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Posted Thu, 09 Sep 2021 13:58:28 GMT by Danielleh
We have a scenario where goods manufactured in Bangladesh and Pakistan, eligible to use the Generalised System of Preference scheme are imported into a Customs warehouse in the UK. They are then consolidated and split into consignments, depending on the final destination. Some goods are entered into free circulation into the UK (duties avoided using GSP documents), or some are sent onto final customers in the EU, Customs cleared in the Netherlands (these goods have not entered free circulation in UK and remained under Customs control the entire time). The goods which are sent to Netherlands are currently paying full duties, and not benefiting from the EU GSP scheme. We have been informed by a Customs agent that Dutch Customs are requesting a certificate of non-manipulation or similar type document, issued by a UK authority. According to the Customs Advisor in the Netherlands we have consulted, this would require a statement of non-manipulation from the UK company to be approved/stamped by HMRC Does HMRC offer this service? If not, what do you suggest we state when a certificate of non-manipulation issued by a UK authority is required from the Netherlands? Is there a way we can raise this issue to the attention of HMRC/DIT if you do not currently issue this document or approve them? Thank you
Posted Tue, 14 Sep 2021 09:53:44 GMT by HMRC Admin 2
Hi,

Originating goods must be the same as those which left the country of export.

Goods can move through or be stored in countries not in the agreement and if consignments are split or domestic legal requirements (such as labelling) are carried out, the goods must remain under customs supervision. 

The importer may be required to submit evidence, for example: 
  • a single transport document
  • a certificate of non-manipulation issued by the customs authorities of the country of transit 
  • factual or concrete evidence based on marking or numbering of packages
If the goods were transported from a feeder vessel and then consolidated with other consignments in a seaport, then there should be a transport document (for example, a bill of lading) for each leg of the journey.

You can find further guidance here: 

Check your goods meet the rules of origin

Claiming preferential rates of duty between the UK and EU

Thank you.
Posted Tue, 14 Sep 2021 10:30:33 GMT by Danielleh
Hi Thank you for the response. You have specifically stated that a form of evidence is: a certificate of non-manipulation issued by the customs authorities of the country of transit Question: Does the UK Government (e.g. HMRC, DIT etc) issue a certificate of non-manipulation for goods which are in transit in the UK? I have asked DIT and been referred to HMRC, therefore that is my very specific question (not another copy/paste of already available information, which I have taken the time to read already). If the answer is 'no' it would be good if this is formally included in HMRC online guidance (as referred to above), so that if a request is made by an importing EU Customs authority, traders can show that the UK does not issue this document. This will ensure the Customs authority does not demand one as mandatory, which is what we find happens today. Thank you
Posted Wed, 22 Sep 2021 14:19:01 GMT by HMRC Admin 2
Hi,

It is up to the EU customer to consult their own EU member state’s customs authority to establish what they need in order to claim preferential rates of duty.

It is for that EU customs authority to state whether or not they require a certificate on non manipulation from the UK customs authority.

This process may not be pre-empted to attempt to support a claim for preference.

If they do so then the request to HMRC should be directed towards:

dutyliability.policy@hmrc.gov.uk

That team will issue it’s own statement if required.

Thank you.

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