For importers and exporters
UK-EU politicians and diplomats struck a free trade agreement last Christmas Eve. The full 1246-page international treaty - the “Trade and Cooperation Agreement” - and a 34-page explanatory summary can be found here: https://www.gov.uk/government/publications/agreements-reached-between-the-united-kingdom-of-great-britain-and-northern-ireland-and-the-european-union
Work is ongoing to convert the legal text of this treaty into guidance for businesses to understand what the provisions are, and the impact the treaty will have, on the building materials’ supply chain. The primary source of official advice on importing, exporting and customs’ declarations, duties & tariffs is here: https://www.gov.uk/topic/business-tax/import-export
The UK Border
The UK now has a full external border with all countries and various controls now apply to goods moving in and out between Great Britain and the EU. Border checks and controls will be introduced in a 3-stage Implementation Period between January and July 2021 to give firms more time to prepare and make arrangements.
These three stages are:
- from January 2021: importers of standard goods must prepare for basic customs requirements - e.g. keeping sufficient records - and will have 6 months to complete customs’ declarations. If tariffs apply to certain goods, payments can be deferred until declarations are made. You must also account for import VAT. There will be physical checks on animals and plants.
- from April 2021: plants and their products (e.g. timber) will need pre-notification and the relevant health documents.
- from July 2021: importers of all goods will have to make full customs’ declarations and pay relevant tariffs & duties. Full safety and security declarations will be required - and physical checks on plants and their products (e.g. timber) will intensify.
Whitehall has published a 316-page guide called the “Border Operating Model” to describe end-to-end processes and systems being used at the border. It is a detailed guide to arrangements being adopted as the UK is no longer in the EU Single Market and the Customs Union. This guide is at: www.gov.uk/government/publications/the-border-operating-model
Importing from the EU
After Exit Day, procedures for importing goods from the EU will change. The steps you will have to take are described here: https://www.gov.uk/import-goods-into-uk
If you are not used to handling complex customs processes - and find the prospect of doing so for the first time daunting - it is better to have someone deal with them for you. Most firms use an agent or intermediary. You have two options:
- use a customs’ agent or broker, freight forwarder or fast parcel operator: www.gov.uk/guidance/list-of-customs-agents-and-fast-parcel-operators
- use the government Trader Support Service: www.gov.uk/guidance/trader-support-service
For goods sold under Incoterms (e.g. timber), importers are liable to pay all costs. Incoterms is an abbreviation for International Commercial Terms, and published by the International Chamber of Commerce. They are used as global terms of trade and are at: https://iccwbo.org/resources-for-business/incoterms-rules/incoterms-2020/
Get an EORI Number
Importers must register for an UK Economic Operator Registration & Identification number. It is a unique identification number used in the EU Customs’ Union. The HMRC uses it to identify you and collect duties. If you are registered for VAT, you ought to have had a GB-EORI number issued automatically by the HMRC.
An EORI is a pre-requisite for applying for customs authorisations & simplifications. It ensures declarations and procedures are matched to the goods so they can be tracked, safety & security declarations can be accurately recorded, etc. You may face increased costs and delays if you do not get an EORI. If HMRC cannot clear your goods, you may have to pay storage fees. You may also need an EU-EORI number for the EU country you import from. The country list is here: https://ec.europa.eu/taxation_customs/national-customs-websites_en
Import Licences and Certificates
For certain goods, you will need a licence or certificate and may have to pay an inspection fee before goods are allowed into the UK. For example: some wood, wood products & bark to prevent harmful pests. You are responsible for goods upon arrival in England, Scotland or Wales, as set out here: https://www.gov.uk/import-goods-into-uk
VAT is an EU tax and payable on imports. They are also called ‘acquisitions’ and you have to add them and any tax due to your VAT return. If the goods are to make taxable supplies, or use in your business, you can reclaim the VAT. If the total value of imports received from the EU is more than £1,500,000, you have to complete an Intrastat declaration (see heading below).
BMF concern was focused on having to pay 20% extra upfront on imports under a ‘no deal’ Brexit. Our lobbying secured a concession from HM Treasury to ease the impact on cashflow & costs. VAT-registered businesses will be able to account for import VAT on their VAT return - instead of paying import VAT on goods before they can be released from ports. This concession applies to imports from both EU and non-EU countries. Guidance can be found here: www.gov.uk/guidance/complete-your-vat-return-to-account-for-import-vat
You must to conduct due diligence checks to ensure you or your representative(s) have followed the relevant UK rules so actions taken are not fraudulent before completing a customs’ declaration.
