From January 2022 you will no longer be able to delay making import customs declarations under the Stage Customs Control rules that have applied during 2021 (except for a specific exception for imports from the island of Ireland to GB whilst discussions on the Northern protocol are continuing). So what options doe we have?
- You can make a full import declaration before the goods can board a ferry or train at the point of exit from the EU.
- You can apply to use the Simplified Declaration procedure to make a declaration in your own records (EIDR) pending a full import declaration within 175 days. This procedure was available in 2021, the difference is that you must now apply and become authorised to do so.
- Transit, in simple terms, allows goods to move from the point of entry into the UK to an inland location to await customs clearance. It doesn’t however remove the need to import clear your goods if you want to receive them.
- And then there is the specific exception from the island of Ireland, Deferred Declarations.
Assuming that you have decided to use Ital Logistics as your Customs Intermediary, having completed a ‘Direct Representation’ letter, below is the procedure for a simple permanent export to the EU.
- Beforehand, you should have checked that your EU supplier has done everything that they need to do to pass EU customs. This will include:
- Holding an EU EORI number
- Has any relevant export/specialist licenses/certificates required
- Has organised export declaration in their country’s declarations system or will allow our partners to arrange
- On receipt of your booking, our partners in the EU country will contact your supplier and obtain the necessary information to be able to verify the above
- If our partners are to handle the customs process on your supplier’s behalf, they will obtain the Commercial Invoice(s) and Packing List(s) and all the necessary data to complete a customs entry
- Our partners will then pass the same documentation, including the cleared EAD along with the unique Movement Reference Number (MRN)
- If our partners are not handling your suppliers customs arrangements, they would still obtain a copy of the Commercial Invoice(s) and Packing list(s), and provide the cleared EAD and its MRN
- We would then enter the data into our system, submit this via API to CustomsPro for review and submission to HMRC, hopefully obtaining clearance
- Depending on your commodity, there may be Customs Duty and Import VAT to pay. See section below VAT and Duty
There are other stages which we and our partners will perform, but in simple terms, the above outlines the process.
Just one more thing though, if you currently buy on EXW basis, consider changing this to FCA.
Import VAT & Duty
Customs Duty (if applicable) should be paid once the goods arrive in the UK. You can pay this directly to HMRC, via us (for a fee), or use a duty deferment Account which means you can delay payment. Guidance on how to set up a Duty Deferment Account can be found here.
With regards to Import VAT, HMRC has devised a new system to alleviate cash flow and enable speedier transit through customs. This is called Postponed VAT accounting. You do not need to apply for this, plus you can use it for imports from the rest of the world. Some common questions are answered by HMRC here.
Our standard import processes will be on the basis that you use Postponed VAT Accounting, although we would request your confirmation that you are doing so.
If you are not VAT registered, then Import VAT must be paid as the goods arrive in the UK, along with, where applicable, any Customs Duties.