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Returnable Packaging

04/04/2019 10:39:37
I’m seeking clarification on the returnable packaging cross-border process in the event of a no deal EU exit.

Here are my specific scenarios;

1. UK company owned packaging being exported to other UK company entities in the EU full and then returned (re-imported) to UK company empty.

2. UK company owned packaging being exported to EU customers full and then returned (re-imported) to UK company empty.

3. EU Supplier owned packaging being imported to UK company full and then being exported (returned) to the EU supplier empty.

4. EU Supplier owned packaging being imported to UK company empty and then being exported to the EU supplier full.

What documentation will be required, what information does it need to show and which Import and Export CPC's will apply to the above scenarios?
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Re:Returnable Packaging

24/04/2019 16:57:49
Hi,

In the event of a no deal EU Exit, the import and export of packing materials from/to the EU would broadly be subject to the same customs procedures and requirements that already apply to goods imported from and exported to outside the EU. This means that import and export declarations would be required, although transitional simplified procedures (TSP) have been introduced for imports from the EU.

Please see the following link for further information about TSP here:

Customs procedures if the UK leaves the EU without a deal

Please note, this information is correct at the time of writing, however the position may change before the UK leaves the EU.

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Returnable Packaging

25/04/2019 08:38:55
Hi,
Pre Brexit most most empty durable returnable packaging and skeleton pallets (eg engine racks) move UK-EU-UK without declaration, but with some form of shipping document. As such they move without a value because the units are owned by the consignor and circulate to facilitate the supply chain.
We have registered for TSP will still have to make a declaration (as you suggest in your response) in our records. What CPC would be recommended for these types of movements & valuation to ensure zero duty & VAT and suggested equivalent treatment by EU customs/port authorities post Brexit?
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Returnable Packaging

25/04/2019 09:19:48
Hi all, I thought I would share the below response I received from my local HMRC team as it may also be useful to others.

• No formal application for authorisation or customs declaration to claim relief is required. Clearance through the customs office without making a formal customs declaration will be treated as:
o an application for TA authorisation
o a declaration by the importer, that the containers or pallets are eligible
o the conditions for claiming relief are met

• A C88 (SAD) declaration to CHIEF using the CPC appropriate for the loaded goods being imported must be made. In box 44 of the C88 (SAD) enter the following additional information code (see the Tariff Volume 3 Appendix C9):
o PAL02 for pallets
o PAL03 for containers

Under EU Safety and Security legislation, the individual identification numbers of the container(s) must also be shown on the import declaration for the loaded goods.

See: section 2.14.1 and 2.14.2 of Annex C to Notice 3001

See notice 3001 for more useful information.


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Re:Returnable Packaging

01/05/2019 09:17:17
Hi Andy,

Thanks for your question.

I have included a link below which provides lists of customs procedure codes.

Check through the guidance from which you should be able to form a judgement as to which is the most appropriate.

CHIEF: customs procedure codes

I hope this helps.

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