A. In the event that the UK leaves the EU without a deal, you’ll need to check whether your current authorisation for Inward Processing still applies. Depending on the specific details of your authorisation, and whether HMRC or another EU customs authority gave you that authorisation, will affect whether you can carry on using it and whether it will be more limited.
Inward Processing is one of five Customs Special Procedures. There are other authorisations to use special and simplified procedures (known as customs facilitations), but here we are only referring to Customs Special Procedures (‘CSP’), these being:
- Inward Processing
- Outward Processing
- Temporary Admission
- End Use (also known as Authorised Use)
- Customs Warehousing
CSP Authorisations issued in the UK
If HMRC have authorised you to place goods into a customs special procedure in the UK, your authorisation will still be valid in the UK after Brexit. You can carry on both importing goods into the UK, suspending customs duties and import VAT or in certain circumstances, relieving some or all of the customs duty. You’ll also be able to use your authorisation to import goods from the EU along with any you already import from non-EU countries. You should write to your HMRC authorisation team to ask for an amendment to your authorisation if there are changes to the range of commodity codes, quantities, values, any other details specified in your current authorisation.
CSP Single authorisations issued in the UK to use in the EU
If HMRC have authorised you to place goods into a customs special procedure, including moving those goods into the EU, your authorisation will still be valid but in the UK only. This means that you can carry on importing goods into the UK under the authorised procedure after Brexit. You should write to your HMRC authorisation team to ask for an amendment to your authorisation if there are changes to the range of commodity codes, quantities, values, any other details specified in your current authorisation. If you want to cancel your authorisation, you must tell the relevant HMRC authorisation team, who will send you a letter cancelling your authorisation and telling you what to do to discharge any goods that you have in stock.
CSP Authorisations given by another EU customs authority
Current guidance issued by the EU is that authorisations for customs simplifications or procedures, such as customs warehousing, issued by the UK will no longer be valid in the EU after Brexit. If you’re named on an authorisation issued by another EU customs authority to place goods into a customs special procedure in the UK, you will not be able to receive goods in the UK under that authorisation after Brexit. For example, to import goods for processing from the EU whilst duty is suspended or relieved, you’ll need a separate authorisation from HMRC.
Where you’ve had goods under an authorisation from another EU customs authority, you’ll have 12 months from the date the UK leaves the EU to discharge those goods from any customs special procedure. You can do this by either exporting the goods, making a declaration into a UK customs special procedure, putting goods into free circulation in the UK.