Export Declarations

 

Arrival messages

Arrival messages should be made as the goods arrive at the port or airport and must contain several specific pieces of information.

Departure messages

As with arrival documentation, departure messages should contain all core information required to progress the movement of goods, the detail of which will be completed by the customs agent.

If transport details on the departure messages are incomplete, you will need to seek permission from HMRC before withdrawing any goods from the port.

 

Repairs and leasing

Goods exported from the UK for maintenance or repair (without a change of ownership) may use a Customs Special Procedure at export and subsequent re -import. The use of a Customs Special Procedure could potentially reduce any relevant duties at the time of re-import.

 

As ever, we are here to help. If you’d like to discuss these changes, and how they may affect your business, please get in touch with us at info@bethancc.com.

 

For further information visit: 

https://www.gov.uk/government/publications/revenue-and-customs-brief-15-2020-vat-conclusion-of-review-of-import-vat-deducted-as-input-tax-by-non-owners

 

https://www.gov.uk/guidance/check-your-arrival-and-departure-messages-are-correct

 

https://www.gov.uk/guidance/making-a-full-export-declaration

Classification, Valuation and Origin

Classification, Valuation and Origin – Knowing Your Product

From the 1st January 2021, all goods moving between the UK and the EU require customs declarations.

All declarations must detail accurate classification, valuation and origin information, as has always been the case for 3rd country movements.

 

Classification

The classification of products details information such as duties payable and any supporting documentation required.  It may be worth stipulating that your supplier provides you with the accurate classification within your contractual terms and conditions.

However, irrespective of the provision of a commodity code from the supplier, the responsibility and the liability lie with the importer or exporter.  Therefore, we would always recommend that you check the tariff to confirm its validity.

 

Valuation

There are 6 methods of valuation to consider when declaring goods at import.  Businesses should ensure that they are fully aware of the method that is relevant to their business, as well as to the individual transactions.

The key thing to bear in mind when calculating the potential duty of a consignment, is that the customs value must include the cost of the goods, insurance and freight.

 

Origin

The rules of origin, as laid out in the ‘Trade and Co-operation Agreement’ form a vital piece of the import puzzle.

Where goods are of EU origin and the origin statement is detailed on the commercial document from your EU supplier, you may be able to claim the preferential duty rate on goods being imported.

However, bear in mind that the statement itself, without proof of origin – is not sufficient. A business may be asked to substantiate the origin declaration, and should be able to provide the necessary evidence if requested.

As well as this, it is important to check the product specific rules against the classification of your product to ensure that it meets the origin rules.

 

We are running an online bite-size training course on this topic on Wednesday 24th February, from 1-2pm. For more information, or to book your place on the course, please drop us a line at info@bethancc.com.

As ever, we are here to help. If you’d like to discuss these changes, and how they may affect your business, please get in touch with us at info@bethancc.com.

 

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

Customs consultancy advise ‘back to basics’ approach to tackle Brexit concerns

 

See below recent press coverage for Bethan Customs Consultancy:

 

A leading North-east customs consultancy has highlighted the need for businesses to understand basic customs documentation as they adjust to our new trading relationship with the EU.

 

Founder and Director of Oldmeldrum-based Bethan Customs Consultancy, Nicola Alexander, said that a high proportion of businesses who deal solely with the EU have never previously needed to complete customs declarations to move their goods. As a result, there appears to be a collective gap in awareness on how to complete the documentation required needed to import and export goods in our post-Brexit economy.

 

She explained: “New rules covering imports, exports, tariffs and data came into force on 1st January this year, and in some cases businesses may now need a licence or certificate to continue trading with EU countries. The exact requirements for each business will vary depending on what is being exported, its value, where the product originates from and to which country it is being sent.

 

“For some time now, we have been working closely with our clients to support their knowledge and understanding of the operational changes necessary for a seamless transition into these new trading conditions. However, judging by the volume of requests for support that we have received from companies who are not current clients, there is a degree of apprehension across the wider business community about how to navigate this new customs landscape. These queries indicate a lack of awareness about the process that will allow businesses to continue moving goods without incurring costs or delays.

 

“There are several simple steps that can help. For example, implementing import and export procedures within your business will provide a clear ‘go to’ guide for staff.  Creating template documents such as commercial invoices and import clearance instructions within your business will ensure the information being supplied to the agent remains consistent, and streamlines the clearance process.”

