Being importer of record without property

Currently we (FR Company) are exporting and importing goods into the UK (B2B). We were supposed to go through an indirect representative to act as importer and deal with the customs. But our client notified us with a possible problem : the transfer of property is done before the export of the merchandise contractually, and that it would make the UK company automatically the IOR. Does the transfer of property have an effect on the IOR and what are the effect it would have ?

Hi It will depend upon what you agree with your customer and often will be in line with the Incoterms you agree. It is normal practice for the IOR to be the company based in the importing country (UK) using a direct representative. As the UK company seems willing and they own the goods at the moment of import it would make sense for them to be the IOR. It is more unusual and more difficult for a non UK company to be IOR. As you say as a non UK company needs an indirect representative, which may have been difficult for you to find. I assume that as you are already importing you have found one of the rare indirect representatives, and already have a UK EORI and probably VAT registration too. It should be borne in mind that only the owner or purchaser of the goods can reclaim the import VAT, so another reason why as a non owner it would not be advisable to be the importer.

Hi
I would advise contacting the Customs and International trade helpline on 0300 322 9434.
Thankyou.