frustration because it’s taken away flexibility for us for shipping consignments. In the past could respond to customer orders straight away and send out items if in stock. Now it’s more difficult as you have to get the paperwork into the transport company, the whole process introduces more delay.

(Great Britain business, small business, manufacturing, not registered for Trader Support Service)

4.2.3 Issues with pallets, increased transport costs, and a decline in trade

While most businesses interviewed found the process of arranging transport remained largely the same, some faced challenges in arranging the shipment of pallets. Businesses reported finding the process of arranging smaller shipments and movement of packages to be straightforward. However, they reported issues with finding hauliers to transport pallets, especially those with multiple products.

Driven by the complexity of providing information (such as commodity codes) for multiple products on a single pallet, some hauliers had stopped shipping to Northern Ireland or were only taking shipments with a single product.

We continued to use DHL for smaller packages/parcels but for pallets we had to find another haulier because the previous pallet haulier stopped Northern Ireland service after Jan 2021. So have to use a broker who finds a haulier.

(Great Britain business, small business, manufacturing, Trader Support Service non-user)

Most participants noted a rise in transport costs because hauliers and couriers increased their shipment rates for moving goods from Great Britain to Northern Ireland in 2021, because of the additional paperwork requirements. The challenge associated with finding hauliers to transport pallets, as detailed above, also led to an increase in costs for pallet shipments.

Additionally, some Great Britain businesses in the sample found that they now needed to split the ‘at risk’ goods and those not ‘at risk’ into different pallets, which increased costs because of the increase in pallets shipped. Most participants were unwilling to pass these increased costs on to their customers and were frustrated at the impact on their business profitability.

It’s annoying. It has definitely increased costs associated with shipping to Northern Ireland customers. Don’t want to discriminate against Northern Ireland customers by increasing postage costs, but it does reduce profit margins for sales to Northern Ireland versus Great Britain.

(Great Britain business, micro business, wholesale and retail, Trader Support Service non-user)

Some participants reported a decline in their trade between Great Britain and Northern Ireland, both during the initial teething period and afterwards, because of the increased administrative burden and delays in deliveries. Some Northern Ireland traders reported their Great Britain partners were not taking their orders on account of the new requirements. They felt this was because the size of the Northern Ireland trade was not significant enough for the Great Britain supplier to warrant the extra time and effort associated with the trading requirements.

Some Great Britain businesses also reported a decline in their Northern Ireland orders because of the increased burden on their customers. Some Great Britain-based food businesses also faced a decline in business because courier companies had started refusing to move food products.

Since 2021 have seen shipments to Northern Ireland reduce from 10 times per month to 5 times per month. Customers are struggling to deal with systems for inputting information and shipments are encountering delays and difficulties.

(Great Britain business, small business, professional, scientific and technical activity, Trader Support Service user)

We stopped selling to Northern Ireland customers via the site as couriers won’t take food. Fewer shipments than before, 20% to 30%.

(Great Britain business, mid-sized business, manufacturing, Trader Support Service user)

Some suppliers now refuse to take orders… for example, nuts from Argentina that I bought from a […] supplier for 20 years but he didn’t want to do Entry Summary Declarations and so on; we now get the same product from Poland. Our business wasn’t big enough for them to worry about.

(Northern Ireland business, small business, manufacturing, Trader Support Service user)

Question 6

5.  ‘Trader Support Service user’ experiences of the new trading requirements

Accepted Answer

This section explores:

businesses’ experiences of registering for Trader Support Service and receiving support from the Trader Support Service service helpline
businesses’ experiences of declarations, tariffs and arranging transport

5.1 Experiences of using the Trader Support Service (Trader Support Service)

5.1.1 Trader Support Service registration

Businesses that participated in the research reported four key drivers for Trader Support Service registration. Firstly, as Trader Support Service is a Government initiative, it was seen as a good place to obtain credible information on the Northern Ireland Protocol requirements. Secondly, businesses were driven to register for Trader Support Service and make use of its automated systems to ensure a smooth trading process and avoid challenges once the new Northern Ireland arrangements were in place.

Thirdly, some businesses in the sample incorrectly believed that Trader Support Service registration was required in order to obtain an XI EORI number, so assumed that they had no choice but to register. In the same vein, some businesses were told by their trading partners or transport agents that they had to register for Trader Support Service to be able to continue trading.

We needed a source of information about what changes were being made and also to look at whatever training was needed.

(Northern Ireland business, micro business, manufacturing, Trader Support Service User)

I thought it would ease any situation because we were registered with Trader Support Service…effectively it would be business as normal.

(Northern Ireland business, mid-sized business, other service activities, Trader Support Service user)

In general, the Trader Support Service registration process was found to be very simple and worked smoothly for most businesses interviewed. Some reported certain specific issues, such as details not being recognised, the website being temporarily unavailable, and difficulties adding more than one person to an account. However, these problems were generally quickly resolved, either unaided or by contacting the Trader Support Service help centre.

