Reliefs and measures for importing and exporting goods

    Contents

  1. Pay no import duty and VAT on medical supplies, equipment and protective garments
  2. Customs authorisations, export and import measures
  3. Delaying import VAT and duty payments
  4. Conditions for zero rating: exports / removals affected by the coronavirus emergency

Pay no import duty and VAT on medical supplies, equipment and protective garments

The Government has announced measures that enable importers to avoid payment of import duty and VAT on certain medical supplies, equipment and protective garments.

The goods must be imported by or on behalf of an organisation based in the UK who are:

  • state organisations, including state bodies, public bodies and other bodies governed by public law
  • other charitable or philanthropic organisations approved by the competent authorities

In line with notice 317, HMRC has given general approval to the following charitable and philanthropic organisations:

  • those registered by the Charities Commission or the Office of the Scottish Charities Regulator
  • state organisations which are devoted to welfare
  • the following, as long as they are non-profit making and their objective is the welfare of those in need:
  • hospitals
  • youth organisations
  • clubs, homes and hostels for the aged
  • orphanages and children’s homes
  • organisations set up for the relief of distress caused by particular disasters in the Customs Union
  • organisations concerned with the relief of distress generally (such as the British Red Cross Society or the Salvation Army)

If the importer is not sure whether or not it falls within the categories above, it can request confirmation by contacting the National Import Relief Unit (NIRU) by email  niru@hmrc.gov.uk.

Goods can be imported on behalf of one of the organisations if they are to be donated or sold (directly or indirectly) to them. The importer must have arrangements in place to sell or donate the goods to one of the organisations at the time that they are imported into the UK.

If the importer is importing goods on behalf of one of the organisations listed, it will need to get authorisation to claim this relief from NIRU. Importers can email niru@hmrc.gov.uk for an application form.

If the goods have been imported on behalf of another organisation,  the importer must obtain and retain satisfactory evidence that demonstrates the end user of the goods was one of the eligible organisations. This evidence must also allow HMRC to trace the goods from their initial import through to their ultimate end use by one of these organisations.

Failure to provide this evidence, may result in the importer being required to pay duty and import VAT.

If the importer is a disaster relief agency, and are importing the goods for free circulation to meet its needs during the coronavirus outbreak, it can also claim relief.

This relief applies from 30 January 2020 until 31 October 2020.

Importers can obtain relief on imported goods for free circulation that are:

  • for distribution free of charge to those affected by, at risk from or involved in combating coronavirus (COVID-19)
  • to be made available free of charge to those affected by, at risk from or involved in combating the coronavirus outbreak, while remaining the property of the organisations importing them

The relief only applies to imports of protective equipment and other relevant devices or equipment for the coronavirus outbreak.

Use the following link to the GOV.UK website where the COVID-19 Commodity Codes List can be accessed, which contains details of what goods the relief can be claimed on.

Goods imported into the UK for donation or onward sale to the NHS are also eligible for relief and can be imported free of import duty and import VAT.

Relief can also be claimed by a disaster relief agency that is importing goods for free circulation to meet its needs during the coronavirus outbreak.

If the goods are loaned, hired out or transferred to an organisation eligible for the relief, the relief will remain in place as long as the conditions continue to be met.

This relief cannot be claimed if the business stops using the goods in relation to those affected by coronavirus. The business cannot loan, hire out or transfer these goods, for consideration or free of charge, unless HMRC has received advance notification.

Businesses will be required to pay import duties and VAT if they loan, hire out or transfer their goods to organisations or individuals not affected by the coronavirus outbreak.

Businesses claim relief by entering the following information when the import declaration is made via CHIEF:

  • box 37 ― enter customs procedure code 40 00 C26
  • box 44 (declaration / notes) ― enter document codes 9AID and /or 9AIV and status codes JP or UP as appropriate

On a final note, businesses cannot use this relief in respect of goods already located in the UK, and VAT must be charged on these supplies in the normal way.

Importers should check whether it is possible to apply a zero rate of VAT to imports and sales of PPE. This could apply if the business imports or sells PPE and does not meet the criteria to claim relief for import duties and VAT. More guidance is in the 'Other VAT measures announced by HMRC' on this site.

Customs authorisations, export and import measures

See the Customs authorisations during the coronavirus (COVID-19) guidance published by HMRC for details of the temporary changes to customs policy and authorisations to assist businesses during the coronavirus outbreak.  

See the Moving goods through customs during the coronavirus (COVID-19) guidance published by HMRC, which covers exports less than €3000, delays during transit of goods and estimated supplementary declarations (though this excludes SDs with excise) to assist businesses during the coronavirus outbreak.

See Notice 826: tariff preferences ― imports, which includes details of the temporary changes made by HMRC. HMRC will allow preferential tariff rates to be claimed based on a copy, including electronic copies, of the original preference certificate held by the declarant without the need to lodge a security. This applies to certificates issued since 1 March 2020 and until the restrictions are lifted. Original certificates to support all imports at preferential rates will need to be submitted when the coronavirus restrictions are lifted. The notice has also been updated to state that it is now acceptable to complete a movement certificate online and send it to HMRC by email. Businesses can also to apply for, and receive, copy preference documents from HMRC via email when exporting goods under the UK and EU's preferential trading arrangements.

