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Importing Goods from 1 Jan 2021

When importing goods post Brexit, you will need to be aware of the following:

  1. Background and the basic building blocks of importing, including paperwork

Prior to Brexit, goods being imported into the UK from the EU would bypass customs formalities.   From 1 January 2021 this position has changed – all goods coming into the UK no matter where from must pass through customs formalities.

Who has to complete these formalities at customs (both when leaving the country where the supplier is based and when the goods come to the UK) depends on what incoterms have been negotiated with your supplier for the delivery of their goods (see dealing with your supplier)

Incoterms also identify who must pay for the transport of the goods and their insurance when being transported.

The paperwork completed and filed with customs dictates: -

  • Who is importer of record – based on the EORI number
  • What rate of duty is payable – based on the commodity (sometimes called tariff) code of the goods
  • Whether any VAT and/or duty reliefs are applicable – based on the customs procedure code of the goods

To find out where to get this data – see the key data section

The University does not have the ability to file its own paperwork with HMRC.   Having seen the data we would have to provide and the implications of getting it wrong, we are in no hurry to start doing our own submissions – let’s leave it to the experts.

   2. Dealing with your supplier

In communications with your supplier you should be identifying who Is responsible for the import/ export paperwork and paying for the transport.

The supplier should not perform the import paperwork when a VAT and/or duty exemption (e.g. goods qualifying under the medical and veterinary exemption) is being claimed.  If they make a mistake the University does not have much recourse to make a correction and we may be stuck paying the VAT and duty.  Our standard terms and conditions indicate incoterm DPU is used in this instance

In other cases, our recommendation is to get the supplier to do most of the work (and cost).  The University Standard Terms and conditions indicate incoterm DDP is used.

Whatever incoterms you negotiate please make sure that the supplier understands their obligations in respect of paperwork they will need to perform and that you identify what costs will follow on from it.

The Viva Xpress Logistics website explains basic incoterms and what they mean.

   3. Dealing with the courier/delivery company

The Courier company will make the import declarations on your behalf but will need details from you to be able to do so.  The courier company will also charge you for the services they perform so you need to budget for this.

There are also certain temporary schemes put in place by HMRC to make the Brexit transition easier – however they only work for fully commercial companies and NOT for the University.  HMRC have stated they are not to be used for purchases related to non-business (grant funded) activities. Accordingly

The University will not be using deferred declarations

The University will not be using postponed VAT accounting

If you are asked to approve the use of the above = please decline

Details that the courier company may well ask you to complete/ advise are included in the key data and where to get it section.

The courier company will charge you for the work that they perform on your behalf.  If they charge a % fee for using their deferment account, confirm if the charge applies even with a same day payment of the VAT and duty due – it may not, and you have saved yourself some cash.

   4. Medical and veterinary relief

An explanation as to when this relief may be applicable can be found on the VAT reliefs webpage.

Before the shipment is made - Identify whether duty is due on the importation using HMRCs tariff tool, if so then contact NIRU at niru@hmrc.gov.uk advising details of the University (VAT Number GB 607606448) and the goods that you are importing and requesting duty relief for medical and veterinary purposes. NIRU will give you an authorisation code which you should pass to the courier company to claim the duty exemption.

Complete and send to the courier company a copy of the VAT relief Certificate L.

Advise the courier company to use customs procedure code 40 00 C17.

   5.  Key data and where to get it

Commodity code –  This can be found by using HMRCs tool Trade Tariff: look up commodity codes, duty and VAT rates - GOV.UK. Your supplier may be able to assist you in determining which is the correct code.

Customs procedure code – This tells HMRC whether duty and VAT is payable on the relevant import. Unless an exemption is being claimed this will be:

Home use, basic declaration 40 00 000

Where you are claiming a VAT and/or duty relief please refer to (i) the section on medical and veterinary relief or (ii) contact the VAT team on vatenquiries@st-andrews.ac.uk.

Deferment account – the University does not have a deferment account – it does however offer same day payment for duty and VAT liabilities. Please liaise with the Accounts Payable department – accpay@st-andrews.ac.uk if you need a same day payment.

Deferred declarations – the University is NOT using deferred declarations

EORI number is GB 607 606 448 000

Postponed VAT accounting - the University is NOT using deferred declarations

Tariff Code – also known as commodity code – see above

   6. Additional Resources

The BUFDG and HEPA guide (PDF, 884 KB) was prepared by BUFDG and HEPA as a reference point for procurement, purchasing, finance and tax teams within universities when purchasing/importing goods from outside the UK from 1 January 2021.

The guide sets out the following:

  • Overview of main changes (due to Brexit)
  • Points to consider when goods are brought into the UK
  • Common terms and issues (Section 5)
  • Instances where import VAT and/or duty is not payable (Section 6)