5.1.2 Experience of the Trader Support Service service helpline

Trader Support Service users in the sample who had interacted with the helpline commonly had positive feedback on the level of support they received. The proactive and supportive approach was appreciated by many users.

I contacted the help centre for help with filling in supplementary declarations. Person I spoke to was very helpful and provided me with a lot of documents to read through and talked me through what I’d done wrong so far.

(Great Britain business, small business, wholesale and retail trade, Trader Support Service user)

However, some participants, mainly those who had had queries of a more technical nature, (for example, on commodity codes, tariffs specific to trading patterns) felt that the assistance or advice they received was not adequate. Either it didn’t help them resolve the issues or it took multiple rounds of calls and emails before it was resolved.

Trader Support Service isn’t particularly useful in determining specific information for bespoke, custom items. They tend to provide information at a more generic level.

(Great Britain business, mid-sized business, healthcare, Trader Support Service User)

Some participants, who had had multiple interactions with the helpline, felt that their experience was inconsistent. At times they had managed to speak to service staff who were knowledgeable and at other times, there were gaps in knowledge and information which was not helpful.

I was unable to solve the problems with supplementary declarations through the Trader Support Service Contact Centre. No consistency of help or level of knowledge or experience from Trader Support Service staff. It was variable and unreliable.

(Northern Ireland business, mid-sized business, other service activities, Trader Support Service user)

5.2 Experience with declarations, tariffs and arranging transport

The research focused on understanding how businesses experienced key elements of the process of moving goods between Great Britain and Northern Ireland. Thus, the focus of the interviews was on:

making Entry Summary Declarations via Trader Support Service
transporting goods
managing tariffs
making supplementary declarations

5.2.1 Entry Summary declarations

Although awareness of Entry Summary Declaration requirements was very high amongst Trader Support Service users after January 2021, many businesses interviewed encountered problems at this stage of the process. Some businesses were unclear on the information they were required to include and struggled to obtain the information as they were unclear where to find it. Required information that businesses found difficult included commodity codes, country-of-origin and net weights for products they were shipping.

However, as they got more familiar with the requirements and through trial and error, some businesses in the sample managed to iron out these challenges. These tended to be businesses that were shipping either a single or limited number of product categories or those that had more straightforward products that didn’t have multiple components.

We had to learn the process of how to submit declarations through Trader Support Service but think I’ve got the hang of it now. It’s just basically going through every single box and every single page and making sure you understand it and we have an answer for it. Our commercial invoice now has details on part number, what product is, size, weight, country of origin, commodity codes.

(Great Britain business, small business, wholesale and retail trade, Trader Support Service user)

We just need to get information together. EORI number, tariff codes. Usually the same information is required each time, so we know what’s required now.

(Great Britain business, micro business, wholesale and retail trade, Trader Support Service user)

Northern Ireland based businesses also reflected this view and reported that their Great Britain trading partners had become more comfortable with information requirements after a few orders.

Once we got the first few orders up and running and found out what the system was, he [Great Britain supplier] was quite happy to continue.

(Northern Ireland business, micro business, wholesale and retail trade, Trader Support Service user)

For businesses that were shipping bespoke products, multiple product categories on a single pallet, or products with multiple components, the information required for declarations continued to prove difficult. This was driven by the fact that for many of these products, the information was not obvious or readily available. Thus, collecting the information for a large number of products or components was challenging for businesses.

An example was a Great Britain business that shipped items such as tools to their office in Northern Ireland for use in the office. Thus, many of the products shipped were not on the price list, which made it difficult for them to obtain commodity codes. Businesses also experienced challenges when they had smaller suppliers who were not set up to provide this information, as illustrated below.

You’ve got to be so aware of everything you’re buying and shipping. A lot of our systems involve bespoke elements that make information requirements complicated. We have to make sure our suppliers are contactable and can provide tariff codes, and so on. and have knowledge around exports. This is challenging for smaller, local business suppliers who don’t understand this - it almost eliminates using smaller businesses.

(Great Britain business, mid-sized business, healthcare, Trader Support Service user)

The administrative burden involved in completing Entry Summary Declarations drove businesses to take different approaches towards fulfilling this requirement. Some businesses managed this independently through the Trader Support Service system and contacted the Trader Support Service helpline for clarification or assistance on the information requirements.

Other businesses either had their intermediaries managing it from the start or had transitioned the responsibility for Entry Summary Declarations to their intermediaries after the first few attempts because of the additional burden involved.

Did 3 Entry Summary Declarations in February on Trader Support Service, then in March we handed over all declarations to hauliers. Don’t know if they use Trader Support Service…why would we use that when somebody will do that for us?