The trade in timber & timber products is a case in point and the new UK Timber Regulation will replace the EU Timber Regulation. Our colleagues at the Timber Trade Federation have helpfully provided advice about the new UKTR and conducting due diligence that you can find here:
Guidance on imports and exports of timber and timber products is here: www.gov.uk/guidance/uk-timber-regulation-imports-and-exports-of-timber-and-timber-products
Deferring Duty Payments
If you import goods regularly, you can apply for a ‘duty deferment account’ to delay paying most charges - namely VAT and customs & excise duty. A duty deferment account lets you pay duties by one monthly direct debit instead of paying for each consignment. If you (or your representative) are an importer and have an authorised guarantee in place, you can apply for an account here: www.gov.uk/guidance/check-which-type-of-account-to-apply-for-to-defer-duty-payments-when-you-import-goods
Rules of Origin
The new UK-EU Trade and Cooperation Agreement governs the rules of origin and claiming preferential tariffs. These rules determine the origin of goods based on where the materials or products (or inputs) used in their production come from. Their purpose is to ensure that preferential tariffs are only given to goods that originate within the UK or EU - and not from third countries (i.e. the rest of the world). If you can demonstrate the goods meet the UK-EU preferential rules of origin, you do not have to pay tariffs under this Agreement.
If you cannot demonstrate the rules of origin, you can still trade the goods but must pay tariffs that the UK and EU apply at the border. For exports to the EU, this will be the EU Common External Tariff. For imports into the UK, this will be the UK Global Tariff. It is your commercial decision on whether (or not) it is in your interest to meet (and prove you meet) the rules of origin in order to benefit from the Agreement’s zero tariffs.
To avoid paying tariffs from 1 January 2021, traders must (in the jargon) “claim preference” by meeting the rules of origin and making a declaration to that effect. You should ensure you take the following steps as soon as possible so that you are ready to use the Agreement:
- check the rules that apply to your goods to ensure they originate in either the UK or EU and can be traded on preferential terms. The general rules are in Chapter 2 of the Agreement and the ‘Product Specific Rules of Origin’ are contained in Annex ORIG-2;
- make sure you and your EU suppliers or customers have agreed whether a claim will be based on an exporter’s declaration - or on the importer’s knowledge - informing customs agents as appropriate;
- get ready to make the appropriate statement on the commercial and customs documentation for all consignments being traded after 1 January 2021.
The rules of origin are complex and if you are not used to them and find it daunting, it is better to seek expert advice to ensure that you comply. in the Agreement, they are set out in two parts, summarised as:
- General Provisions: these rules apply to all goods traded under preference - and include both the primary and administrative requirements.
- Product-Specific Rules of Origin: these specific rules set out - for every product based on their Harmonized System code - what the requirements are for that product to be considered “originating”.
To be considered as “originating” and qualify for preferential tariffs, materials or products must be sufficiently worked or processed within the UK or the EU 27 countries. By contrast, “non-originating” goods are those imported from third countries (i.e. the rest of the world). “Non-originating” may also refer to goods whose origin is unknown or it is not possible to determine.
Guidance on the rules of origin under the UK-EU Agreement is at:
Guidance on claiming preferential rates of duty on goods under the new Trade and Cooperation Agreement - and how to declare them on your import declaration - is at:
Guidance on delaying declarations for goods imported into the UK from the EU is at:
You have to complete customs’ declarations to get your goods through customs and in or out of Great Britain (see below for Northern Ireland). You have to decide whether to complete them yourself or use an agent. Doing so yourself can be complex: you will need compatible software and may prefer to find a firm that offers training to help you.
