CUSTOMS INFORMATION PAPER (13) 27
Inward Processing – Authorisations and responsibilities of
agents and IP Authorisation holders
Who should read:
All businesses using Inward Processing (IP) and
agents/representatives who are employed by IP
traders.
What is it about:
IP Issues including: retrospective IP Authorisations,
restriction of coverage of IP with a Simplified
Authorisation, IP Authorisation holders’ and agents’
responsibilities.
When effective:
Extant until/ Expires
Immediately
Until further notice
1. Introduction
This is one of a series of CIP papers being issued by the Inward Processing
(IP) Policy team. They will cover subjects where there have been:
 changes in IP policy;
 where current IP policy has been found to have not been implemented
correctly; and
 where confirmation of existing IP policy has been sought from the EU
Commission.
The contents of this and other CIPs issued by the IP Policy team will be
incorporated into the next update of the IP Public Notices (221 and 221A)
later this year.
This particular CIP provides updated guidance and clarification of the
following IP related issues:
 retrospective IP Authorisations;
 revised rules regarding the use of IP with a Simplified Authorisation;
 EORI numbers; and
 advice for IP traders using an agent/representative.
2. Retrospective IP authorisations
2.1 Retrospective IP authorisation may only be considered for traders who are
seeking full IP Authorisation, not for those who use IP with a Simplified
Authorisation (where the request for authorisation is made by means of the
submission of a customs declaration (Article 497(3) type authorisations)).
2.2 The EU Commission has confirmed that any goods which require an
economic test cannot be subject to a retrospective authorisation as there is no
provision in the Customs Code for the economic test to be carried out
retrospectively.
3. Exclusions from IP with a Simplified Authorisation
Revised rules regarding the use of IP with a Simplified Authorisation were
announced last year in CIP (12)17. This is a reminder that goods in Chapter
93 and Chapter 97 of the Tariff and all goods above the value of £500,000
(regardless of the Tariff classification) can no longer use IP with a Simplified
Authorisation. Businesses intending to process any such goods under IP will
need to submit an application for full IP Authorisation at least 30 days prior to
any start date using form C&E810 .
4. Economic Operator Registration and Identification (EORI) numbers
4.1 All companies involved in International Trade (including importing,
exporting, Inward Processing and other CPEI procedures) have been required
to have an EORI number since they were introduced in July 2009 as part of
the EU Safety and Security Regulations. You must ensure that you quote
your EORI number on all IP Application Forms, Customs Declarations, Bills of
Discharge and in any correspondence with your Supervising Office. Please do
not confuse your VAT number with your EORI number.
4.2 When completing your customs import and (re)export declarations please
ensure that the name and address in boxes 2 and 8 on a declaration
(Consignor and Consignee) MATCH the EORI number you enter in these
fields. Companies should be particularly careful where they are a subsidiary
to ensure that the correct EORI and name and address are supplied on the
declarations. The details of the holder of the EORI authorisation including
name and address are held on a central EU database. Any changes to
details must be notified to the EORI team at the following email address
[email protected] .
4.3 Please keep your EORI records up to date. Further information on EORI
numbers can be found in the Frequently Asked Questions (FAQs) on the
EORI Web page.
5. Using an agent/representative
A) Information provided to agents/representatives
5.1 We have had a number of incidences recently where IP traders have been
obliged to pay suspended duties and Import VAT because the
agent/representative did not follow the correct import/re-export processes for
IP. The most common issue was that an incorrect re-export CPC had been
used which effectively removes the IP goods from Customs Control (Article
203 Customs Code).
5.2 When using an agent/representative, you should ensure that your
instructions are clear that the goods are under the Inward Processing
procedure and the correct Customs Procedure Codes (CPCs) should be
used at import and re-export. Express Parcel Operator or other Bulking
CPCs should not be used under any circumstances for IP (re)exports.
5.3 As it is the IP authorisation holder who is ultimately responsible for
ensuring that all the conditions of IP are met and who will bear the cost
responsibility for the debt, we would recommend that instructions to
agents/shippers are made in writing and evidenced in your IP records and that
you develop your own assurance checks to confirm that your instructions
have been complied with. If you send instructions by email this may include
keeping “read” receipts.
B) Documentation received from agents/representatives
5.4 We have also recently seen issues around the lack of documentation
(such as Export declarations and CHIEF/Transit declaration reference
numbers) being kept in IP traders’ records. This can also lead to the trader
having to repay duties and Import VAT suspended under IP. When using an
agent/representative, you should request evidence of (re)export in the
form of CHIEF declaration reference numbers and/or prints from the National
Export System (or their commercial equivalent reports that show the relevant
evidence of export data including the CPC and customs clearance codes).
The Export Policy team’s Best Practice Guide (Section 43) describes what
information can be considered as proof of export.
6. Contacts
Queries on Customs Procedures should be directed to the Excise & Customs
Helpline on Tel 0845 010 9000.
Questions can also be submitted electronically by email using the iform at the
following link: Customs General Enquiry Form.
If you have a specific query about your Inward Processing Authorisation
please contact your Supervising Office:
For IP with a Simplified Authorisation this is NIRU - Abbey House, Head St,
Enniskillen, Northern Ireland, BT74 7JL. E-mail - [email protected] (or
visit the NIRU Website for further details).
For IP authorised Large Business Service (LBS) Traders this is your
Customer Relationship Manager (CRM).
For non LBS authorised traders this is CITEX – Authorisations and Returns
Team, 2nd floor East, HMRC, Fitz Roy House, Castle Meadow Road,
Nottingham, NG2 1BD.
Issued on the 22 April 2013
Money Directorate.
by the JCCC Secretary HMRC, Excise, Customs Stamps &
To find out what you can expect from us and what we expect from you go to
www.hmrc.gov.uk/charter and have a look at Your Charter