(Great Britain business, small business, agriculture, forestry and fishing, Trader Support Service user)

5.2.2 Arranging transport

With the exception of the challenges associated with shipping pallets, which has been captured in the previous section, most Trader Support Service users found the process for arranging transport had not changed, and they continued to use the same couriers or hauliers to move their goods. The key difference was in the paperwork requested by hauliers for every order, including information such as tariff codes and net weights.

However, a small number of businesses in the sample referred to some additional challenges. Firstly, some participants reported that many couriers had stopped taking food products, causing challenges for food businesses. While the participants attempted to find a solution to this by exploring the HMRC website and contacting Trader Support Service, it was met with little success.

A second issue related to Great Britain hauliers tying up with Northern Ireland-based hauliers. One business reported their Great Britain haulier tied up with a Northern Ireland haulier to take the goods over, ensuring minimal delays. Their perception was that Northern Ireland based hauliers were better informed and able to manage the new process.

Thirdly, drop shipping was mentioned as a challenge by one Great Britain business as drop shippers were no longer shipping goods to Northern Ireland. Instead, they were sending the goods to the Great Britain business for them to send on to Northern Ireland. This caused an increase in costs for the Great Britain trader who had to cover the costs of the goods being shipped to them and for their shipment to Northern Ireland too.

5.2.3 Managing Tariffs and Mitigations

There was a basic level of awareness that tariffs may need to be payable when moving goods from Great Britain to Northern Ireland. However, there was widespread confusion and lack of clarity on the exact requirements with regard to tariffs.

Businesses interviewed had adopted different approaches to managing tariffs on their Great Britain to Northern Ireland trade. Some, including those that had completed secondary declarations via Trader Support Service, as well as those that had export experience with EU and rest of the world countries, had looked for information on GOV.UK or the HMRC website to confirm their commodity codes and the tariff implications.

One business talked about referring to the World Trade Organisation rules, which led them to the conclusion that tariffs were not applicable on their products.

Some businesses assumed that there would be no tariff implications based on their EU trading experience where their goods were zero-rated or because they thought it was the end customer’s responsibility. Some also thought tariffs would not apply for Northern Ireland as it was an internal movement of goods. These businesses, however, had not taken any action to confirm whether this was correct.

A small number of businesses in the sample that had been charged a duty on completion of the Supplementary Declaration expressed uncertainty around why this had occurred. There also was some confusion around when a tariff would be applied. One business interviewed talked about being charged a duty for one shipment but not on the following two shipments, which raised questions around when duties and tariffs are applied.

At the end of my Supplementary Declaration, it said £[…] duty to pay. For the second and third supplementary Declarations, did the same with Trader Support Service helpline to complete and at the end, it came up as ‘zero duty’. It’s all very strange…why is duty different to the first Supplementary Declaration?

(Great Britain business, mid-sized business, professional and scientific activities, Trader Support Service user)

A small number of businesses also had specific trading patterns where they moved goods between their offices in Great Britain and Northern Ireland or they were involved in ‘temporary exports’ (where goods were moved to Northern Ireland for temporary use and then brought back to Great Britain. An example is where equipment is moved for events).

These businesses also felt they lacked information on their specific circumstances and whether they were required to pay a duty or not. Attempts had been made to clarify this via the Trader Support Service service helpline but had not been resolved.

Many businesses that were interviewed did not feel that they had a clear understanding on either when tariffs might be payable or on the options available to mitigate these tariffs. As captured above, while businesses, had some awareness of the possibility of tariffs, there was very limited awareness around tariff mitigation. In fact, most businesses interviewed also did not understand the concept of goods ‘at risk’ and when or how it would apply.

The key sources of information on tariffs for businesses in the sample tended to be the GOV.UK and HMRC websites. Some also reported using tax consultants, getting information from local commercial organisations such as the Chamber of Commerce, and the Federation of Small Businesses.

5.2.4 UK Trader Scheme

A few businesses in the sample, mainly those whose products were from the EU, were aware that tariffs were payable on the products they were selling to customers in Northern Ireland and had taken proactive steps to manage it by registering for the UK Trader Scheme. One business reported having managed to temporarily register for the UK Trader Scheme but was facing challenges making it permanent on account of the requirement to have a fixed place of business in Northern Ireland.

5.2.5 VAT (Value Added Tax)

Feedback on VAT liabilities from traders in the sample was mixed. Some felt that there was a lack of guidance from Trader Support Service on VAT and that they were not clear on the VAT requirements. Guidance from HMRC was highlighted as a key need for traders moving goods to Northern Ireland.

On the HMRC website it says VAT should be accounted on the invoice as a normal sale, but if it’s at risk then what do you do? There’s no guidance on Trader Support Service from the VAT perspective, what is the trader supposed to do?

(Great Britain business, micro business, wholesale and retail trade, Trader Support Service user)

However, a few participants were aware of VAT requirements and had registered for it in Northern Ireland. These tended to be those who had financial advisors such as accountants who had suggested this action.

