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Posted Tue, 03 Nov 2020 12:10:20 GMT by MonikaKW
I have a question about customs and VAT liability after Brexit. We are a retailer and use dropshipping from an EU country. The process looks like this. 1. A customer in the UK places an order with us . 2. We place an order for this item with the dropshipper. 3. The dropshipping company from EU sends the item directly to our UK customer and issues an invoice to us. Majority of our customers are non-business. The dropshipper ships with courier service (DPD, GLS). We are now unsure: 1) Who is liable for customs duties? Are we the importer of records so we should pay them? Or is the final customer liable? 2) Who is liable for VAT (supply or import) - are we correct in thinking it is us?
Posted Thu, 26 Nov 2020 10:40:30 GMT by Paul Campbell
Same question. I've just been on an HMRC support call and my question was the only question not responded to so I am guessing HMRC have no idea on the answer
Posted Wed, 02 Dec 2020 14:27:35 GMT by HMRC Admin 11
Hi MonikaKW, 

Firstly can I just apologies for the delayed response. 

‘Consignee’ includes any owner of the goods or any other person possessing, or beneficially interested in them at any time between their importation and their clearance by customs or the person to whom goods have to be delivered.

As for the liability, there’s guidance on this page:

Customs debt liability

Please refer to the following guidance on

Changes to VAT treatment of overseas goods sold to customers from 1 January 2021: Goods located outside the UK at the point of sale

Under the section headed ‘Goods located outside the UK at the point of sale’ it establishes that for most consignments not exceeding £135 in value, instead of VAT being collected at importation or delivery to the customer, VAT will be accounted for at the point of sale.

This means that the following types of businesses will have to register for UK VAT (if not already registered) and account for VAT to HMRC:

• any business that operates an OMP (Online marketplace’s) that facilitates sales of goods to UK customers.
• any business that sells goods directly (without OMP involvement) to UK customers where the goods are (a) outside UK at the point of sale (b) imported to the UK in consignments not exceeding £135 in value. 

Thank you.
Posted Mon, 11 Jan 2021 18:40:15 GMT by Szczepan
Thank you for that. I need some further help though. So in the scenario: I sell on online marketplace Sell on my marketplace Purchase parcel with delivery to customer If less than 135 gbp there is only Vat to be paid which we have to register for. Parcel gets delivered This is fine but it is causing an issue - the purchase invoice needs to be attached to the parcel for customs to see and the customer as well. This is then becoming not profitable dropshipping business as we will lose customers. Could you advise me on scenario NR. 2 I sell on marketplace I get order delivered to my warehouse - value less than 135 gbp I change invoice to UK invoice and attach it to the parcel. I send the parcel to customer. Does that make me an importer and do I have to register as one? Thanks!
Posted Wed, 13 Jan 2021 13:53:26 GMT by HMRC Admin 8
You can find further guidance here:
Brexit: new rules are here
UK distributors and suppliers:
You’ll need to confirm whether you or your supplier will act as an ‘importer’.
You’re an importer if you’re the first one bringing goods from outside the UK and placing them on the market in Great Britain.
If someone has already placed a good on the UK market before you sell it in Great Britain - or if the manufacturer has appointed another UK-based person to carry out importer duties - you will remain a distributor and will not have any additional responsibilities.

As an importer, you’ll need to make sure that:
• goods are labelled with your company’s details, including your company’s name and a contact address. Until 31 December 2022 you can provide these details on the accompanying documentation rather than on the good itself if you import certain goods from the EEA (and in some cases Switzerland).
After 31 December 2022, your details must be affixed to the product or, in circumstances where the legislation allows, on the packaging or an accompanying document
• the correct conformity assessment procedures have been carried out and that goods have the correct conformity markings
• the manufacturer has drawn up the correct technical documentation and complied with their labelling requirements
• you maintain a copy of the declaration of conformity for a period of 10 years
• goods conform with the relevant essential requirements
You must comply with the above for goods placed on the GB market regardless of whether they are CE or UKCA marked.

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