Brexit Statement

The United Kingdom left the European Union on the 31st of January 2020. The UK has now entered the transition period in which trade negotiations with the EU will be undertaken. The transition period is due to end on the 31st of December 2020. Whilst we await the outcome of trade negotiations, Incora remains concerned by the potential ‘no-deal’ scenario in January 2021 and we continue plan for this outcome. We will run our Brexit project to mitigate the most relevant risks to our business and ensure continued supply to our customers. Throughout the transition period and beyond, Incora will action all the key areas of risk to ensure continuity of supply and to minimise any impact to our customers’ businesses.

As a key integrator within the global aerospace industry, Incora imports and exports products throughout the UK, EU-27 and the rest of the world daily. As part of our current obligations, Incora operates with our own EORI numbers within the EU, utilises Customs Authorisations and extensively exports products to countries around the world. Incora has strong capability and experience in the preparation of relevant customs documents, export paperwork as well as a dedicated Trade Compliance and Customs Team within the business to manage the changing customs landscape. We confirm that Incora has the necessary controls in place to ensure the correct commodity codes exist for products supporting appropriate export paperwork. Therefore, as trade between the UK and EU-27 will be subject to border controls and required customs paperwork in 2021, Incora is already capable of managing these additional processes with our logistics partners (Logistics Providers, Freight Forwarders and Customs Agents).

Incora continue to invest in customs authorisations to help minimise the impact of duty and VAT upon our business. Incora can also confirm that we have completed due diligence on all carriers used by Incora ensuring that they all have sufficient and suitable resources available to manage the import and export declarations on our behalf and have capacity to accommodate the increasing paperwork burden associated with UK-EU27 Trade in 2021. From a VAT & duty perspective, Incora can confirm it has resources to manage changes in duty requirements associated to EU-27 deliveries, and already operates a duty deferment scheme which provides a level of risk mitigation.

Incora will communicate to all relevant suppliers and ask that they take necessary and appropriate actions to mitigate the impact of Brexit upon our company, and provide customs data as required for UK-EU27 trade after the transition period ends. Incora has asked suppliers to review their regulatory compliance and seek approvals where necessary. Incora has requested that suppliers engage with the export control competent authority and apply for any licences required to export items subject to export controls.

Incora hold a strategic stock portfolio in our facilities and will advance inventory into the our sites where possible in advance in attempts to secure against any delays resulting from increased customs surveillance of imports into the UK from the EU-27. We will work closely with our partners/suppliers to review lead times for products imported into the UK, taking the appropriate steps to mitigate potential delays for our customers.

Of course, there are unknowns in this scenario that cannot be anticipated but we are working with our third-party service providers to respond agilely to risks. Incora hope that this information provides the clarification required and assurances that we are preparing for the end of the transition period.

Frequently Asked Questions

1. What is the transition period and what impact does it have on Incora?

The UK ceased to be a member of the EU on 31 January 2020 and entered a transition period with the European Union which will last until 31 December 2020. During this time, current rules on trade, travel and business for the UK and EU still apply, so little has changed in respect of day-to-day operations. However, Incora needs to prepare for any changes implemented from 31 December 2020 once the transition period ends. The biggest areas of impact are in relation to our workforce, cross-border transactions and taxation.

2. Is a ‘no-deal’ Brexit possible?

’No deal Brexit’ referred (until January 2020) to an EU Exit without a Withdrawal Agreement and thus without transition period. A ’no deal Brexit’ in this sense did not happen as the UK left the EU with an agreed Withdrawal Agreement and entered into a transition period which will last until 31 December 2020. During this time negotiations with the EU around trade and other issues will be ongoing. ’No deal’ now refers to the potential for the UK to reach the end of the transition period with no trade deal with the EU in place.

3. Will the ongoing COVID-19 pandemic delay Brexit?

Negotiations on the future relationship between the UK and EU are ongoing, albeit delayed, despite the coronavirus pandemic. Both parties have said they are committed to achieving a deal by the end of the year, when the current transition arrangements come to an end. However, this still remains an uncertainty.

4. What is the new UK Global Tariff and what will it mean for Incora?

In May 2020, the Government announced a new UK Global Tariff (UKGT) which will replace the EU’s Common External Tariff from 1 January 2021 at the end of the transition period.
It is described as a ‘simpler, easier to use and lower tariff regime’ and is aimed at scrapping red tape and reducing cost pressures, to help UK businesses compete in terms of global trade.

5. What can Incora do to protect our business from Brexit?

We have carried out a Brexit risk assessment to see if Incora has any specific vulnerabilities. As part of the risk review, we have modelled different scenarios would impact Incora including the financial impact of the UK and EU reverting to World Trade Organization rules if no trade agreements are reached during the transition period. We are assessing delays in the supply chain, and issues with recruitment, impacts on importing and exporting and the consistency of Regulatory issues post-Brexit.

6. Where are the Incora facilities in Europe located?

We have Offices in the United Kingdom, Italy, France and Poland. Our European Warehouses are in Poland, Germany and France.

7. Will Incora still be able to supply substances containing Chromium VI compounds under your REACH Authorizations?

The UK Government has committed to sign REACH into UK Law and recognize EU-based Authorizations should there be a “No Deal” scenario; however, the EU have not yet indicated that they would reciprocate. Should this scenario happen, we would be unable to import Chromates covered by our Authorizations into the EEA; this will be a commercial issue for Wesco and a production issue for customers in the EU where we are the sole Authorization holder. Where we are not the sole Authorization holder, we will be able to purchase from European-based members of the CTAC and CCST consortia where appropriate. As a Distributor, not a manufacturer, we do not believe that we can appoint an Only Representative (OR) within the EU. We are unsure if we will be able to transfer the Authorizations to a European Legal Entity. We are currently taking legal advice as to our options.

8. Do we anticipate problems with staffing due to Brexit?

So far, we have not seen any significant loss of staff who are EU Nationals within the UK or vice-versa. We are continuing to monitor the situation closely in the run up to the Brexit date.

9. How can I make sure Incora’s supply chain is ready for the end of the transition period?

It is difficult to predict how the end of the transition period will impact supply chains, so many businesses may not be 100% ready. However, there are some sensible steps Incora can take.
First, Incora has conducted a thorough review of the supply chain in order to get a full understanding of the network and where any potential risks lie. For example, if Incora’s supply chain crosses the EU-UK border, what will happen if there are delays in the event that no trade agreement is reached at the end of the transition period in December 2020? We are implementing strategic inventory controls, repositioning and relocation in an attempt to mitigate risk as much as possible. Incora has tested the risks in different Brexit scenarios and identified mitigating actions – such as working with different suppliers, or building in contingencies for any delays.

10. How can I minimize delays when supplying goods?

The Government has confirmed plans to introduce import controls on EU goods at the border when the transition period ends on 31 December 2020. Traders in the UK and the EU will have to submit customs declarations and be liable to goods checks. The EU has also said it will enforce checks on UK goods entering the Eurozone.