Making a declaration depends on where your goods start or end their journey. To check if you need to declare goods you move (a) between Great Britain and Northern Ireland; (b) between Great Britain and the EU; or (c) between Great Britain and the Rest of the World, please go here: www.gov.uk/check-customs-declaration
To start a declaration, you have to look up the commodity code(s) for goods using the UK Trade Tariff tool that has now replaced the EU’s Common External Tariff. This is central to the entire process and is the source of information on preferential trade agreements. Looking up commodity codes will classify your goods correctly and show the VAT rate; what duties must be paid; if an import licence or certificate is required; and if goods are liable to trade protection measures (e.g. anti-dumping or quotas). The UK Trade Tariff is at: www.gov.uk/trade-tariff
You must tell the HMRC the value of your goods when making a declaration. This value is used to calculate the amount of duty and VAT you owe and to compile official trade statistics. There are 6 ways to work out the value of imports as described here: www.gov.uk/guidance/how-to-value-your-imports-for-customs-duty-and-trade-statistics
Most declarations are submitted online to the HMRC Customs Handling of Import and Export Freight (CHIEF) database. If you make your own declarations, you have to buy compatible software that can submit to the CHIEF database. You also have to apply for (and be granted) access by giving full contact details that are linked to your CHIEF badge. If you use the Simplified Declaration procedure, the method is a different process. You can check here to see if you need to declare goods being shipped in or out of the UK: https://www.gov.uk/check-customs-declaration
During the 3-stage Implementation Period (January-July 2021) described earlier, you have a few months to complete customs’ declarations - and payments can be deferred until declarations are made. Guidance on delaying declarations is at: https://www.gov.uk/guidance/declaring-goods-brought-into-great-britain-from-the-eu-from-1-january-2021
Customs & Excise Duty and VAT
When you have calculated the value of goods, and classified them correctly for tax purposes, you must pay import customs & excise duties and VAT. You can do either by (a) paying at the time of entry or (b) if you have a duty deferment account (see above), you can delay payment until an agreed date. Paying is described here: www.gov.uk/guidance/paying-vat-and-duties-on-imports
You should check that the seller who is exporting goods from the EU has done everything they need to do to make sure goods go through EU customs smoothly & safely. Has the seller:
- got an EU-EORI number from the relevant EU authority ?
- obtained any relevant export or specialist goods’ licences or certificates ?
- completed an export declaration on their country’s declaration system ?
- issued their hauliers or drivers with all necessary documents before heading to the border ?
Intrastat collects trade statistics on goods (not services) between EU countries. The European Commission and UK Government use these statistics to monitor their economies and the Balance of Payments. UK companies are obliged to declare sales or purchase information by registering if, in the last calendar year, you bought or sold:
- imports valued at more than £1.5 million from EU countries;
- exports valued at more than £250,000 into EU countries.
After registering, you or your representative(s) must submit monthly returns on (amongst others) goods bought, sold, hired, loaned or leased; used in construction; or transferred between your businesses. Your obligations including record-keeping are described here: www.gov.uk/intrastat
Importing from the EU or European Economic Area into England, Wales or Scotland:
- Get a GB-EORI number and perhaps an EORI number for EU country you import from.
- Check if your goods need an import licence or certificate - most goods do not.
- Check VAT guidance to understand your VAT responsibilities and what records to keep.
- Decide whether you will handle customs’ declarations and other processes internally - or get someone else to deal with them for you - most firms use an agent.
- Check the UK Global Tariff for your goods using a commodity code that identifies the VAT rate, what duties must be paid, and if an import licence or certificate is required.
- Apply for (and be granted) a duty deferment account to pay duties by monthly direct debit.
- Check you have all the information to complete a customs’ declaration including EORI number.
- Check the exporter in the EU you are buying from has done everything they need to do to make sure goods go through EU customs smoothly & safely - including any export licence.
- On receipt of imported goods, update your records with date and time they arrived.
- Conduct due diligence to ensure you and your representative(s) have followed the rules before completing a customs’ declaration on imported goods.
- After you have calculated the value of goods, and classified correctly to ensure you pay the right amount, pay any import VAT and customs & excise duties owed.
- Ensure you or your representative(s) submit your Intrastat returns (if applicable).
Over time, changes to current rules & procedure for trade with the EU will be the same as now for the rest of the world. To alleviate delays or disruption at the border from Exit Day, there are steps you can take on importing during the Implementation Period between January and June 2021 - including deferring an immediate need to submit entry summary declarations described here: https://www.gov.uk/guidance/delaying-declarations-for-eu-goods-brought-into-great-britain
The Northern Ireland Protocol to the Withdrawal Agreement was agreed as a way to avoid a hard border on the island of Ireland. The Protocol took effect from 1 January 2021 and - for as long as it is in force - Northern Ireland will align with all relevant EU rules on placing goods on the NI market. This ought to mean no extra processes, procedures or restrictions on the flow of goods - so called “unfettered access” - to the whole of UK market.
