1. The UK company has a GB EORI and is aware of the delivery

2. The importing company has a UK Deferment Account (or one in place by the time the full declaration is submitted)

3. At the time of arrival all import details are recorded by the importing company into their own records (known as transitional EIDR – entry into declarant’s records) to enable a full declaration to be submitted at a later date, no later than 175 days of goods arrival in the UK

4. VAT is calculated by the importer and included on the relevant quarterly VAT return linked to the date of physical arrival.

5. A full customs declaration and payment of import duty will be made no later than175 days of the goods arrival.

1. Deliveries from the EU have required import declarations into the UK since January 1st, 2021, but not necessarily at the time the goods crossed the border. 

2. A UK business is responsible for import declarations on goods they have received unless they know that the sender has been able to complete the import formalities. Which would require an EU company to have a GB EORI and be able to pay/account for import VAT.

3. An Incoterms ® Rules used on a purchase order may indicate whether the UK business is responsible for import formalities. Only a DDP (Delivered at Place) term could make the supplier responsible for the import procedures, and even then, you must check they are able to fulfil this obligation

4. So, though a UK business may not have control of the physical movement and delivery of the goods they will generally still be responsible for import formalities, the payment of duties and VAT.

• If your business has received goods delivered from an EU member state at anytime from the beginning of 2021, investigate how the goods crossed the border and consider your regulatory obligations. The Customs Information Paper explains the next steps from an HMRC point of order.

• Compare the order book against goods that have been delivered. 

• Compare your goods inward records to see what has physically arrived from the EU

• Check if there is someone in your business who instructs freight companies to complete import customs declarations and check if all physical arrives have the corresponding paperwork 

• Consider registration for the monthly MSS Reports (HMRC Management Support System). The reports represent an invaluable source of information from HMRC of all recorded imports and exports made against a UK business’s GB EORI. There are 2 standard reports available, one for imports the second for exports: each report is £240. These reports can represent a substantial data source for compliance evidence if used as part of a UK trader’s compliance processes. This will help you check physical arrivals against imports that have been declared to HMRC as only imports that have been declared will appear on this report. The ones not showing are the ones to investigate. Registering for the reporting period from 1st January 2021 should capture all imports made against a GB EORI.