I am the multimodal import manager at Aramex (global logistics, courier, and package delivery company) and I head up the import team here at Manchester Airport. We bring in goods from all over the world, most recently to include the European Union, since Brexit. That includes arranging the freight for shipping and also the customs clearance and onward delivery. My work includes ensuring the correct import procedures and sometimes advising on export procedures for things that are going to go out on a temporary basis for repair and then be returned back to the UK. I am also a skydiver and have been jumping for 11 years now. I have around 2000 jumps.
Before Brexit, you were able to move goods between the UK and EU in free circulation, so that means you didn’t need to notify HMRC or customs that you were sending something between countries within the European Union. As we are not now in the European Union this complicates matters a little, and even if you own the goods you now have to apply the correct paperwork and include the proper export entry declaring why it is going out of the country. Then, upon return, you need an import entry and the correct paperwork to bring it back in.
A lot of the time we encounter problems simply because people don’t understand there is this process in place, and they are completely unaware they need to notify their courier – FedEx or DHL or whoever is doing the shipment. It is their responsibility to notify the courier that they actually own the goods, that they are already in free circulation in the UK, but they are being exported temporarily for repair or alteration. This includes the servicing of AAD units. It would also include goods going back to the US (or any other country) for repair – rigs, canopies, whatever. This then means that on the return leg, the customer again notifies the courier that the shipment is a British return, and the import entry can be matched to the details of the export entry, and Duty & VAT is then not applicable. What’s happening is the couriers are treating items as a brand new import into the UK because the commercial value of the goods has to be declared on the paperwork and nobody has told them the goods are returning back to the UK after repair so that is where the importer is being charged the duty, the VAT, the use of deferment, and all the other charges they tag on to the end of that invoice.
What you must do is send out your item with the correct paperwork to say that it is being temporarily exported for repair, and when it is returned to you the manufacturer or whoever is doing the maintenance, they should also include correct paperwork to state that it is being returned after repair. The onus is on the exporter/importer (customer), to know this.
When exporting, the customer can help with this process by advising the shipment is being exported temporarily for repair and the entry should use CPC 2100000. The customer will need to include a document called a commercial invoice – which states the value of the goods along with a statement “Temporary Export for Repair”. The customer should then request a copy of the export entry, a document called a C88 from the carrier.
When it is being returned, the customer should request a commercial Invoice from the company their goods are returning from abroad by stating “Goods Returned After Repair”. They will need to ask a copy of this be included in the package and then they should also send this to the courier along with a copy of the C88 export entry and the instruction that the goods are coming back after repair as a British Return, and to use CPC 6121000 on the import entry.
These CPC numbers are not documents – they are codes that the shipping agent will enter into the system that notifies customs if the goods should be liable for import VAT and Duty. It is the clearance instructions that confirm the goods are being re-imported back into the UK after repair, maintenance, or adjustment. People are experiencing problems through not properly declaring things for export for maintenance or repair, so incorrect paperwork simply makes it look like a brand new product being shipped into the country when it returns – therefore being subject to a customs entry into home use with VAT and duty applicable.
Rather than the likes of Royal Mail, you are better off using a proper international courier, like Aramex, as they will have a customs clearance department to complete the entries for you. Your goods will also be transported properly and insured for the proper amount. Regardless of who does the shipment, you will still need to provide the correct paperwork and instructions. Getting it right is about providing the right information from the start of the process – shipping out the goods – not trying to deal with the issue upon the return of the goods.
Now, after Brexit, the instructions are the same whether sending something to China or to Germany. In the UK we need to get away from the mindset that you can freely post things like before. It is all about the paperwork. You don’t need to apply to HMRC with the codes etc, the shipping agent will do this on your behalf, but you do need to provide clear instructions for them to process the entries correctly for you.
Text: Joel Strickland