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Posted Tue, 20 Feb 2024 10:34:04 GMT by
I have made a number of imports from China where the supplier supplies me my order in the UK under DDP terms. They use a freight forwarder, who acts as the Importer of record. I am now being asked by Amazon to provide an Import Entry Number but the freight forwarder who does the import says they don't provide this for DDP terms as they are the importer. Since I take ownership of the goods in the UK, I believe I am not the importer under these terms, is this correct? If I am not the importer, is my supplier obligated to provide a UK VAT invoice? If my supplier does not provide a UK VAT invoice, does that make me non compliant with regulations? I am 100% committed to understanding and complying with all regulations, so any advice how to move forward and rectify and mistakes is welcome. Thank you
Posted Tue, 20 Feb 2024 14:34:08 GMT by Customs oldtimer
Hi MastyCabanyal It really depends on what you , your supplier and the freight forwarder have agreed . There are many interpretations of DDP . Some mean the supplier will just pay import duty but not import VAT . Sometimes the overseas seller will also be the importer and then make a domestic sale to their customer. Freight forwarders and couriers have DDP terms that mean they will pass on the charges to their customer but the importer is the receiver of the goods. It is highly unusual for the freight forwarder to be the importer / declarant in their own name unless they are involved in the sale. You need to find out which scenario applies and whose EORI number has been declared as the importer. If you are the importer then you will find either C79 or a Postponed VAT statement in your CDS dashboard. Perhaps the HMRC admins will add the link to get your postponed VAT statement.
Posted Wed, 21 Feb 2024 09:15:39 GMT by HMRC Admin 21
Hi MastyCabanyal,
You are correct in your understanding of this. As you were not responsible for the import, you would not have the documentation requested. This does not make you non-compliant. 
Thank you.
Posted Wed, 13 Mar 2024 01:16:18 GMT by Jeffreyqqy Adam
Dear all, I'm reaching out for some guidance regarding a matter I find myself entangled in, related to importing goods under DDP terms. As a retailer in the UK, I'm considering purchasing a batch of goods from China. It appears that the freight forwarder involved has their own EORI number and takes full responsibility for the customs declaration and duty payment process, subsequently delivering the goods directly to my doorstep. Given this setup, the freight forwarder acts as the Importer of Record, whilst I essentially take ownership of the goods once they land in the UK. However, the freight forwarder is reticent to share detailed documents related to customs duties and VAT. This leads me to a couple of pivotal queries: As I'm not listed as the Importer of Record, does this absolve me from needing import proof for these goods, allowing me to simply rely on the transaction records I possess? In the absence of detailed import documents from the freight forwarder, would maintaining comprehensive records of purchase orders, payment receipts, and contracts with the freight forwarder suffice to meet the requirements for legality and tax compliance? I place great emphasis on adherence to regulations and wish to ensure my business operations align impeccably with legal and regulatory standards. I'd be immensely grateful for any advice or guidance on how to navigate this situation while maintaining the utmost integrity and compliance. Thank you ever so much for your assistance.
Posted Wed, 13 Mar 2024 15:16:25 GMT by Customs oldtimer
Hi The arrangement you have described with the freight forwarder acting as importer in their own name is highly unusual unless they are also sales agents . It would be more typical if they were acting as indirect customs representative for the Chinese seller or more commonly representative of the UK buyer. As a representative they would still need to use their EORI, it does not make them the importer. We do not have a definition of importer of record in the UK legislation. You really need to check exactly what has been or is being agreed contractually as DDP can be interpreted quite differently particularly by sellers and buyers. Only when you fully understand the agreement and responsibilities of the various parties will you understand what is required from a tax / VAT perspective . DDP looks like the easy option for the buyer but you should also consider other Incoterms where you have control of the customs declaration and import taxes. Most frequently the seller is only agreeing to pay customs duties but not taking responsibility for the customs clearance and being the importer. Overseas sellers may not understand the UK VAT implications so the buyer is named importer and responsible for the import VAT particularly if they are VAT registered in the UK. To take one scenario, If you are not named as importer and have no contractual agreement with the freight forwarder then you would have no right to any import documents ,sight of duty payments etc as these costs should already be included in the DDP price. If this is the case you are not importing goods the seller or their agent is.
Posted Wed, 27 Mar 2024 09:23:58 GMT by HMRC Admin 19

You can refer to the guidance below to find what you or your business may need before you hire someone to act directly or indirectly on your behalf:

Check what you need to consider before getting someone to deal with customs for you

Get someone to deal with customs for you

Thank you.

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