 

In a bid to help businesses understand how the new arrangements are operating in practice, the Bethan team plan to release a series of short Q&A videos.

 

The firm will also be running two bite-size training sessions on ‘Imports’ and ‘Exports’ in the coming weeks.

 

Photo: Jonathan Addie Photography – https://www.jonathanaddie.com/

Border Control Posts – What You Need to Know


A Border Control Post is a dedicated area within a port area where Government agencies can inspect goods prior to import / export. This inspection can take the form of a physical check, or a documentation check. Government agencies may also allow the import / export process to continue without their involvement.
With various uncertainties and changes in prospect, and as we all adapt to a new movement of goods process, it would be sensible to expect the frequency of these physical and /or documentation checks to increase, along with a more structured inspection programme.
If this is something you have limited experience of, it’s only natural to feel some trepidation. However, an understanding of the process, and your role in it, whether you are a business or port authority, goes some way towards alleviating this.

What does the inspection process look like?

Clear communication and co-operation between port authorities and businesses is vital in addressing the practical measures that will ensure these inspections take place in a timely and efficient manner.
Any physical inspections may delay the import / export of goods, so it’s important to factor in considerations such as whether these are perishable.
There are several logistical storage and handling issues to consider. Does the port or harbour have a lay-down area to act as a Border Control Post? Is this clear, accessible and available to use at short-notice?
Does the port have an adequate facility with the associated equipment in place?

Documentation

You should make sure that all of your shipping documentation is in order, including, for example, cargo summaries, invoices and manifests.

 

Contingency planning

There are a number of reasons why Government agencies might not give permission for the import / export to proceed ranging from straightforward documentation irregularities or errors, to the import / export of unauthorised goods. Potential actions by Government agencies can include the detention of goods, monetary penalties, payment of the Duty and VAT, as well as criminal proceedings.

The team at Bethan Customs Consultancy have extensive experience spanning HMRC, Border Force and supply chain and logistics. We can support businesses at every stage of the process from guiding through standard inspections and follow-up visits, to liaising with HMRC in ensuring compliance and minimising penalties.

As ever, we are here to help. If you’d like to discuss these changes, and how they may affect your business, please get in touch.
Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

Deferred Customs Entries

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

As of 1st January 2021, HMRC are allowing businesses to defer entry of their Customs declarations on goods imported or exported for up to 6 months. In essence this will maintain the security of the supply chain during what promises to be a period of upheaval for businesses which trade with EU partners.

As a business, the most important consideration is whether the deferring of the declarations works for your commercial business. You will still be required to input all the relevant information from your records into your commercial systems at the time of the transaction, even if you don’t send this to your freight forwarder immediately. However, it does allow you to continue importing business critical goods without incurring potential delays while setting up the new process.

If you are interested in this option, there are a number of factors to bear in mind.

EORI

Any UK company importing goods from the EU should have a GB EORI number.

Know your goods

Make sure you are fully aware of your customs obligations in relation to your goods. For example, what is their tariff code? Do your goods attract customs duty? Do they require any other certification, such as an import licence, health certification or certificates of conformity? Does your import declaration require any additional support documentation?

Controlled goods

The deferred declaration process is not applicable in the case of controlled goods, so businesses which import or export these must follow the normal rules for making import declarations.

Controlled goods include:

• Alcohol products
• Tobacco products
• Fish
• Fertiliser
• Plants
• Animals
• Explosives

VAT requirements

Is your business registered for UK VAT? Do you need to be registered for UK VAT? If you wish to use Postponed VAT Accounting, then a UK VAT registration is a necessity to allow this facilitation. All business should retain within their commercial records the import transaction information to ensure accurate duty and VAT is being paid.

Commercial records

Before importing the goods, it’s important to ensure that your business records are of a sufficient standard to document and maintain all the relevant information. In addition to the standard import transaction information held, companies will be expected to record the date and time of arrival of the goods within their commercial premises.

Timescale

Should you wish to defer making an Import Declaration – you have up to 6 months to submit the Supplementary Declaration to HMRC. Of course, no business would want to be in the position of having to make all their declarations at the same time, so it’s worth putting in place a process for the declarations to be made within a business acceptable timeline.

