UK Importers may have overpaid Import Customs Duty

In the world of international trade, various mechanisms exist to ease the burden of customs duties and facilitate smoother commerce. Among these, Autonomous/Temporary Duty Suspensions (ADS) have emerged as crucial tools, enabling businesses in the UK and the EU to navigate the intricacies of import customs duty for components and raw materials that are essential for production but not readily available in local markets.

ADS stands distinct from other suspension regimes like Customs/Bonded Warehouse, Inward Processing, and Temporary Storage. Its primary purpose lies in granting importers temporary relief from customs duties, either in part or entirely, for inputs required in their production processes. These suspended duties can make a substantial difference in the cost-effectiveness of businesses that depend on global supply chains. Moreover, ADS not only aids the domestic market but also facilitates exports of finished goods, contributing to economic growth on both fronts.

In both the UK and the EU, a structured framework of ADS is in place, with numerous suspensions already operational. Both entities offer specific application periods during which new suspensions can be requested by eligible businesses. This provision encourages innovation, economic resilience, and adaptability to changing market dynamics.

However, the landscape of ADS is not without its challenges and occasional hiccups. A notable incident occurred on December 31, 2022, when the EU made the decision to eliminate a substantial number of autonomous duty suspensions that had originated from UK-only applications made before the Brexit era. This shift had an unintended consequence, leading to the accidental removal of associated commodity codes from the UK Global Tariff.

Reintegrating these commodity codes into the UK Global Tariff proved to be a complex endeavor, marred by technical difficulties encountered by HM Revenue & Customs. This challenge persisted for up to six months into the year 2023, during which certain commodity codes were effectively "missing" from the UK Global Tariff. The implications of this situation were far-reaching, potentially causing UK importers to inadvertently overpay import customs duties during this period.

In light of these developments, importers who utilized the affected commodity codes during this timeframe are encouraged to take proactive measures. Pincvision, as a trusted partner in the realm of international trade compliance, stands ready to assist. Importers are advised to undergo a comprehensive review to ascertain whether they qualify for a retrospective duty reclaim. This process can potentially result in the recovery of overpaid duties, thereby rectifying the unintended financial strain on businesses.

Are you wondering if this might have had any effect on your business? Please contact Peter, to receive the full list of TARIC codes by using the form below.
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Now the UK have their own temporary duty suspension regime in place, there have been over 100 new measures which were entered into UK law on the 1st January 2023. HM Revenue & Customs has introduced sub-CN10 codes to the UK Gloabl Tariff which makes identifying any new suspensions extremely difficult for UK importers. It has also introduced a second method of utilising these suspensions. Generally speaking there are two separate measures that need to be followed for suspensions coverd by CN10 level and sub-CN10 level commodity codes.

We would recommend that any UK importer would use the MSS and/or CDS “import item“ report which you can download here.

Our UK Partner, Customs Connect, has a duty analytical software tool (C360) that can be used to identify if any codes detailed in either of the two opportunities listed above have been used. Importers are being asked to either subscribe and upload these reports to C360 or to send the data to Customs Connect/Pincvision for one of our consultants to upload and evaluate.

If your company is interested in learning more about autonomous/temporary duty suspensions in the UK then we can offer a free consultation to discuss existing suspensions and the processes and stipulations for new suspension applications.

31 Aug 2023 at 10:45 am
3 min
Published by:
Peter Italiaander
Head of Customs & Trade Affairs
Customs & Trade Affairs
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