Have registered for VAT in Northern Ireland after being advised to do so by tax adviser. Forced into using a consultant as the tax system is too complicated to understand by going directly to HMRC.

(Great Britain business, mid-sized business, manufacturing, Trader Support Service user)

The key sources of information on tariffs after 1 January 2021 included Trader Support Service guidance and webinars, HMRC emails and guidance, financial advisers or organisations such as their local Chamber of Commerce and Federation of Small Businesses.

5.2.6 Making Supplementary Declarations

At the time of fieldwork, there were varying levels of awareness and engagement with supplementary declarations across the Trader Support Service user group in the sample. While business size and trading patterns were not seen to drive awareness, the mode of shipping to Northern Ireland did have an effect.

Those using hauliers tended to be more aware, while participants using couriers or not involved in arranging transport were less aware of the need for supplementary declarations. This was potentially driven by the fact that hauliers were requesting additional information required for the supplementary declarations as it was a requirement to move goods, while many courier companies had not started to do this at the time the interviews were being conducted.

Never heard of them. Never come up in conversations.

(Great Britain business, mid-sized business, manufacturing, Trader Support Service user)

Amongst those businesses interviewed that were aware of the need for supplementary declarations, there was a high degree of confusion around who was responsible for completing them (their trading partner, intermediary or supplier) and when in the trading process they were required to be completed.

Confused about supplementary declarations. Is the onus on parent company as the exporter or Northern Ireland business as the importer?

(Northern Ireland business, micro business, wholesale and retail trade, Trader Support Service user)

Some businesses interviewed reported receiving requests (from the Trader Support Service team) for supplementary declarations on certain shipments, but not all. There were also reports around the absence of any form of confirmation once the declarations had been completed, which led to questions around whether they were meeting the requirements.

I don’t understand why we get them for some deliveries but not others…seems to be picked at random

(Northern Ireland business, micro business, agriculture, forestry and fishing, Trader Support Service user)

A few businesses in the sample with particular trading characteristics (for example, traders who deliver directly to end customers, rather than trading partners, in Northern Ireland or big retailers such as supermarkets) or those asked to do it by their hauliers reported they had attempted or completed supplementary declarations via Trader Support Service.

For these participants, completion of the supplementary declarations on the Trader Support Service system stood out as the key pain point in the Great Britain-Northern Ireland trading journey. They did not find it was simple or trader-friendly and this left them feeling frustrated about their trade with Northern Ireland.

The issue is Northern Ireland is such a small part of our business that we just want it to be quiet and, in the corner, but it’s causing me so much aggravation. I spend more time on the Northern Irish business, which is about £1m per year, than I do importing £90 million of stuff from Europe. It’s just a nuisance.

(Great Britain business, mid-sized business, wholesale and retail, Trader Support Service user)

Question 7

6.  ‘Trader Support Service non-user’ and ‘not registered for Trader Support Service’ experiences of trading under the new requirements

Accepted Answer

This section explores:

traders’ reasons for not using and not registering for Trader Support Service
the Trader Support Service ‘non-user’ and ‘not registered for Trader Support Service’ experience with declarations, tariffs and arranging transport

In this section, ‘Trader Support Service non-users’ will refer to businesses that had registered for Trader Support Service (and may have used it information and guidance) but not used it to move goods. Businesses that had not registered for Trader Support Service are referred to as ‘not registered for Trader Support Service’.

6.1 Reasons for not using or registering for Trader Support Service

Some businesses in the sample that had registered for Trader Support Service but decided against using it to submit paperwork for 2 key reasons:

firstly, several businesses we spoke to reported that they did not feel the need for Trader Support Service’s online declaration services because they already used couriers or intermediaries to move their goods, and were happy to continue to do so
secondly, some business saw Trader Support Service as a ‘risk’, as they perceived the online declarations systems to be difficult to use and were wary of fines or delays to shipments if anything went wrong with it

Haven’t used Trader Support Service…not for declarations. I cannot afford to take any risks with any shipments, and a lot of companies that I know of don’t use Trader Support Service. They’ve tried it, they’ve used it and thought no, this is not for us, this is just too much work for us.

(Great Britain business, micro business, wholesale and retail trade, Trader Support Service non-user)

The main reason that the businesses we spoke to reported for not registering for Trader Support Service was a lack of awareness of the service. On being provided with information on the service that Trader Support Service provides, businesses generally had a positive response to it, and thought that it would be helpful as a source of information and support.

The fact that it is a free service was viewed positively. However, most also felt they would not actually need to use it (even if they had been aware of it), as their intermediaries take care of most or all process requirements.

From my point of view, it would give me peace of mind, knowing there’s a service out there that can help you.

