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Friday 1 February 2013

Responsibilities under some Customs Procedure Codes



Along with the cash advantages, some of these codes make the importer legally responsible for controlling, reporting or re-exporting the goods within a set time period.  Poor use of CPCs, or a lack of understanding or control, can leave an importer open to Customs audits and potential penalties for non-compliance.  Most of the responsibilities are easy to undertake and control - the most important thing is to be aware of the responsibilities under the CPC you choose.  These are clearly detailed in Vol. 3 of the Tariff.

Following are some examples of the responsibilities that may be incurred with a CPC.
 1. You must be authorised by HM Customs before you use it.
2. Proof of export will be required when the goods arrive in the UK to allow the relief from import duty/VAT.
3. The goods must be exported within a set time period.
4. After re-exporting a duty reclaim must be made within a stated time.
5. Quarterly reports must be submitted to HM Customs.
6. Good audit records that permit tracking and tracing of imported items may be required.
7. The end-use of the goods is controlled and they cannot be diverted or scrapped without Customs approval.

Where appropriate the format of the seven digit CPC’s link the import and the export of goods, so allowing Customs to see that you have fulfilled your responsibilities.  For example:
 • Goods imported to be repaired under a simplified procedure will be entered to CPC 51-00-001. When these goods are re-exported from the EC the CPC used will be 31-51-000 - the middle pair linking the export CPC with the reason for import, i.e. 51.  The use of the correct export CPC cancelled the importer’s responsibilities.  If an incorrect CPC is used at export then the importer will have problems.

An understanding of the Customs Procedure Codes that relate to your particular activities is desirable; that is not to say that your current use of CPC’s is faulty or that your import clearing agent or forwarder is incompetent, but merely to emphasise that responsibility and control should rest ultimately in the importer’s or exporter’s hands.

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