Beyond Borders: How to manage custom complexities and streamline your business.

When temporarily exporting from the UK, there is no prior authorisation or notification required to HMRC. You can export these goods under CPC 23 00 000 (or other applicable CPC in the 23 series) and later reimport them into the UK under CPC 61 23 F01/F05 if the goods are returning in the same state in which they were exported.

Temporary Admission is a procedure that is legislated for in the Union Customs Code (UCC), but the authorisation to use this procedure is granted by the individual member states of the EU. Depending on which member state you are temporarily importing into you’ll need to check with the local customs requirements and receive a prior authorisation to be able to suspend the duty/VAT on temp import.

CFSP (or CSDP as it’s now known) can be used from animal products from the EU by using the appropriate CPC to show that the goods imported are being subject to SPS controls. This would be submitted on a per-truck basis using a simplified frontier declaration. The IPAFFS/CHED would still be required to be done in advance of arrival and included on the frontier declaration.

The follow up supplementary declaration can be submitted per-truck or could aggregate together depending on the conditions of the authorisation.

This depends. If your warehouse is a customs-supervised warehouse and you are clearing the goods at import into the customs warehouse, then repacking may already fall under the ‘usual forms of handling’ which are permitted by your warehouse authorisation. You can check out more of the info here – https://www.gov.uk/guidance/check-if-you-can-carry-out-simple-repairs-or-process-your-goods-in-a-customs-warehouse

If your warehouse is just a distribution warehouse, and you’re currently clearing the products from China into UK free circulation before reexporting out to USA, then you could potentially benefit from utilising a Temporary Admission authorisation to cover this instead.

A private warehouse would only be able to store your goods if you are the warehouse keeper. A public warehouse would be able to store your goods as long as those goods fall within their authorisation.

You can import into a customs warehouse when the goods arrive and then transfer them to another customs warehouse owned by another warehouse keeper at a later date while having all the import duty and VAT suspended. The customer will then still be allowed to transfer them to the cruise ship without the payment of duty/VAT.

Postponed VAT Accounting (PVA) allows for all import VAT to be accounted for on the importer’s VAT returns. That means the import VAT that is due at the time of import is instead postponed until it is accounted for and is dealt with at the same time as the rest of the company’s VAT account. So PVA allows you to import goods without directly paying VAT to HMRC at the time of import.

A deferment account is used to defer paying the VAT until a later date. The transaction for the VAT is still made to HMRC, but on the 15^th of the following calendar month. All VAT paid under deferment to HMRC will then need to be reported on the company’s VAT return for that month/quarter.

So PVA = no payment of import VAT made to HMRC, accounted for on return. Deferment = paying import VAT at a slightly later date and reclaiming via VAT return.

There are countries other than EU member states that are part of the Common Transit Convention (CTC). Those are: Iceland, Liechtenstein, Republic of North Macedonia, Norway, Serbia, Switzerland, Turkey, Ukraine and United Kingdom. Goods that are in free circulation in any of those non-EU member states would use a T1 transit document to show the goods are of non-Union status while transiting across the EU to the UK.

You can use transit to cross over the UK as a Landbridge as well. Whether it’s a T1 or a T2 transit depends on where the goods were originally exported from. EU free circulation goods would use a T2 transit to cross through the UK as a Landbridge (e.g. Germany to ROI) and goods in free circulation in the above non-EU members would instead use a T1 transit when crossing through the UK (e.g. Turkey to ROI).

PVA can still benefit a company’s cashflow as it does not require an upfront payment of import VAT to HMRC at the time of import (or on the 15^th of the following month when using deferment). Instead, the payment of import VAT to HMRC and the reclaim of the import VAT from HMRC are both accounted for on the VAT return in the month/quarter in which covers the date of import.

You can still use Inward Processing for goods that are only subject to VAT at import, i.e., subject to 0% duty. But you may find that the additional restrictions and logistical requirements in using IP as being less beneficial than importing into free circulation and using PVA in dealing with the import VAT.

If the goods are only coming into the UK before then being exported out to USA in the exact same state, then there’s a couple different solutions.
You can either use a Temporary Admission authorisation to enter the goods into Temporary Admission for the duration in which they are in the UK. The TA procedure would then be release at export.

You can also use a customs warehouse to enter the goods into. That procedure would be released when the goods are removed from the warehouse for export to USA.

Or if it’s part of one singular movement, and the goods are not remaining in the UK other than to transport from the port of arrival from the EU to the port of departure to USA, then you could instead look at doing it as a transhipment movement. If it’s imported into inventory linked locations, that can release the link by setting it for transhipment, and the movement across the UK roads can be covered under a transit movement between the two ports.

Each of those would allow goods to move as described without the need of full import clearance into UK free circulation.

Inward Processing, and other special procedures, are primarily used for the purpose of duty relief/suspensions. If the goods you’re importing are not subject to any duty on import, and your VAT is already dealt with using a simplification or PVA, then you may not find any additional benefit in using Inward Processing.

Currently, the only CDS exports that are being allowed are those that export via GVMS only locations. These being Dover, Folkestone/Eurotunnel etc. The hauliers would still be required to use GVMS for these and the export DUCR on the CDS export declaration would still be used much like the CHIEF DUCR is.