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Freight Agents - Avoiding the Risk of Customs Civil Penalties when Arranging Exports

Freight agents act as third parties in arranging exports on behalf of exporters. These agents are advised to ask for certain information from the exporter so they do not face the risk of Customs Civil Penalties (CCPs). CCPs could apply because freight agents, as representatives of exporters, also hold responsibility for the accuracy of information in documents and/or the authenticity of documents attached to a shipment.


HM Revenue & Customs (HMRC) recommend that freight agents should routinely request the following information from exporters:


Their UK Economic Operator Registration and Identification (EORI) number (this used to be TURN) for use in box 2 of the declaration.

Details of whom the goods are to be consigned to, their name and address in full.

A commercial reference that can be incorporated into the Declaration Unique Consignment Reference (DUCR) to assist with the export audit trail.

Details of where the goods are to be exported, ie country of final destination.

Shipping or flight details (if known).

Correct value of goods and correct currency code.

The Commodity Code if known, and a clear and unambiguous description of the goods, their quantity, marks and numbers.

If the goods have been previously imported, or are later to be re-imported to a Customs Relief, you need to know so that the correct export procedure code (CPC) can be applied. If an incorrect CPC is used, it can lead to any Customs relief on Duty and VAT granted at import, being liable for payment/repayment by the exporter or yourselves. If the appropriate CPC is known, then this should be quoted on the export papers supplied by yourselves yet, as specialists, you may still wish to verify that the code quoted is correct.

Any reference numbers previously issued by HMRC such as Inward Processing Relief, Outward Processing Relief authorisations or previous declarations should also be provided.

After checking all the information provided by the exporter, you should also:


Where a UK EORI number is not provided, confirm that the exporter is not registered and give consideration to the correct procedure to be used for the goods - ie is the export a private export or, if commercial, should the exporter first obtain an EORI number? Incorrect use of PR or UNREG terms may restrict your clients' ability to zero rate their goods for VAT purposes.

Check that the destination is a third country and not a European Union (EU) member state. Many exporters are unaware of which countries are members of the EU and look to their agents to confirm whether the goods qualify for export.

Ensure that an item is entered for each Commodity and not bulked for convenience.

Ensure that a declaration is made for each exporter and not bulked for convenience sake (unless approved to do so within Memorandum of Understanding (MoU) approved procedures). Where identity of the exporter cannot be confirmed, VAT zero rating may be affected.

When receiving details from your customers, please use any DUCR provided. If a DUCR is not provided then the guidance in the Tariff should be followed. In the air environment, AWB numbers are often used in the latter part of the DUCR yet in other freight areas it is helpful, for audit purposes, to use exporters commercial reference(s).

Owing to the increased use of official electronic records by HMRC, they strongly recommend that, to assist exporters, the actual DUCR/MUCR used or the CHIEF Export Entry Reference (EPU, Entry Number & Date) is notified to your clients. HMRC need to be able to trace the shipment through the traders' records to enable them to help verify claims for VAT zero rating on exports.


Many shipments are notified via inventory booking references so these are also worth confirming with Port loaders. Where goods have been consolidated, the higher level MUCR should always be used.


 

( linda )15 Nov,2011

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Freight Agents - Avoiding the Risk of Customs Civil Penalties when Arranging Exports
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The Importance of Insurance for Freight Forwarders
Where to Find Information on the Valuation of Imported Goods
The Costs of Using a Freight Forwarder
Types of Insurance for Freight Forwarders
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