Deferring customs payments

I have a small online fine jewellery business. We have contacts from various countries that will regularly send us goods. These vary from loose diamonds to completed jewellery pieces. Some of these suppliers are able to send us goods on a 'sale or return basis' meaning we return anything we don't sell. Occasionally, we may order pieces where we are not happy with the quality and may want to send back. In these example circumstances, it won't make sense to pay the import duty or customs payments, as we won't be keeping the items. Are we right in thinking, that to allow goods temporarily into the country, we need to apply for https://www.gov.uk/guidance/apply-to-import-goods-temporarily-to-the-uk-or-eu Or would we be looking for another scheme? In anticipation of this being the correct scheme to apply for, we requested a Customs Comprehensive Guarantee number. HMRC have approved this but have requested we ask our bank to agree to be a guarantor. Unfortunately our current bank isn't on the approved PRA list of financial institutions. In order to be granted the Customs Comp Guarantee number, we are willing to find an approved bank account immediately, however I am still uncertain as to why a bank would be willing to be a guarantor for us. I don't want to go ahead and find a new approved bank account, only to be told they are not willing to guarantee this. Any advice on how to proceed? We can't be the only new business that needs to import goods temporarily to check stock quality, inspect goods, return if not sold etc.

Hi You can only use temporary imports scheme for the specified purposes permitted by the scheme. If you are a UK established company a comprehensive guarantee is only required if HMRC specifically tell you one is required. It may be that you don’t need a guarantee at all but are eligible for a guarantee waiver. If a guarantee is required HMRC publish a list of acceptable guarantors , it does not have to be a bank that acts as guarantor , some insurance companies also offer the service. They and the banks will charge for the service . This is common. The alternative is to pay duties on deposit when claiming TA and reclaim when the goods are reexported. If the goods are found to be faulty or not in accordance with contract after import and you have paid duty you would usually need to put in a rejected import claim in those circumstances.

Thank you. The reason we are applying for the comp guarantee is because we couldn't apply to temporarily allow goods in to the country without one. It asked for a CCG number while we were applying. The CCG has been approved but struggling to complete the next step, guarantor. In your experience, what would be the best method to avoid paying import tax on pieces we are only going to quality check or photograph, then return? I believe photography is a reason to allow temporary imports. Are you saying, other than this, our best bet is 'to pay duties on deposit when claiming TA and reclaim when the goods are reexported.' All help appreciated. Many thanks.

Hi,
Unfortunately HMRC are unable to comment on status of guarantors and their requirements.
A customs guarantee is an agreement to cover customs debt that has arisen, known as actual debt or will arise from certain customs special procedures, known as potential debt.
You must get authorisation to use a customs comprehensive guarantee if you have full authorisation to put goods into customs special procedures (inward processing, temporary admission, or end use).
Thank you.

Hi The TA authorisation asks if you have a CCG, it’s a yes or no answer. If you answer no you give a reason. Only If you answer yes will it ask for the number . look on the link on the TA guidance whether you need a guarantee https://www.gov.uk/guidance/import-and-export-customs-comprehensive-guarantees-ccgs To quote: “You’ll not need a customs comprehensive guarantee unless we tell you one is required when you apply: -for full authorisation to put goods into customs special procedures (inward processing, temporary admission, or end use) -to operate a temporary storage facility or customs warehouse” So unless HMRC have instructed you that you specifically need a guarantee such as if you are an overseas business or a poor compliance record then one isn’t needed for most UK businesses. Contrary to what HMRC Admin 8 has said, since Brexit a CCG is no longer required for most special procedures. If security is required then the alternative to a CCG or single guarantee is a cash deposit at time of import .

Thank you both, In that case, can I potentially return anything and claim the import duty back on ANYTHING if I don't want to keep it? For example, I order a piece of jewellery from overseas and I pay the import duty for it to arrive in the UK. However, the quality isn't up to standard so I want to return it. To claim the import duty back do I just use a C285 (or equivalent) form? If so, are there any stipulations to be aware of? Eg, item value, time limits etc? Thank you.

No that is not what is being said. Temporary Admission is a very specific type of import and still requires authorisation. It is just the guarantee part that isn’t necessary required. If you pay duty and the goods are rejected as faulty ( not just because you don’t sell them or don’t like them ) then you can reclaim duty using a c&e 1179 which must be submitted 48 hours prior to a reexport not a c285.

Just to add if you use temporary admission and don’t reexport then you need to actually arrange for another import entry to pay the duty, There is no automatic right to a refund of duty just because you reexport something . If you do make a reclaim it can only be for one of the specified reasons.

Ahh I'm stumped then. As I applied for the temporary admissions and they categorically asked for a Comp Customs Guarantee number as part of the application. I therefore couldn't progress any further into the application without one. I cannot find a definite answer anywhere as to how businesses import items from overseas just to look at, before returning and avoiding import duty in the process. Is this even possible?

There should be the option on the application to say no you have not got a customs guarantee. It will usually only ask you for a CCG number if you answer yes. If you are struggling with the online application use the print and post version instead. TA is the option for examining goods prior to purchase. You can make a reclaim by invalidating the customs entry within 90 days if you reexport goods . This sort of claim can be on a C285. Unfortunately there is no easy way round this.

Hi,

The time limit for submitting a claim for repayment of overpaid duty and VAT and what is required for the claim is covered in below guidance.

How to claim a repayment of import duty and VAT if you've overpaid: When to apply

Thank you.