But this has proved to be wholly incorrect - and businesses are encountering considerable problems in shipping goods to Northern Ireland. For instance: goods imported from the EU that are unpacked & repacked in Great Britain - exported back to the EU - notably the Irish Republic but also Northern Ireland (due to the Protocol and the Trade & Cooperation Agreement) - without any significant processing or adding value having been done - means companies have to deal with customs declarations & duties, rules of origin, VAT, etc.
Under the Protocol, goods from Great Britain not deemed to be ‘at risk’ of leaving the UK customs territory will not attract tariffs - but any ‘at risk’ of entering the EU Single Market will pay EU tariffs. You have to make customs declarations and may need to pay tariffs when bringing goods into Northern Ireland from Great Britain - or from outside the EU, namely the rest of the world.
For goods coming into NI from GB, you will not pay customs duty if you are:
- able to claim a preferential rate of duty under the new UK-EU Trade & Cooperation Agreement.
- authorised under the UK Trader Scheme and declare that your goods are not ‘at risk’ from onwards movement into the EU.
- eligible to claim a waiver on the customs’ duty up to specified limits.
Before you move goods, some of the matters you must consider are:
- you need an XI-EORI number to move goods between NI and non-EU countries - namely Great Britain and the rest of the world.
- you can sign up for the free Trader Support Service or get someone to deal with customs for you.
- if you want to declare goods are not ‘at risk’, you have to apply for authorisation for the UK Trader Scheme.
- if you import goods regularly, you can apply for a Duty Deferment Account to delay paying most customs charges.
- you have to find the commodity code to make customs declarations when shipping goods.
- you have to check the rules of origins requirements for your goods.
This is not an exhaustive list and you should read the guidance on goods in and out of Northern Ireland at: https://www.gov.uk/guidance/trading-and-moving-goods-in-and-out-of-northern-ireland-from-1-january-2021
Exporting to the EU
The primary source of official advice on importing, exporting and customs’ declarations, duties & tariffs is here: https://www.gov.uk/topic/business-tax/import-export
After Exit Day, procedures for exporting goods into the EU will change as described here: https://www.gov.uk/export-goods
You must complete an export declaration to get your goods through customs and into the EU. These rules currently apply to exports to the rest of the world including Switzerland, Norway, Iceland and Liechtenstein. You can make the declarations yourself or use an intermediary such as a customs agent or freight forwarder instead. You will need a GB-EORI number.
Declarations are submitted online using the National Export System. If you choose to do this yourself (rather than use an agent) you have to register here to use the National Export System: www.gov.uk/guidance/export-declarations-and-the-national-export-system-export-procedures
You or your representative must make a full declaration before the goods arrive at the UK port or airport of export - otherwise they may be stopped at the border. You will need to be trained to make declarations - and may also need to buy compatible software that can make submitting declarations easier. There are grants available for staff recruitment, computer software and external training - please see the section on the “Don’t Forget” page.
Export Licences and Certificates
You need a licence or certificate to export certain goods. This mostly relates to agricultural, horticultural & piscatorial products, chemicals & controlled goods - but timber and wood packaging are included: www.gov.uk/guidance/export-licences-and-certificates-from-1-january-2021
Timber exported to the EU or EEA requires documents about the source and legality of your timber - so that your customer(s) can meet the EU Timber Regulation (EUTR) due diligence rules.
Wood packaging material shipped in either direction must comply with the ISPM15 international standard by undergoing heat treatment and marking. This includes pallets, crates, boxes, cable drums, spools & dunnage. Checks will be carried out upon or after entry into the EU. For advice, please contact your supplier or the Timber Packaging & Pallet Confederation at: www.timcon.org
After Exit Day, you can charge zero rate VAT on most goods you export into the EU.
You should check that the buyer who is importing goods from the UK has done everything they need to do to make sure goods go through EU customs smoothly & safely. Has the buyer:
- got an EU-EORI number from the relevant EU authority ?
- obtained any relevant import licences or certificates ?
- completed an import declaration on their country’s declaration system ?
UK companies must declare information on sales or purchases with the EU worth more than £250,000 by registering with Intrastat and submitting monthly returns: www.gov.uk/intrastat
If you export to the EU or European Economic Area from England, Wales or Scotland:
- Get a GB-EORI number and perhaps an EORI number for EU country you export to.
