Import declarations by couriers (imports into GB from the EU)

I receive my monthly MSS imports data from HMRC. This includes details of import declarations made by carriers such as FedEx, UPS, and DHL. The carriers claim preference on goods imported into the UK from the EU even where there is no statement of preferential origin. They do this without checking with me first. I have continually queried this with them, as I want to ensure that I am compliant with the customs rules, but they generally ignore my emails. I have finally received responses from two of the couriers: FedEx: "In the instances of good made in the EU valued below £1000, FedEx can apply duty waiver without preferential statement." UPS: "The brokers are instructed to use Importers knowledge up to 1000 GBP without permission" Is what the couriers saying correct? Is there any published guidance regarding this? I've struggled to find anything so far. What should I be doing where I do not have the relevant paperwork to demonstrate that the goods have EU preferential origin? Are there any wide exemptions that mean that I should effectively ignore the duty issue on goods being imported into GB with a value of £1,000 or less?

Most agents will apply the preferential rate automatically, we advise our customers to advise us when they DO NOT want us to apply it. They are correct that for small shipments with a total value of less than £1000 you do not need to prove origin. Search for 'proving originating status' on GOV.UK for more info. For larger shipments there should be a statement of origin on the suppliers invoice and if the value exceeds 6000euros the supplier must be a registered exporter and show their REX number. If these rules do not apply then preference can be claimed under importers knowledge which means you would need to prove origin if questioned by HMRC.

If the goods are below £1000 and the invoice shows an EU country as the country of origin there is not a requirement to show the full statement on preferential origin. There are a number of exceptions in the trade agreement (Article 60) including Small packages between private persons Traveller’s personal luggage Low value consignments (value to be set under uk law) The domestic law that sets £1000 is the Customs (Origin of chargeable goods :Trade preference scheme) (EU exit ) Regulations 2020. The UPS answer is technically incorrect as this is not importers knowledge.

I would strongly warn against using importers knowledge unless you have a really good relationship with the supplier. It shouldn’t be treated as a fallback option if you don’t have proof of origin at the time of import. There is a long list of proof you as importer need to hold to demonstrate that the goods meet the origin requirements if HMRC want to verify the preferential origin.This includes knowing the manufacturing process , cost of materials, how the goods met the product specific origin rules etc. As much of this information is commercially sensitive many suppliers will not provide all the info you need. To quote guidance : If the importer cannot get the information, including when the exporter or producer does not provide the information because it is deemed commercially sensitive, preferential tariff treatment may still be claimed if the exporter issues a statement on origin.

Just to add, that importers cannot use importers knowledge then change to statement on origin or vice versa.

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

I strongly advise against relying on the importer's knowledge unless you have a well-established relationship with the supplier. Using their knowledge should not be seen as a backup option if you lack proof of origin during the import process. To demonstrate compliance with origin requirements, as an importer, you are required to maintain a comprehensive set of proof. This includes understanding the manufacturing process, material costs, and ensuring adherence to product-specific origin rules. However, it's important to note that suppliers often withhold certain commercially sensitive information, making it difficult to obtain all the necessary details. For more detail read this blog [link removed by admin]

The problem is that the FPO just do as they like to clear the goods, as fast as possible and have no regard for any origin issues. Added to this I find in most cases the first we know about such an import will be when it appears on the MSS. The FPO do not ask how we want to clear, someone in the factory orders a part from our UK agent then we find it has been posted from an address in the EU. The parts just arrive and by then it is too late to say please don't use importers knowledge! HMRC should be taking this up with the FPOs to get a uniform approach.