(Northern Ireland business, micro business, wholesale or retail, not registered for Trader Support Service)

If I was working for a huge company and we were selling different products all the time and some of them were dangerous or really high value, then it might be something we’d need…but I feel currently we might not need to use that.

(Great Britain business, micro business, wholesale or retail, not registered for Trader Support Service)

6.2 Overall experiences

The experiences of businesses that had registered for Trader Support Service but not used it to move goods (Trader Support Service ‘non-users’) and those ‘not registered for Trader Support Service’ were similar across the different points in the Great Britain to Northern Ireland trading journey. The key difference, however, lies in the sources of information they referred to.

While Trader Support Service was the primary source of information for Trader Support Service ‘non-users’ many of the businesses that had ‘not registered for Trader Support Service’ were highly reliant on their intermediaries to inform them about requirements, in addition to the GOV.UK and HMRC websites that they consulted. In fact, the guidance provided to them by intermediaries or fast parcel operators received strong positive feedback from these businesses. They felt it was more tailored to their business profile or industry compared to HMRC guidance, which was seen as more general.

Additionally, a few businesses that had ‘not registered for Trader Support Service’ had also appointed external consultants or customs agents, who provided them with information on the requirements.

At an overarching level, both groups of businesses interviewed (‘Trader Support Service non-users’ and ‘not registered for Trader Support Service’) reported a largely positive experience of trading with Northern Ireland after 1 January 2021. This was primarily because most businesses interviewed had left it to their intermediaries to complete the required paperwork. In fact, some participants reported being ‘pleasantly surprised’ at how easy it turned out to be.

However, it should be noted that HMRC has adopted a temporary approach to applying declaration requirements to the movement of goods in parcels (where in almost all cases, goods sent to consumers in Northern Ireland will not require a customs declaration). This may have contributed to the ease experienced with moving goods. Their experiences of each stage of the journey are outlined below in more detail.

6.3 Experience with declarations, tariffs and arranging transport

6.3.1 Declarations

Awareness of and engagement with declarations amongst both groups of businesses (‘Trader Support Service non-users’ and ‘not registered for Trader Support Service’) was low. Most in the sample did not have any knowledge or very limited knowledge of the declaration requirements and were not familiar with terminology such as Safety and Security declarations, Entry Summary Declarations or Supplementary Declarations.

Even where there was awareness, levels of understanding were often low, as businesses assumed this part of the process was being taken care of by their intermediaries who handled all the paperwork. Amongst these businesses, some participants mentioned having to provide additional information to their couriers or hauliers, but no unprompted connection was made to Northern Ireland declaration requirements.

We now have to produce 3 copies of an export invoice, but the good news is it’s prepared by UPS for us as part of the online process.

(Great Britain business, micro business, wholesale or retail, not registered for Trader Support Service)

Our long-standing hauliers have stepped in and said ‘we’ll do this for you’ but they’re actually charging me through the nose for it. I don’t even know what’s been involved. So, I need to find an alternative and do it myself. […] We are actually at no profit because of all the charges that have been incurred.

(Great Britain business, small business, wholesale and retail trade, not registered for Trader Support Service)

6.3.2 Arranging transport

Similar to the Trader Support Service user group in the sample, most businesses in the ‘Trader Support Service non-users’ and ‘not registered for Trader Support Service’ groups also reported minimal issues with arranging transport. They found that they could do it in the same way they had done previously (for example, book a shipment on the intermediaries’ website, enter the required information, followed by collection.)

'’We just log everything on [the TNT system], print the labels, the driver picks it up, I can then log in and get a proof of delivery. It’s dead straightforward really.

(Great Britain business, mid-sized business, manufacturing, not registered for Trader Support Service)

However, as in the case of the Trader Support Service users, these businesses also faced challenges with pallet shipments. A participant who used a haulier to move goods was told (post January 2021) that the haulier was only able to take single product pallet loads because of the commodity code requirements. This drove him to change using an alternative carrier, which was able to successfully move the goods to Northern Ireland.

6.3.4 Tariffs

There were varying levels of awareness of tariffs and duties across both the ‘Trader Support Service non-user’ and the ‘not registered for Trader Support Service’ groups in the sample. Some businesses were unaware of the new requirements and thus, had not considered any tariff implications.

Others, although aware of the possibility of tariffs, were under the impression their products were not affected by tariffs. This was driven by their trade with EU and rest of the world countries where their goods had not been subject to a tariff and thus they had assumed the same in the case of Northern Ireland. A few businesses had also checked GOV.UK for commodity codes and confirmed that they would not have to pay a tariff.

There was also low awareness of tariff mitigation options amongst this group of participants - and similarly to the Trader Support Service user group, the concept of ‘goods at risk’ was not fully understood. In fact, it was highlighted as a key gap in information. Further, most businesses interviewed were not aware of the UK Trader Scheme.

