Home >UKWA calls for agility and rigour in Brexit negotiations

UKWA calls for agility and rigour in Brexit negotiations

04 January 2017

In a Position Paper for HMRC on Brexit, the United Kingdom Warehousing Association (UKWA) has outlined its preferred outcome and called for a robust trade system to be in place when the UK formally leaves the EU.

The UKWA says: “We would like to see the UK retain the same access to the single market and the European Customs Union that it currently enjoys, including access to community systems such as EMCS, Union Transit, Eurostat, etc. If this is not possible and the UK has to take an alternative path, the UK should look to become a champion of free trade and work towards a reduction of non-tariff barriers, both here and abroad.

“As an absolute minimum, systems need to be in place before the moment we formally leave the European Union to ensure that trade can continue without undue obstacles. These systems need to be clear, robust and well-understood. We accept that such systems may represent a transitional phase and again the length and scope of this needs to be clear.

“Industry must be consulted and forewarned of any changes to trading arrangements as far in advance as possible to enable businesses to make relevant changes to allow trade to continue.”

The UK must ensure that its customs' technical experts are present in all negotiations with the EU that relate to their area of expertise adds UKWA. 

“The strength of any agreement which covers trade in goods with the EU will be underlined by the attention given to the detail and any agreement could potentially be worthless to a large group of importers and exporters if a detail (such as rules of origin) is misunderstood. We therefore call for HM Government and HMRC to ensure that technical experts are always present at meetings discussing any area of customs competency,” the Association explained.

Free trade

UKWA says the UK should look to replicate the benefit of existing EU free trade agreements and those agreements which are currently under negotiation between the EU and other nations.

Also, the UK should look to negotiate free trade agreements with key strategic and economic partners with whom, at present, the EU does not have a free trade agreement.

“But, most significantly, the UK needs to ensure that a favourable trading relationship is agreed with the EU. Although this may be politically challenging considering the Government's position on the four freedoms of the EU, it is vital so not to disadvantage UK traders when trading with EU partners,” says the Association.


The introduction of the Union Customs Code in May this year has offered some facilitations to business which have been welcomed. There have, however, been some negatives which have put an unnecessary burden on UK business. We call on HMRC to examine the impact of the UCC on UK trade, and to remove any unnecessary burdens. We have listed some suggestions below, but this list is not exhaustive.

• Removal of the requirement for customs guarantees for potential duty on goods in customs warehouse and under other special procedures.

• Reintroduction of the First Sale for Export rule.

• Reintroduction of IP Drawback.

• Clarification of the definition of exporter.

• Clarification of the legal texts.

Market Access Database

The EU offers its importers and exporters access to the Market Access Database. This is a tool which is used by importers and exporters to understand what requirements they must comply with to ensure that they can trade. The UK may lose access to this database as the EU places restrictions on access from outside the EU (for example. you cannot access it from the USA).

UKWA says: “We would like to see a commitment that the UK will negotiate access to the existing database, or the UK will set up its own comprehensive market access database.”

You can download the UKWA’s Position Paper free here - http://www.ukwa.org.uk/files/7114/8223/6139/20161125_-_UKWA_Position_Paper_for_HMRC_on_BREXIT.pdf