- Check if your goods need an export licence or certificate.
- Check VAT guidance to understand need to retain export records to apply zero VAT rate.
- Decide whether you will handle customs’ declarations and other processes internally - or get someone else to deal with them for you - most firms use agents or intermediaries.
- Register to (and be granted) use the National Export System and apply for a CHIEF badge(s) to make declarations - training is required - you can buy specialist software to make it easier.
- Complete an export declaration using the NES that gives you a unique reference number to use to ship your goods across the GB border.
- Check the importer in the EU you are selling to has done everything they need to do to make sure goods go through EU customs smoothly & safely - including any import licence, an EU-EORI number, and completed an import declaration there country.
- Keep records of goods you have exported to the EU for six years - you may need them to claim any reliefs or refunds.
- Ensure you or your representative(s) submit your Intrastat returns (if applicable).
Make sure your hauliers, drivers or shippers have all the necessary documents before heading to the border. More detailed information for road and freight transport can be found at:
- by road at the Road Transport Association: www.rha.uk.net
- for freight at Logistics UK: https://logistics.org.uk
The EU will not have a period of grace after Exit Day because the EU is not leaving the EU. Your exports to the EU must
have the name & address of the relevant EU importer and other obligations described in the bullets above from now on.
Trading with the rest of the world
After Exit Day, procedures for international trade remain the same as before and are found here:
- get a GB-EORI number.
- check if your goods need an import licence or certificate - most goods do not.
- check VAT guidance to understand your VAT responsibilities and what records to keep.
- decide whether you will handle customs’ declarations and other processes internally - or get someone else to deal with them for you - most firms use an agent.
- check the UK Global Tariff for your goods using a commodity code that identifies the VAT rate, what duties must be paid, and if an import licence or certificate is required.
- apply for (and be granted) a duty deferment account to pay duties by monthly direct debit.
- check you have all the information to complete a customs’ declaration including EORI number.
- check the exporter you are buying from has done everything they need to do to make sure goods go through customs smoothly & safely - including any export licence.
- on receipt of imported goods, update your records with date and time they arrived.
- conduct due diligence to ensure you and your representative(s) have followed the rules before completing a customs’ declaration on imported goods.
- after you have calculated the value of goods, and classified correctly to ensure you pay the right amount, pay any import VAT and customs & excise duties owed.
In addition, you or your representative must check the rules of the country you are exporting to - e.g. export licences and certificates. Import duty might have to be paid in that country. You can get help from the Department for International Trade to research and find export markets and learn how to do business overseas at: www.great.gov.uk/advice
The UK Government has a range of international sanctions against certain countries, companies and individuals for finance, trade and immigration reasons. For example: national security & anti-terrorism; human rights & modern slavery; and bribery & money laundering. Please check to see if your exports are controlled under UK sanctions here: www.gov.uk/guidance/uk-sanctions
TIMBER AND TIMBER PRODUCTS
Timber supply chains are regulated to ensure harvesting is legal and sustainable and global forest governance is upheld. Traders in timber & timber products must take action to ensure goods originate from legal sources. The Timber & Timber Products (Placing on the Market) Regulations 2013 - known as the UK Timber Regulation - and the UK Forest Law Enforcement, Governance and Trade Regulations 2012 are the relevant legislation in Great Britain. Both have since been amended but requirements in these regulations remain broadly the same as the EU Timber Regulation. In Northern Ireland, the EU Timber Regulation remains in force.
Guidance on the rules that apply after Exit Day can be found here: www.gov.uk/guidance/uk-timber-regulation-imports-and-exports-of-timber-and-timber-products
This webpage covers imports and exports in various directions:
- trade between Great Britain and the EU and EEA.
- trade between Northern Ireland and the EU and EEA.
- trade between Great Britain and Northern Ireland.
- exports from Indonesia into Great Britain with a FLEGT licence.
- exports from Great Britain into the EU and EEA with a CITIES permit.
You must conduct due diligence checks to ensure you or your representative(s) have followed the relevant rules so actions taken are not fraudulent before completing a customs’ declaration.