A small number of businesses in the ‘not registered for Trader Support Service’ group, reported challenges with finding information on tariffs. They felt that information on the HMRC website was either too technical and thus, difficult to understand or that relevant information was not available in a single location and was ‘dotted all over’. This caused a certain level of anxiety amongst these businesses that they were missing important information, which could cause them to be hit with a bill in the future.

I’m worried that I’m storing up trouble…looked on HMRC website and can’t find information on whether my goods/sector pay a tariff to Northern Ireland. The information on the site is hard to understand…language is like it’s written by lawyers…nothing is clear.

(Great Britain business, micro business, wholesale or retail, not registered for Trader Support Service)

Question 8

7.  Looking to the future

Accepted Answer

This section explores:

whether traders are considering making any changes to their supply chain and trading arrangements in future
areas where businesses have highlighted they would like to be provided with additional information and support to help them manage their Great Britain to Northern Ireland trade more effectively in the future

7.1 Changes to supply chains and trading arrangements under consideration

Many Great Britain businesses in the sample reported not having any concrete plans for changes with regard to their Northern Ireland trade at the time of the interview. However, some of the businesses interviewed, primarily Trader Support Service users, did highlight certain options that they were exploring, as detailed below, to ease the administrative burden posed by the new trading requirements, specifically with regard to declarations.

In addition, a few businesses in the research, from both Great Britain and Northern Ireland sides, talked about reducing their levels of trade between Great Britain and Northern Ireland. For these Northern Ireland based businesses, it was about finding alternative suppliers from the EU or Ireland. For the Great Britain businesses, it tended to be those for whom Northern Ireland was not a key market for their business model.

When talking about the future, many businesses interviewed, while not expressing worry or anxiety about the future at this stage, did express uncertainty. Some felt it would get better and easier for them, while others were uncertain how it would pan out and were waiting to see. This is reflected in the fact that very few had concrete plans for change and most had not yet taken any action on the options they were considering at the time of fieldwork.

7.1.1 Great Britain businesses: Plans for the future

As above, a number of businesses flagged that they were exploring making changes to their trading arrangements in relation to Northern Ireland. These included alternative trading routes, opening an office in Northern Ireland, increasing stock in Northern Ireland, increasing staff and reducing trade with Northern Ireland.

In terms of alternative trading routes, one option discussed was avoiding the Great Britain land bridge. Some Great Britain businesses interviewed, which tended to be the medium-sized ones with over 50 employees, that had already used a trading route between EU and Ireland for certain goods movements were considering using this route to service their Northern Ireland based customers. This would enable them avoid entry into Great Britain, thus bypassing the Great Britain land bridge.

Planning to change route to deliver into Northern Ireland - Eastern Europe to France to Ireland. Consolidate and store in a warehouse and move to Northern Ireland. This will eliminate passage through Great Britain entirely. This may be slightly more expensive and take a little longer, but it is much simpler and with reduced administrative burden.

(Great Britain business, mid-sized business, wholesale or retail, Trader Support Service user)

A few businesses interviewed discussed the option of opening an EU base to move goods into Northern Ireland, although they flagged that this was not yet something they were seriously considering. The perception was that it could help to reduce barriers as well as costs for customers as moving goods from an EU country to Northern Ireland would bypass the need to adhere to the requirements of the Protocol.

However, this would depend on the importance of the Northern Ireland market to them at the time and the trading requirements then. One business did express the expectation that things would ‘improve with time and experience’.

An option that was being considered more seriously by a small number of businesses in the research, in the short to medium term was the opening of an office in Northern Ireland. Some of these tended to be businesses that traded only with Northern Ireland and did not have any trade with the EU or other international markets. They planned to then put orders for their Northern Ireland customers through this office and avoid the Great Britain to Northern Ireland trading challenge.

A small number of businesses interviewed talked about increasing stock held by their Northern Ireland trading partner. One anticipated sending stock for up to 6 months from Great Britain, with the expectation that this could reduce the number of shipments to Northern Ireland. One business, a supplier of products to hospitals reported that they are keen to increase stock in Northern Ireland so they can have stock ‘on hand’ to enable immediate supply in response to orders.

Some businesses that participated in the research also talked about the need to increase staffing levels to manage the increased paperwork requirements. This would enable them to bring more of this in-house, thus doing away with the need for a customs agent.

A small minority of businesses interviewed talked about waiting to see how trading requirements evolved. They reported that if trading conditions became more difficult for them or got more expensive, they would either stop promoting sales in Northern Ireland or consider stopping their Northern Ireland trade altogether. These tended to be businesses that also traded with EU and rest of the world countries and were thus potentially less dependent on their Northern Ireland trade.

7.1.2 Northern Ireland based businesses: Plans for the future

Like their Great Britain counterparts, most Northern Ireland based businesses in the sample also did not plan to make any changes to their supply chain arrangements. However, there were a few options that some businesses were exploring in order to be able to manage their trade effectively. While most Northern Ireland-based businesses did not express anxiety about the future, there was a level of uncertainty reflected in their plans.

