Completing a CN22 For Exporting a Repaired Item Back to the EU

[Martin Winlow]

Hi,

I run a business in Scotland which, in part, repairs electric vehicle charging equipment. I have recently been sent an item for repair from the Republic of Ireland. I have repaired it and now wnat to send it back to its owner in Ireland. I have previously had a complete nightmare on behalf of a similar customer with huge delays getting the repaired item through customs without them having to pay full import duty as if it were new.

Is there a special cuspms code I need to use? I looked at An Post's website and found a section that recommended emailing them with the parcels (Royal Mail) tracking number and a few other details which I did but never recieved anything back from them. I am keen (obvs) to avoid a repeat.

Regards, Martin Winlow
EVBitz.uk Ltd

 

[Customs Geek]

I ve probably mentioned this in previous threads but all customs authorities treat any import as taxable unless a reason is provided to mitigate or reduce the duties.

I would recommend stating return after repair and quote the original export tracking number ( from Ireland) on the CN 22 to reduce the risk of you customer being charged.
It may be they need to pay and then provide the suggested documentation to mitigate those charges.

In future I suggest that you let your customers know what the correct procedure is to prevent unexpected costs on return

In the case of goods being exported and reimported for repair the original sender usually needs to use a special customs relief . These usually need to be applied for in advance or if it’s occasionally used this can be done at the time of export / import.
To get the relief you customer should have exported the goods using outward processing relief , have proof of export and be able to quote this on reentry.
The Irish revenue guidance is here
www.revenue.ie/en/customs/businesses/processing-enduse-warehousing/outward-processing.aspx
If the repair is charged for then even with the relief import taxes would be charged on the cost of repair.

I assume you meant this guidance from AN Post . When they mention the tracking number it would be for the goods when they left Ireland.
Do I have to pay customs on an item that I sent to a non-EU country for repair?
If you sent an item to a non-EU country for repair and are requesting to have it returned to you, you need to provide the below information to An Post, who will request the removal/refund of the customs charge raised on your behalf:

• Copy of the original/repair invoice from the sender
• Proof of exporting (Tracking number used to the send the item)
• Correspondence from the sender regarding repair being done/return (if possible)

The information can be sent to An Post via email at [email protected]

 

[Martin Winlow]

Hi 'Customs Geek. Thanks very much - that all makes sense. I'll do a little spiel for future customers from outside the UK to refer to.

 

[Martin Winlow]

Hi 'Customs Geek. Thanks very much - that all makes sense. I'll do a little spiel for future customers from outside the UK to refer to.

Hi CustomsGeek,

What I didn't ask explicitly is what tariff code I should put on the CN22 when returning the repaired item to the customer? I am still having real problems with this - the relevant page of HMRC is utterly hopeless as it simply does not appear to cater for my situation (hardly unique, one would have thought). It simply bangs on an on about everything from the perspective of the customer - or seller n the case of goods being exported after sale... nothing whatever about a business carrying out repairs (where or not the same business supplied the goods originally by exporting them).

Worse, when I rang HMRC to ask them for guidance on this their *utterly* baffling response was "We can't advise on how to complete the CN22 as it is a legal form". What on *Earth* is going on?!!

Worse still, when I rang the number on their site to complain about this insanity, the operator claimed that the web page was wrong and that all complaints had to be made 'online'. A thorough row ensued!

Anyway, if you or someone else can help with an appropriate tariff code for repaired goods (in this case an EV charging cable whose normal code is 8544429090), I'd be very grateful.

MW

 

[Customs Geek]

Hi

Commodity codes don’t change because the goods have been or are to be repaired. A commodity code essentially defines the type of item being exported/ imported so the purpose of the import/ export doesn’t change that.
If 8544429090 is the normal code you would use then that is what you should put on the CN 22 . I would tick the returned goods box in the contents section then mention the goods are being returned after repair in the description free text. If the customer has a specific approval for export for repair then you would also mention this.

The origin is where the goods are manufactured.

HMRC can be obtuse and many of the call handlers have very limited knowledge. They should provide general advice but won’t tell you specifically what to put as that always sits with the person making the declaration.
As you are using the Postal service you may get more assistance from them. The Post office effectively acts on behalf of Customs / Border Force and therefore handle customs aspects themselves.

 

[Martin Winlow]

Hi

Commodity codes don’t change because the goods have been or are to be repaired. A commodity code essentially defines the type of item being exported/ imported so the purpose of the import/ export doesn’t change that.
If 8544429090 is the normal code you would use then that is what you should put on the CN 22 . I would tick the returned goods box in the contents section then mention the goods are being returned after repair in the description free text. If the customer has a specific approval for export for repair then you would also mention this.

The origin is where the goods are manufactured.

HMRC can be obtuse and many of the call handlers have very limited knowledge. They should provide general advice but won’t tell you specifically what to put as that always sits with the person making the declaration.
As you are using the Postal service you may get more assistance from them. The Post office effectively acts on behalf of Customs / Border Force and therefore handle customs aspects themselves.

OK - thanks. That has at least cleared up the commodity code question. As you say, I'll just talk to Royal Mail in future (tho from previous experience, I won't get much more sense out of them - the whole country is falling apart).