“you need a suppliers declaration proving the origin of goods"

Greetings We are a small company ( 2 in the warehouse, 2 in the office). We are confused by HMRC emails saying “you need a suppliers declaration proving the origin of goods, when exporting form UK to EU ” . The electronic valves that we supply , were made 40 years ago. The companies who made them are closed down .Customs tariff for valves is 8540810000 Can you advise me how I can provide paperwork to “prove the original manufacturing country for the goods” . WE cant be the only UK company exporting vintage made items to the EU :-) Best regards Martin Billington

Hi,

Suppliers declarations help support a commodity's origin. They are particularly useful when claiming EU-UK preference.

If you’re exporting goods you may need to get suppliers declarations from your UK suppliers to prove the origin of materials used in the manufacture process, or for finished products that you buy and re-export. When a customs declaration is completed, this is a declarants confirmation that the country of origin is correct to the best of their knowledge. 

This includes when you:

• have not changed the tariff heading of the materials (where as a result of processing, the final product must be classified under a different heading)
• have exceeded the specified limit on the value of the non-originating materials, you’ll need a suppliers’ declaration to cover the value of materials in excess of the limit for the value of the materials that is over the specified limit
• manufacture using materials at a later stage of production than that specified
• only carry out minimal operations 
• buy and export goods in the same state

Using a suppliers’ declaration to support a proof of origin

Thank you.

Hi Martin784961. To add to HMRC's comments Suppliers declarations are only required if you are making a declaration of ' UK preferential origin' when trading under a trade agreement the UK has concluded such as the one with the EU. This can only be used if the goods qualify and would allow your customer to claim zero or reduced duties at import. It is not an obligation to use the trade agreement or provide the statement on origin provided for in the agreement. It is likely with old goods that you cannot meet or provide proof under the rules of origin requirements for the goods under the trade agreement they can still be traded, but they will not be able to benefit from a reduced rate of Customs Duty. Whatever the standard or MFN rate of duty would apply to your product at import ( EU duty for ccommodity8540810000 is 2.7%) . You will however still need to state what country the goods were manufactured in on your invoice.

HMRC admin 2 . thanks fr your reply, I do appreciate it. However …… Think of me as an antiques dealer. The valves were manufactured 40 or 80 years ago. A lot of the stock on my shelf is valves I purchased 5 years ago, or even 15 years ago. When I bought it , eg 5 years ago, it’ was usually one of the following sources. Probate sales, Company close down The general public, selling private collections , who cannot answer question about “origin of the materials. “ . They may have acquired a collection over several decades. Other UK firms export vintage made items to the EU (Antiques?: collectibles ? car parts? ) . what do they do ? More thoughts welcome

Old timer. thank you! Yr thoughts are a breath of fresh air .........

Hi Old timer Many Thanks again for yr helpful words. By any chance do you know where i can find words similar to the below, but in a more formal setting. Eg website belonging to HMRC , a chartered accountant etc. I completely believe you, but all them others …. kind regards Martin Billington Export Ltd “Suppliers’ declarations are only required if you are making a declaration of ' UK preferential origin' when trading under a trade agreement the UK has concluded such as the one with the EU. It is not an obligation to use the trade agreement or provide the statement on origin provided for in the agreement . It is likely with old goods that you cannot meet or provide proof under the rules of origin requirements for the goods under the trade agreement they can still be traded, but they will not be able to benefit from a reduced rate of Customs Duty.”

Hi Martin The importer or their customs broker/ agent would need to actively claim preferential duties for UK Origin goods which they cannot do if proof isn't provided. The default position would therefore be full duty rates irrespective of the country of origin including the UK. You may find this useful https://www.gov.uk/government/collections/rules-of-origin-for-goods-moving-between-the-uk-and-eu#rules-for-small-consignments-of-goods There is a paragraph just before the ' documents' heading that mentions that certifying origin is not required if you don't want to claim reduced or nil duties. Non preferential origin of goods is covered in both UK and EU customs legislation but unfortunately both are silent on situations where you don't have or can't get manufacturing information. If there are some 'made in' markings or manufacturer information on the items that may prove useful. As I said the same EU duty rate applies for all countries but it is impossible to make a customs declaration without stating a country of origin. If preference isn't being claimed or unless the goods are subject to some sanction quota or restriction the origin declared is generally accepted.

Hi
 

martin784961,

Thank you for your follow up query. Unfortunately, there is no further information that can be provided in relation to the previous response provided. I would advise you to contact our written enquiries team who will be able to assist you further.   Write to HMRC for help with questions about importing, exporting and customs reliefs. HM Revenue and Customs - CITEX Written Enquiry Team Local Compliance S0000 Newcastle NE98 1ZZ United Kingdom Include your VAT registration number and the name and postal address of your business. Thank you.