Monies will be taken from the Deferment Account when the supplementary declaration / deferred declaration has been submitted.

Who will be making the declarations?

Customs Freight Agents can make the declarations to Customs on your behalf. Does your business have a preferred Customs Freight Agent? If you have engaged the services of a Customs Freight Agent, have you checked whether they can or will make Deferred Customs Declarations for your business? Have you asked them if you can utilise their Deferment Account, and is there a cost associated with doing so?

Alternatively, if you intend to make your own Customs Declarations, there are several important considerations. Do you have personnel with the necessary experience and specialist knowledge to carry this out on behalf of the business? Do you have the necessary software to complete these Declarations and communicate with HMRC?

If so, your business will require a Deferment Account, which must be set up and authorised by HMRC prior to your first deferred declaration being presented.

And finally….

The legislative requirements surrounding customs declarations are subject to change at the moment. For the most up-to-date information please visit: https://www.gov.uk/prepare-to-import-to-great-britain-from-january-2021.

As ever, we are here to help. If you’d like to discuss these changes, and how they may affect your business, please get in touch.

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

The Free Trade Agreement and your Business

Photos by: Grant Anderson – www.grantanderson.me / @grantandersondotme

As the end of the Brexit transition period looms ever closer, we’re all eagerly waiting to find out whether the UK government and their EU counterparts can reach a Free Trade Agreement.

Any such agreement would allow ‘free’ trade between the EU and the UK. It would mean that, if we have a full Free Trade Agreement covering all the relevant sectors, the rate of duty would be 0%, allowing the movement of goods without the payment of any additional duty. So far so good, but there are still several changes in the pipeline that you need to consider, regardless of whether an agreement is reached or not.

Declarations

There seems to be a common misunderstanding that a Free Trade Agreement would remove the need for any additional paperwork. This is certainly not the case! Businesses must still adhere to all the standard administrative regulations from trade bodies such as HMRC, HSE and DEFRA. Anyone exporting goods from the UK will still be required to complete export declarations in the UK, and ensure that goods are formally imported into the EU with an import declaration, and vice versa.

In order for HMRC to process import / export declarations, detailed and comprehensive documentation must be submitted to them, so it’s vital that you factor in the additional time and cost of consolidating all of this information, as well as process time with HMRC and other Government bodies.

Contracts

With this increased volume of official documents required across the supply chain, it’s imperative that businesses pay close attention to the terms and conditions of contracts, particularly in relation to risk and the liability for making declarations and paying any relevant duties.

EORI numbers

It’s also worth noting that businesses may require both EU and UK Economic Operators Registration and Identification (EORI) numbers in order to make import / export declarations. If you have already held or been allocated one of these, you can apply to HMRC online. It’s a straightforward process which typically takes HMRC around 3 days to approve.

Trade Tariffs

Finally, businesses should also be aware of both the UK and the EU trade tariffs for their goods, regardless of whether there is a Free Trade Agreement in place or not. Depending on the terms of sale previously agreed with the customer, the liability for paying any additional duties may well lie with them.

If you’d like to discuss these changes, and how they may affect your business, we’d be happy to have a chat. You can get in touch with us at: info@bethancc.com.

Smooth Sailing – Customs Planning Advice for Port Authorities

Exporting support Bethan Customs Consultancy

As things stand, it’s full steam ahead for the end of the Brexit transition period on 31st December 2020. This will have significant implications for port authorities in relation to the customs procedures and documentation required for goods being imported and exported.

Customs entries

Previously free circulation goods were allowed to move within the EU with no tax or duties payable. However, all EU states will now be classed as a third country, and vice versa. As such, port users should be aware that customs entries will be required for all cargo, and may be required to show that the goods comply with EU standards.

Port authorities should also consider whether they have the correct approvals in place to allow commercial businesses / customers to import and export goods through the port?

It’s also worth checking whether port users have the relevant Economic Operators Registration and Identification (EORI) numbers. EORI should be held by all UK and EU businesses looking to import and export goods, from / to each other. Previously EORI numbers issued in the UK would have been accepted in the EU. However, post 31.12.2020, there will be GB EORI and EU EORI numbers. Therefore, all businesses within the supply chain should ensure they have the appropriate EORI.

