2. 2015 Grant Thornton UK LLP. All rights reserved. The Union
Customs Code A guide for UK business
3. 2015 Grant Thornton UK LLP. All rights reserved. Union
Customs Code What is which UK business is affected? Businesses
involved in global trade in goods will be affected by UCC changes.
Manufacturers, exporters, freight forwarders, warehouse-keepers,
clearance agents, carriers and importers should all assess how the
UCC will impact them. This impacts UK businesses trading
internationally and: Paying customs duty Importing and/or exporting
Storing goods in warehouses 'under bond' Processing raw materials
into something else without paying customs duty. The UCC
(Regulation 952/2013) entered into force on 30 October 2013 but
will only be applied as of 1 May 2016.
4. 2015 Grant Thornton UK LLP. All rights reserved. What are
the key changes? Mandatory financial guarantees for special
(customs) procedures and temporary storage. Focus on Authorised
Economic Operator (AEO) certification. Impact on customs
authorisations. The removal of the earlier sale provisions relating
to customs valuation.
5. 2015 Grant Thornton UK LLP. All rights reserved. Financial
guarantees This will apply to an estimated 20,000 existing customs
authorisations in the UK, where a guarantee is not currently
required Transitional arrangements for guarantees and customs
authorisations Existing guarantees for potential debts will be
reassessed by Customs until 1 May 2019 Current authorisations will
need to be reviewed (expiry date vs reassessment) All customs
duties which are potentially due through the operation of a customs
duty relief scheme or suspension regime, must now be secured by a
guarantee.
6. 2015 Grant Thornton UK LLP. All rights reserved. Authorised
Economic Operator (AEO) Becoming accredited with HMRC as 'AEO'
before 1 May 2016 means: A full financial guarantee waiver (for
potential duty) Partial guarantee waiver (actual duty) Your
authorisations to use customs warehouse under bond and processing
relief will be renewed post 1 May 2016 Enhances the business's
reputation as a 'trusted partner' Recognised status
internationally, can speed up international supply chain and
logistic processes
7. 2015 Grant Thornton UK LLP. All rights reserved. Earlier
sales, customs warehousing Loss of first sale/ earlier sale Earlier
sale facility will be withdrawn and replaced by a last sale only
rule. This means that the customs value must be declared on the
price payable immediately before entry into free circulation.
Impact on customs warehousing Loss of first sale facility also
means that customs value must be based on the last selling price
before removal of goods. A transitional period until 31 December
2017 is currently proposed to businesses A business contract with
your supplier, linked to the import and requiring use of earlier
sale value must be in place as early as Spring/Summer 2015. Any
mark-up and profit would need to be included, inflating the customs
value, where goods are sold before removal from a customs
warehouse.
8. 2015 Grant Thornton UK LLP. All rights reserved. How to
prepare for upcoming changes? May 2016 is not a long way ahead
However, any business contemplating AEO as a strategy to prepare
for the UCC changes should place this high on the agenda for 2015
Strategic customs planning and collaboration are vital General
recommendations Identify the key areas that are affected (such as
customs warehouse, royalty agreements) Determine the risk level in
order to prioritise and build your strategy Review and amend those
areas in order to minimise any potential risks of non- compliance
Monitor any upcoming changes How Grant Thornton can help
Cost-benefit analysis of UCC changes Risk reviews Remediation of
gaps encountered Assistance with writing or updating processes and
procedures Completion and submission of your AEO application pack
Liaison with HMRC Designing and implementing a monitoring programme
Providing a regular update service on UCC
9. 2015 Grant Thornton UK LLP. All rights reserved. Contact
details For further details please contact one of our team members
below, or your usual Grant Thornton contact. Ian Worth Customs
Associate Director T +44 (0)20 7728 2174 E [email protected]
Ilektra Sarri Associate T +44 (0)20 7728 3437 E
[email protected]