Timber imported from certain countries must be accompanied by a forest law enforcement, governance & trade (FLEGT) licence - e.g. Indonesia. You or your representative(s) must have them verified by the Office for Product Safety & Standards before the customs’ declaration is made. Once verified, the goods are considered legal and due diligence does not have to be done. The expectation is that UK authorities will still recognise FLEGT licences after 1 January 2021.
Colleagues at the Timber Trade Federation have helpfully provided advice that you can find here:
HELP WITH EXPORTING
The Department for International Trade offers help to UK companies to (amongst others) research and find export markets and learn how to do business overseas at: www.great.gov.uk/advice
UK Export Finance is the credit agency that helps exporters with working capital loans, insurance against non-payment, credit guarantees and other export services: www.great.gov.uk/get-finance
Under the UK-EU Trade and Cooperation Agreement, you do not have to pay tariffs if you can demonstrate that goods meet the rules of origin requirements. These rules determine the origin of goods based on where the materials or products (or inputs) used in their production come from. Their purpose is to ensure that preferential tariffs are only given to goods that originate within the UK or EU - and not from third countries (i.e. the Rest of the World).
If you cannot demonstrate the rules of origin, you can still trade the goods but must pay tariffs that are applied at the border. For exports to the EU, this will be the EU Common External Tariff. For imports into the UK, this will be the UK Global Tariff. It is your decision whether (or not) it is in your interest to meet (and prove you meet) the rules of origin in order to benefit from the zero tariffs.
Guidance on claiming preferential rates of duty on goods under the UK-EU Trade and Cooperation Agreement - and how to declare them on your import declaration - is at:
Rest of the World
In May 2020, ministers unveiled a new ‘Most Favoured Nation’ tariff regime - called the UK Global Tariff - that has replaced the EU’s Common External Tariff. The main changes include scrapping unnecessary tariffs & tariff variations; rounding tariffs down to standard percentages; and getting rid of “nuisance tariffs” that were 2.5% or below.
Certain industries are protected to support British manufacturers from unfair trading like dumping and subsidies. Ministers recognised that zero tariffs on ceramics would expose home markets to cheap imports. But other goods including aluminium and steel will not be protected by tariffs.
Tariffs do not apply to existing preferential access agreements like the Generalised Scheme of Preferences. They will not apply to free trade agreements negotiated and signed in future. The UK Global Tariff is at: www.gov.uk/trade-tariff
There are pricing implications to consider:
- removing tariffs completely means duties have been cut to zero on imported materials, products and tools. For example: paint (down from 6.5%); copper alloy tubes (down from 5.2%); screws, nuts & bolts (down from 3.7%); LED lamps (down from 3.7%); window frames (down from 3%); glass sheet (down from 3%); thermostats (down from 2.8%); screwdrivers (down from 2.7%); bricks (down from 2%); roof tiles (down from 2%); blocks (down from 1.7%); and cement (down from 1.7%) are now zero-rated tariffs.
- simplifying by having bands for certain duty rates; removing the number after the decimal point so the rate is a whole number; and rounding tariffs down to the nearest standardised band. For example: hand tools for plasterers & painters currently 3.7%, circular saws & blades at 2.7%, and central heating boiler & spare parts at 2.7% will all drop down to 2% band.
Liberalising tariffs in this way creates winners and losers and raises the issue of competitive advantage between the UK and other countries. Not having tariffs on so many imports creates a lop-sided market - because neither the EU nor countries around the rest of the world are proposing to cut their tariffs on UK exports. That is why striking a UK-EU trade deal was so important.
BMF and NFB Comment
The UK imports billions of pounds more of materials & products from the EU than we export there. As a long-standing and mature supply chain, we tend to deliver on a ‘just in time’ basis. Keeping construction going partially depends on being able to move imported goods across borders and through ports to get them to customers.
The BMF welcomes the UK-EU Trade and Cooperation Agreement and news that tariffs and quotas do no longer apply. But non-tariff barriers - like rules of origin and customs checks - mean goods will take long to arrive with extra costs for firms to familiarise themselves with new rules, complex procedures, longer record-keeping and such like.
The risk is that the flow of goods is disrupted - or prices rise - or stockpiling occurs. Another risk is that circumstances force firms to switch to a ‘just-in-case’ basis instead of a ‘just-in-time’ model. If so, NFB members may not be able to reliably obtain materials & products when needed (for whatever reason) that will have profound impacts on business planning, site operations, project completion, contractual liabilities, cashflow and ultimately, business survival.