Questions and Answers

Products manufactured in Germany and moved/sold to customers in the UK — issues with excise duty

10 December 2018

It is our intention to have products manufactured in Germany and moved/sold to customers situated in the UK. As the products are liable to a duty of excise within the territory of the EU, we understand that the goods may only be moved without payment of excise duty under the Excise Movement Control System (EMCS) procedure.

We believe that to utilise these procedures the receiving premises in the UK must be approved as an excise warehouse by HM Revenue & Customs (HMRC) and be allocated a System for Exchange of Excise Data (SEED) number relevant to the excise warehouse. Our issue is that our UK Ltd company is not physically based in the UK and the premises we will be using to receive the goods does not hold an excise warehouse approval and is not authorised as an authorised warehousekeeper.

I have contacted HMRC and it advised that, as we do not have premises within the UK, we cannot make an application for the UK warehouse to be approved as an excise warehouse and therefore it cannot be allocated a SEED number for the purpose of the EMCS system. This will make our planned business scheme expensive if we have to pay excise duty on the goods being manufactured in Germany. We wondered if you could review this and advise if what HMRC says is strictly correct and if there are any options available to us that will mitigate the costs?

I don’t understand the codes used by my freight forwarder on the import entry

30 November 2018

We have recently imported some goods from Japan, they were previously sold by us to the Japanese company but they, unfortunately, need to be repaired. The freight forwarder has declared the goods to Inward Processing (IP) under the Authorisation by Declaration procedure, which I believe we can use three times a year if necessary. The forwarder explained that we need to return the goods to Japan within six months and submit a Bill of Discharge (BoD) to HM Revenue & Customs (HMRC) in Belfast at the National Import Reliefs Unit (NIRU). Can you explain the codes the freight forwarder used on the import entry?

I have applied for AEO C but should I apply for AEO S?

23 November 2018

We have recently applied for Authorised Economic Operator for the customs simplifications (AEO C) badge, but now a third-party company has advised that we should also apply for AEO S for supply chain security.

The reasons given by the third party are below. Is it really worth us applying for AEO S?

“AEO S accreditation is the accreditation that enables ‘fast-tracking’ goods through customs control and the AEO C accreditation is the accreditation that enables the operation of customs reliefs such as Customs Warehousing, Inward Processing, etc.”

New to exporting — help with VAT and thresholds

9 November 2018

We are predominantly a small “local” company and probably 99% of our business is in the UK. Because we have a website, however, we have found that we have been supplying all sorts of places. We sell a niche product made in France that we get orders for from as far afield as the USA. We have recently invested in a new IT system which comes with an integrated website (under development) and when this is live we will potentially be able to do more foreign sales.

We have been making sure we get the VAT right but have only recently become aware of the National Export System (NES) and Customs Handling of Import and Export Freight (CHIEF). I couldn’t find anything about thresholds so it seems as though, if you send goods beyond the EC, you have to use them. Currently, we send parcels off by UPS using Parcel2Go.com and all the documentation is taken care of through this process. Is this enough or should we be doing things differently?

What is Returned Goods Relief?

5 November 2018

One of our customers has asked us to “look at Returned Goods Relief (RGR) for goods exported from the UK that we want to bring back to the Republic of Ireland”. Is there some special arrangement between the UK and the Republic of Ireland?

Issues with the commodity code for cafetieres

25 October 2018

We have just started importing cafetieres and have had a problem with Customs about the commodity code number we used. As the article is mainly glass we coded it under Chapter 7013 “Glassware of a kind used for table or kitchen”, but we have been told that it should be coded under aluminium as the plunging device is made of this material. Is it worth arguing the case?

Establishing the nationality of employees under the EAR and ITAR

12 October 2018

My question relates to establishing the nationality of employees under the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR). If the employee does not possess a passport, what is the acceptable method to establish nationality? Could the individual’s birth certificate be used instead?

Import licence needed for steel bars imported from India — is this mandatory?

12 October 2018

We have a shipment of steel bars that has arrived in the UK from India. This is a regular shipment as we bring the bars into the UK 4–5 times a year. We have been told by our freight agent that this time we need an import licence and that we will have to pay an extra 25% customs duty — unfortunately, we haven’t noticed anything about this and we do need the goods. I just wanted to see if there was anything we could do to avoid these new requirements?

What are ASTM standards?

8 October 2018

We are working on a project that requires detailed information on the American Society for Testing and Materials (ASTM) standards, grades, tolerances, etc. Are you able to point me in the right direction?

What’s the best way to find a distributor or agent?

8 October 2018

What’s the best way to find a distributor or agent?

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