Temporary storage facilities

All goods being shipped to the EU will require a pre-shipment security declaration before departure, potentially delaying vessels loading/departing. Consideration should be given to whether goods will need to be temporarily stored within the port site.

Any such storage facility must be approved by Border Force, meeting their specific criteria for security purposes, and allowing goods to be examined and customs cleared with minimal disruption.

Import and export documentation

While draft legislation in relation to exports is in place in the UK, the EU’s full expectations will be revealed in the final trade agreement.

So it’s vital to be prepared for changes to UK requirements. The likelihood is that port users will need to liaise more with HMRC in order to progress the clearance of goods. More documents will be required when importing and exporting goods going forward – for example, goods being exported to the EU will require documentation proving that they meet EU standards.

Port approvals

Businesses which currently hold approvals within the EU for importing and exporting may find that these no longer apply in the UK. There is still some uncertainty regarding how the situation will be resolved, but there is the potential that these approvals could be invalid once the transition period ends. Going forward, the onus will be on businesses to ensure their approvals remain valid.

Access to Government agencies

Something else to bear in mind – Government agencies are more likely to be visible within port areas post 31st December 2020, including HMRC, Border Force, Police, Trading Standards, Food Standards, Fishery authorities.

If you’d like to discuss these changes, and how they may affect your business, we’d be happy to have a chat. You can get in touch with us at: info@bethancc.com.

Fancy Joining Our Team?

Compliance Executive…

We currently have an exciting opportunity for a Compliance Executive to join our highly experienced and passionate team.

We are looking for a self-motivated individual with excellent knowledge of customs legislation and a full understanding of supply chain procedures.

If you have the following experience, we would love to hear from you:
– Several years experience within a similar role
– A positive “can do” attitude
– Excellent communication skills
– Excellent knowledge of Microsoft Excel, Word and Power Point

For more information or to apply, please send a covering letter along with your CV to:  nicola.alexander@bethancc.com

Closing Date: Friday 23 October 2020

Why are HMRC Authorisations Important for Business?

The 2nd September is undoubtedly a date for your diary – from tomorrow there are 120 days until – 31 December 2020 – the end of the transitional period for the UK leaving the EU. That figure is important, because it’s the same number of days that it takes for HMRC to process applications for a Customs Comprehensive Guarantee (CCG), something which must be in place before accessing other duty suspension authorisations. This guarantee covers the potential duty liability that a business may have to suspend at the time of importation.

Why is it worth securing these approvals? Put simply, having access to an HMRC Authorisation can secure a more advantageous market position for your business. Given the imminent legislative changes for businesses which import and / or export, having these in place could help your business to avoid potential delays and additional charges as a result of legislative changes.

Holding one of these approvals demonstrates the high standards to which your business adheres in the global market. This is crucial for securing the confidence of your business partners, something that is even more important during these turbulent times.

What’s more, some HMRC Authorisations allow for the suspension of import duties, thus assisting businesses to better manage their cash flow. While certain special procedures can be applied for as a one-off, or for regular use, depending on individual business needs.

These duty suspension Authorisations include:

Authorised Consignee – An Authorised Consignee approval allows for businesses to undertake the customs process away from the border, at an Approved Premises.  This is an efficient way of moving non-Union goods across several customs territories into the UK, while avoiding border delays.

Customs Warehouse – A Customs Warehouse approval allows for businesses to import goods into a customs warehouse with the potential duties suspended.  The goods can be stored for an indefinite period of time within the Customs Warehouse.  Duties only become payable when the goods are released into free circulation.

Inward Processing – An Inward Processing approval allows for businesses to temporarily import goods for the purpose of processing, inclusive of repair, without the payment of duties/ VAT at the point of import.

Outward Processing – An Outward Processing approval allows for the temporary export of goods for processing or repair. Upon re-importation to the UK, you are then able to claim full or partial duty relief.

Authorised Use – Formally recognised as End Use, an Authorised Use approval allows businesses to import certain goods at a reduced or zero rate of duty, provided they are put to a prescribed end use within the approved time frame.

Underpinning all of the above, a business which holds AEO (Authorised Economic Operator) status is internationally recognised for their business compliance standards, in a fashion similar to a ‘kite mark’.

Should you wish to discuss any of the above HMRC Authorisations to ascertain their suitability for your business, please get in touch – we are more than happy to help.