Exporting goods from Estonia: if the non-preferential origin is Estonian would my goods be of EU preferential origin?

16 May 2018

We export goods from Estonia, where goods are assembled by our sister company (the delivery terms with the company is EXW Incoterms® 2010). Can we still name the UK company as the manufacturer as we have designed the goods, the goods belong to us and are assembled on our behalf (eg UK manufacturer, but non-preferential Estonian origin)? (For the purpose of this question, presume the work carried out in Estonia is not a “simple assembly” but a last, substantial, economically justified process.) If the non-preferential origin was then Estonian would it automatically mean the goods are of EU preferential origin too?

Shipping to the Middle East under DAP – should I use CIP instead?

9 May 2018

My company currently ships to many destinations in the Middle East using the Incoterm Delivered at Place (DAP) rule, although we are now considering whether it would be better to use the Carriage and Insurance Paid (CIP) rule instead.

Could you explain the following requirements when using the Incoterm CIP in terms of:

  • insurance requirements as a seller

  • documentation requirements as a seller for both customs and our customer?

What documentation is it necessary to complete? Is it still necessary to create documentation to clear customs at the receiver’s end?

Which type of parts should I be classifying as PL9009?

3 May 2018

I have a query regarding PL9009 on the UK Strategic Export Control List. We have previously been advised that our parts are not subject to dual use export controls as the parts do not contain vinyl ether. I have been advised recently by a couple of customers that they are classifying some parts as PL9009 due to not being able to ship parts to Iran.

Is this a classification we should be using? If yes, which type of parts should we be classifying as this?