One business trading in food and drink worried that their Great Britain trading partner may stop trading with them in the future because of the additional burden although no changes had been made as yet. Some businesses, such as a confectionary retailer, reported that they would wait until after their busy summer season to review the situation and explore whether they needed to find an alternative supplier locally, from Ireland or the EU.

Some of the options for future trade with Great Britain being explored by Northern Ireland based businesses were: scaling up stocking capacity and identifying new suppliers. On the former point, one Northern Ireland based business recognised the need to scale up their stocking capacity in order to be able to manage deliveries effectively.

On the latter point, a small number of Northern Ireland based businesses reported that they are looking for new suppliers in Ireland or the EU, on account of cancelled orders and delayed deliveries. They believe this would involve ‘less hassle’ but are also unsure of the availability of the products they need.

7.2 Future information and support needs

A few businesses interviewed reported not having any specific information requirements, either because they felt that there was adequate information already available or because they didn’t require anything at the moment as the process was taken care of by their intermediaries. However, many businesses expressed a need for information and support to help drive clarity on the process requirements and their responsibilities.

Businesses felt that direct communication from HMRC via emails or letters would be helpful to them in accessing relevant guidance. There was a mixed response to webinars, and while some businesses were keen to continue attending them and felt they would be useful in the future, some also felt that they may not work for them as it would mean taking time out from their work to attend them. One micro business also felt that the webinars are likely to be designed for bigger businesses and not customised for the smaller ones.

While businesses felt that the requirements of the Northern Ireland Protocol would get easier with time and familiarity with processes, there were some clear areas of support highlighted by them.

7.2.1 Simple, easy-to-navigate guidance

Participants commonly remained unclear about how all the steps in the trading process worked and what were the key requirements at each stage. There was also lack of clarity on where responsibility lay for the different declarations, for example with the Great Britain seller or buyer in Northern Ireland and how or where they could easily access information such as commodity codes. Additionally, it was also highlighted that some of the current guidance tended to be lengthy and unwieldy, which they found it difficult to navigate.

Thus, they wanted simple, clear information that is easy to digest. This included:

simple language and plain English (no technical terms)
documents and videos that were not too lengthy or unwieldy (where there were lengthy documents required, guidance on how to navigate the document was felt to be useful)
graphic visualizations of steps or processes were also felt to be important
different examples of trading scenarios and how the rules apply

7.2.2 Customised information and guidance

Participants, especially many small businesses, felt that the current information and guidance tended to be generic and included information that was not relevant to them, which made it difficult for them to digest. A few businesses that had specific trading patterns (such as ‘temporary exports’ or internal movement of goods between offices in Great Britain and Northern Ireland) also expressed a need for information that is specific to their circumstances.

They felt that accessing this level of customised information was not easy on the HMRC website or via Trader Support Service. Thus, there was a call for specialised input and guidance for these circumstances either via direct communication (emails with links to information) to them or through a special Trader Support Service or HMRC helpline where they could clarify their responsibilities. They felt it was important to customise information to the size of the organisation, sector or trading patterns.

7.2.3 Confirmation on completing processes successfully

Many businesses interviewed expressed uncertainty around whether they were getting things right. There was a lack of clarity on the requirements, but they also reported not receiving confirmation when processes were completed. They reported that this would be valuable as it would provide reassurance and reduce anxiety.

7.2.4 Easy access to trading information via local authorities

Some participants, in both Great Britain and Northern Ireland, would like their local authorities to be sources of information on the Great Britain to Northern Ireland trading process in the future, in addition to HMRC and Trader Support Service. This may be driven by the fact that small businesses are engaged and supported to an extent by their local authorities on other matters and thus, have an established relationship.

7.2.5 Increased clarity on specific areas of the information

Participants also felt that there were details on specific aspects of the process requirements that it would be beneficial to get more information on in the future.

Specific gaps in information were highlighted, such as lack of clarity on which trading partner’s (for example, the Great Britain seller or supplier or the buyer in Northern Ireland) XI EORI number is required for the paperwork, confusion around who was responsible for making declarations, and how businesses may be able to easily access information on commodity codes. Businesses felt that it would be important for future guidance and information from HMRC to cover these areas to ensure smooth trading in the future.

Question 9

8.  The impact of COVID-19 on the Great Britain to Northern Ireland trade process

Accepted Answer

8.1 Great Britain to Northern Ireland trading patterns pre-2021

The impact of COVID-19 on businesses that participated in the research was reported to have been mixed, depending on sector. Some businesses, such as those providing goods to retail establishments that had to close experienced a drop in sales, whereas businesses in the pharmaceutical and food and drink industries that we spoke to saw their sales increase exponentially.

