FAQ Brexit January 2021

Does the late trade deal between the UK and the EU change anything concerning earlier communicated implications of the Brexit?

For the supply of our paperboard, it does not. The UK is now a third country, implying that everything needs to be customs cleared when supplying from the UK (Incada) into the EU and v.v. (Invercote).

Furthermore, the UK left the EU-VAT regime, which requires Workington-mill to be fiscally represented in the EU and the supply into the EU will have to be managed using multiple VAT-ID’s for Workington mill.

Please Observe: This does not mean that several legal entities will act on behalf of Workington mill. There is one single legal entity supplying into the EU, being Holmen's paperboard Workington Ltd. However, several VAT-ID’s have been registered for Holmen's paperboard Workington Ltd.

Will there be any import tariffs applicable on paperboard?

No, there are no import tariffs applicable for the supply to EU-countries. Non-EU countries might be impacted by import duties, when those countries do impose import duties for products with UK origin.

How will the importing processes & customs clearance be taken care off?

Holmen  will take care of the customs clearance process in nearly all EU countries and has partnered up with service providers in both directions, including customs brokers to manage the process.

How does the mill ensure that there is no issue on the supply of raw material to Workington?

• The mill practices a dual sourcing strategy for all raw materials (for >90% of our inbound
• Raw Material are dual sourced) and 60% of items used are UK sourced
• The majority of EU raw material (>80%) is entering the UK via northern seaports on the east and west coast of the UK which are judged to be a considerably lower risk in terms of customs delays/congestion
• Safety buffers are increased for inventories selectively for some EU supplied materials.
• The lead-times for raw material have been extended for some products and the re-order

points are increased

• An ongoing dialogue and risk assessment of critical suppliers is in place and monitored by

our procurement team

Which Incoterms will we be using for Invercote in the UK and Incada in continental Europe?

For the foreseeable future we will supply with the conditions DDP when crossing the EU border in either direction, in case we supplied with DAP conditions before. From Workington mill within the UK and from storage and sheeting locations on mainland Europe to EU destinations, we will supply with delivery term DAP.

Which VAT-ID do I need to use for the supply of Incada?

For supply within the EU, The VAT-ID of Workington mill depends on the supply chain of the goods. In case we deliver directly from our Workington mill, the VAT-ID of the EU-entry country will be used. For supply from sheeting stations or call off locations in NL, DE and FR, the VAT-ID of Workington mill for those respective countries will be used. From other call off locations, the VAT-ID of the EU-entry country will again be used.

Which VAT-ID’s are valid for Workington mill?

For Workington mill we have now registered the following VAT-ID’s

Belgium                                     BE742756318

Germany                                   DE327591590

The Netherlands                        NL801415299B01

Sweden                                     SE502045675101

France                                       FR 92429867781

Portugal is pending.

Will I be charged VAT for my Incada-supply?

For mainland Europe local VAT will be charged in the following two scenarios

• When supplying from Workington mill to Swedish destinations
• When supplying Incada from German locations (sheeting/call off) to German destinations

How can I be certain my material will not face any delays?

Now the transition period has ended, and the Brexit situation is a fact, we supply under the new conditions. It has not led to any congestion at the borders yet. As reported in 2020, we have ramped up our service stocks in mainland Europe. The call off stocks for supply to destinations in mainland Europe have also been moved to mainland Europe. It remains to be seen if the border crossing will become more congested.

Will the paperboard supply be impacted by the EU-timber regulation (EU) No 995/2010)?

There are no concerns for the supply of Incada to the EU. Workington Mill has contractual agreements with its suppliers that they need to meet the requirements of EUTR and performs a due diligence review every year as part of the management systems.

Will the Brexit have an impact on FSC-/ PEFC schemes?

Chain of Custody schemes like PEFC and FSC are not impacted by Brexit

How can I be sure the board from Iggesund produced outside EU complies with EU-directives (e.g. for food contact material and non-food references applied within EU?)

After consultation between the Confederation of Paper Industries (CPI) and Food Standards Agency (FSA) in the UK we have been advised that there will be a ‘close alignment’ with the EU product safety regulations, so no negative impact on the Product Safety compliance status of our Incada paperboard products.

At the moment we are fully harmonized with all paperboard related packaging EU legislation requirements and until instructed otherwise these standards will remain unchanged.

We take this opportunity to assure our customers that we will continue the dialogue with the various advisory bodies and communicate any change or regulatory divergence from this position should it arise. The instruction for now remains ‘business as usual’.