Is a zero-value commercial invoice acceptable for repaired goods being returned free of charge to a customer in the USA?

2 July 2018

Is a zero-value commercial invoice acceptable for repaired goods being returned free of charge to a customer in the USA? Although our internal department believed the commercial invoice had to show the customs value of the goods being shipped, even if there was no charge to the customer, our US customer has advised us the following: “Please note, that the true value of the commercial invoice is the repair cost of each unit ... not the value of the end item. Under the US valuation rules, an article manufactured by you in the UK sent for repair under warranty (at no cost to the US buyer) at the time of re-entry into the US has duty assessed upon the value of the repair. The fact that the repair is under warranty is irrelevant to customs.”

Shipping goods directly from China to Australia — Form E queries

21 June 2018

We have a new supplier in China from whom we wish to ship goods directly to our Australian distributor, who will hold it in a customs bonded facility, (complete with the Association of Southeast Asian Nations (ASEAN) free trade form, Form E) for them to onward supply to our customers in the ASEAN region, eg Vietnam, Malaysia and Thailand.

  • Who generates Form E and when?

  • To qualify for the use of Form E, does the shipment need to be shipped directly from China (Shenzhen) or can the shipment be shipped out of Hong Kong and still qualify for Form E?

Canada-EU Comprehensive Economic and Trade Agreement — importing seafood into the UK from Canada

20 June 2018

We import seafood into the UK from Canada. We would appreciate some advice with regard to the Comprehensive Economic and Trade Agreement (CETA) between Canada and the EU. Our intention is to import goods from Canada into Denmark where they will be held in a customs warehouse under bond (T1 goods, ie customs duty unpaid). The Danish company then ships them to the UK duty unpaid and we arrange customs clearance and pay the relevant customs duty on arrival in the UK. Can we claim CETA preference at this point or must it be declared to customs at the place of arrival, ie Denmark, for preference to be claimed?

If the Danish company does the import clearance through SKAT (Danish customs) but pays no customs duty because of it being a zero rate under the CETA do the goods still become free circulation goods? We have been advised that to be “in free circulation” the goods must have had duty paid.

Are Certificates of Origin required for all shipments to Turkey?

15 June 2018

Along with an ATR, we have been advised by one of our Turkish customers that a Certificate of Origin is also required for exports to Turkey according to new regulations on documentation requirements. Could you confirm if this is customer specific or is it a new requirement that applies to all shipments to Turkey?