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.
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?
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
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.
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.
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.
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