A lot of [customers] were retailers, a lot of them were closed, it was a huge problem.

(Great Britain business, mid-sized business, wholesale or retail, Trader Support Service non-user)

We’ve had our best year ever because a lot of the companies we service were the guys going out disinfecting premises, doctors’ surgeries and hospitals.

(Great Britain business, micro business, wholesale or retail, Trader Support Service non-user)

8.2 Preparations for the implementation of the Northern Ireland Protocol

Businesses in the sample said that COVID-19 had not affected their preparation for the changes in new trading arrangements. Some businesses, however, reported having more time to commit to preparations on account of a slowdown in trade.

With it being quieter in general with everything that was going on around COVID, it actually gave us a little more time to spend trying to get on top of what could possibly happen when we left Europe.

(Great Britain business, small business, manufacturing, Trader Support Service user)

8.3 Initial experiences of moving goods in 2021

The impact of COVID-19 on businesses and operations added to the delays faced by Great Britain to Northern Ireland traders in the sample, as organisations faced the challenge of employees being off work with COVID-19.

It [delay in delivery] was either due to Covid or Brexit and that was the verbal response when I phoned up to enquire or tried to make contact via the website or email.

(Northern Ireland business, micro business, wholesale or retail, not registered for Trader Support Service)

Additionally, the impact of COVID-19 also added to reductions in trade, particularly for those businesses in the sample selling to specific sectors in Northern Ireland such as retail, who faced reduced sales on account of COVID-19 and resulting lockdowns.

Our Northern Ireland business decreased from 4.5% to 1%…a combination of COVID-19 and customs changes…a bit of everything.

(Great Britain business, mid-sized business, wholesale and retail, not registered for Trader Support Service).

Cookies on GOV.UK

Glossary of terms

1. Executive Summary

1.1 Awareness and attitudes prior to 1 January 2021

1.2 Preparedness for the new trading requirements

1.3 Businesses’ experiences of the new trading requirements

1.4 Looking to the future

2. Introduction

2.1 Background

2.2 Research Aims

2.3 Method and sample

3. Great Britain to Northern Ireland traders’ understanding of and preparations for the implementation of the Northern Ireland Protocol

3.1 Great Britain to Northern Ireland trading patterns pre-2021

3.2 Business awareness of and attitudes to the changes before 2021

3.2.1 No awareness

3.2.2 Basic awareness

3.2.3 Moderate awareness

3.2.4 High awareness

3.2.5 Areas of confusion

3.3 Preparedness for the new trading requirements

3.3.1 Discussions with trading partners

3.4 Barriers to taking action

3.4.1 Gathering information about changes

4. Great Britain to Northern Ireland traders’ initial and on-going experiences of moving goods in 2021

4.1 Initial experiences of moving goods in 2021

4.1.1 An increase in the administrative burden

4.1.2 Delays in shipments through hauliers and couriers

4.2 Common themes defining the experience of moving goods to Northern Ireland

4.2.1 Sense of surprise at changes

4.2.2 Issues with administrative burden and lack of clarity

4.2.3 Issues with pallets, increased transport costs, and a decline in trade

5. ‘Trader Support Service user’ experiences of the new trading requirements

5.1 Experiences of using the Trader Support Service (Trader Support Service)

5.1.1 Trader Support Service registration

5.1.2 Experience of the Trader Support Service service helpline

5.2 Experience with declarations, tariffs and arranging transport

5.2.1 Entry Summary declarations

5.2.2 Arranging transport

5.2.3 Managing Tariffs and Mitigations

5.2.4 UK Trader Scheme

5.2.5 VAT (Value Added Tax)

5.2.6 Making Supplementary Declarations

6. ‘Trader Support Service non-user’ and ‘not registered for Trader Support Service’ experiences of trading under the new requirements

6.1 Reasons for not using or registering for Trader Support Service

6.2 Overall experiences

6.3 Experience with declarations, tariffs and arranging transport

6.3.1 Declarations

6.3.2 Arranging transport

6.3.4 Tariffs

7. Looking to the future

7.1 Changes to supply chains and trading arrangements under consideration

7.1.1 Great Britain businesses: Plans for the future

7.1.2 Northern Ireland based businesses: Plans for the future

7.2 Future information and support needs

7.2.1 Simple, easy-to-navigate guidance

7.2.2 Customised information and guidance

7.2.3 Confirmation on completing processes successfully

7.2.4 Easy access to trading information via local authorities

7.2.5 Increased clarity on specific areas of the information

8. The impact of COVID-19 on the Great Britain to Northern Ireland trade process

8.1 Great Britain to Northern Ireland trading patterns pre-2021

8.2 Preparations for the implementation of the Northern Ireland Protocol

8.3 Initial experiences of moving goods in 2021

Is this page useful?

Help us improve GOV.UK

Help us improve GOV.UK