In this exclusive article, Mike Court shows us that life as an international trade compliance expert is often anything but ordinary!
I have been an international trade advisor for more than 8 years, working with International Trade Matters Ltd for 6 of them. During this time, I have engaged with a wide range of clients with diverse requirements, from human hair extensions of Mongolian origin to frozen, European milk whey. No two days are the same, whether I’m getting stuck into an audit or delivering a training course.
To to start my week I was in discussion with a new company processing frozen milk whey from Italy in the UK, to place on the UK market. The conversation was around tariff code import duty and VAT. As the product was classed as a food ingredient, there was nil import duty or VAT as long as the supplier indicated the goods were of EU-Italian origin.
Later, I took an enquiry from a client shipping goods from China in containers direct to the West Coast of the USA. Their US Import bond had been cancelled and they needed to know how to re-establish the US Import bond and how that would impact their in transit shipments.
I was in discussion with an electronics company having issues with their Import/Export Customs declarations. This was due to a third party customs agent making mistakes on their customs declarations leading to overpayment of both Import duty and VAT. The second issue was on the collection of proof of Exports from the same freight agent.
I directed the client to HMRC to start the process of having the original import entry cancelled and a new correct customs document to enable a refund. After several calls to the freight agent, the client was provided with the proof of export that is required for all UK exports to support their zero-rated commercial invoices.
It is important to remember that even when you’re paying another company to take care of your freight logistics, not having the skills and checking the declarations and paperwork in-house can be costly.
I travelled to Wales to carry out a customs audit on a manufacturing and distribution company. This involved a very detailed set of audit questions, whilst gathering the documentary evidence to prove that their systems and personnel are following HMRC requirements with their imports and exports.
I was working with a company exporting aviation equipment. They wanted to establish a process for clients to return products for updates and alterations before re-exporting to them. I explained that the business should work out how many times per year they were doing these types of transactions and if they established that they were doing this more than three times per year, they would need a Customs Special Procedure Inward Processing to be able to defer the import duty and VAT on the returned products.
A very interesting day indeed. I was asked to provide details on two up-and-coming UK/EU legislation changes for different clients.
- Firstly, a detailed explanation and a time frame for the Carbon Border Adjustment Mechanism (CBAM) legislation which is due to enter UK law over the next 2 years, along with the financial implications and reporting requirements for the UK entity. This legislation will certainly add considerable cost to UK Imports and the requirements to capture data from suppliers will add to the general admin tasks.
- Secondly, to provide detailed advice on the UK-Russian ongoing sanctions and the requirements that UK businesses need to start to capture raw material origin from their suppliers. This does mean that Importers will need to obtain, not only the origin of the products imported, but also the origin of the raw materials the parts are made from. This updated legislation will also involve admin collecting this data either by having suppliers providing long term agreements or by mill certificates to prove evidence of the origin of the raw materials.
So here we are, at the end of another busy week. If you’ve got any queries like those above, I’d love to hear from you.
Here’s Mike’s top tip for international trade:
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