HMRC has also updated Notice 812: European Union Preferences ― trade with Turkey to state that it is now acceptable to complete a movement certificate online and send it to HMRC by email.  Businesses can also to apply for, and receive, copy preference documents from HMRC via email when exporting goods under the UK and EU's preferential trading arrangements.

It is now possible to download an interactive PDF version of the Movement Certificate EUR-MED (C1300) that is used to record preferential trade in goods between the UK and participating countries.

It is now possible to download an interactive PDF version of the Movement Certificate EUR1 (C1299) that is used to claim preferential duty rates on goods exported to countries that have a preferential trading agreement with the European Community.

It is now possible to download an interactive PDF version of a Movement Certificate A.TR (C1232) to complete to record the movement of goods between the UK and Turkey.

HMRC has announced that it is not possible for businesses to submit forms to the National Import Reliefs Unit by post. All forms and other correspondence need to be emailed to niru@hmrc.gov.uk. Businesses should include their EORI number on the correspondence, and it is not necessary to provide the business’ name and address.

Exporting personal protective equipment during coronavirus (COVID-19).  During the coronavirus outbreak anyone wanting to export personal protective equipment (PPE) to areas outside the EU and EFTA member states and certain other territories will temporarily need a PPE licence.  However, goods exported from the EU after midnight on Monday 25 May 2020 no longer require an export authorisation. The European Union export authorisation requirement for PPE products (Regulation 2020/568) expired on 25 May 2020 and will not be extended.

Delaying import VAT and duty payments

The CIOT has received a message from HMRC regarding deferring import VAT and customs duty for businesses that are struggling to pay as a result of the coronavirus outbreak. The contents of the message have been provided in full below:

Duty deferment account holders

‘If a duty deferment user is facing severe financial difficulties as a direct result of COVID-19 and is unable to make payment of deferred customs duty and import VAT due on 15 May they should contact HMRC to request an extension. They will be asked to provide an explanation of how COVID-19 has impacted on their business finances and their cash flow.
Duty Deferment users who had a payment extension agreed for their April payment should email the Central Deferment Office: cdoenquiries@hmrc.gov.uk. The email should confirm that the payment extension is being requested for the May payment due to COVID-19 and should also indicate that their financial situation remains the same (or has worsened).
All other requests can be made by contacting the Central Deferment Office at the email address above, or by phoning 03000 594243 or the COVID-19 helpline on 0800 024 1222. The helpline operating hours are between 8am and 4pm Monday to Friday (excluding bank holidays).
Duty Deferment Account holders will be able to use their accounts during the extended payment period agreed unless they default on a subsequent payment in that period, in which case HMRC may consider suspending their account. The outstanding payment will not affect their duty deferment limit so they will not need to increase their guarantee to cover the outstanding payment.
Where HMRC agree to an extended payment period, interest will not be charged on the outstanding payments provided they are paid in full by the agreed date.
HMRC can only arrange Duty Deferment extended payment arrangements with the Duty Deferment Account (DDA) holder.  Where a customs agent or intermediary who holds a DDA is granted an extended payment arrangement, HMRC would expect the agent to pass on the benefit of the additional time to pay to the importer if the payment arrangement was agreed on the basis that they’ve been unable to secure payment from an importer.
Separate arrangements are available for deferred excise payments. Businesses unable to pay excise duty owed to HMRC due to COVID-19 should contact the COVID-19 helpline to on 0800 024 1222 discuss an enhanced Time to Pay arrangement.’

Duty / import VAT payments not covered by a duty deferment account

‘Registered importers who pay cash or an equivalent and are facing severe financial difficulties as a direct result of Covid-19 can contact HMRC to request an extension to the payment deadline at the time the payment is due. They will be asked to provide an explanation of how Covid-19 has impacted on their business finances. HMRC will consider this request and decide whether or not to agree an additional time to pay. The decision will be taken on a case-by-case basis and could be refused.
If the request is approved, the conditions, including the length of time offered, will depend upon the importer’s individual circumstances and may require the holding of a guarantee for the period of the time extension. We cannot offer this facility to non-registered importers. For further information, please contact the Customs Debt Policy inbox (custdebtrr.customspolicy@hmrc.gov.uk).’

Conditions for zero rating: exports / removals affected by the coronavirus emergency

HMRC has published updated guidance in VEXP30310 in which it states that it realises that it may not be possible for businesses to either export or remove goods within the prescribed time limit due to coronavirus, meaning they have become liable to account for VAT on the supply. HMRC has extended the time limit to export goods for businesses that have been adversely affected by coronavirus, and the guidance provides details of when the extension can be applied and the conditions that need to be met.