Sending low/zero value items to EU from 1 January

John_V85

Free Member
Jan 11, 2019
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Periodically we send low-value replacement or missing parts (think custom screws, etc.) to customers in Europe which prevents an otherwise unnecessary return. These parts are not things we sell individually (no SKU, etc.) and have negligible value.

Typically we have been using Royal Mail International services.

I'm going round in circles somewhat, trying to determine if this is viable from 1 January and how one would account for something of negligible value. The last thing we want is to send a couple of screws and then we (or the recipient) receives a VAT/duty bill.

Any advice or pointing to the relevant resource would be gratefully received.
 

Kristen Lee

Free Member
Aug 7, 2013
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Hiya,
Resurrecting this as we are a business that occasionally needs to send replacement parts for either faulty items or that were accidentally left out of the original purchase. We are putting on the CN22 form and also supplying supplemental invoices saying the item is a replacement for a faulty part and we are therefore giving it a value of £0, as the customer has already paid customs & VAT on the orignal item. However we have had multiple times where customers have had issues on their end and the item being sent back to us 'due to insufficient documentation'. I'm not really sure how much more specific I can be. Is there a different HS code I should be using perhaps?
 
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Customs Geek

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  • Oct 27, 2022
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    The problem is that customs do not recognise anything as having a zero value . They don’t take into account whether it is being charged for or a free replacement. It is also not appropriate to put a made up value.
    Without getting into the complexities of custom value rules when there isn’t a sale the customs authorities are looking for a value similar to that had the goods been sold.

    Goods imported into the EU below €150 are relieved of duty and if the customer is VAT registered they should be able to recover any import VAT charged if you show their VAT number.

    Even if the goods are free replacements they are treated as a new import so it’s irrelevant to customs that you don’t choose to charge.
    if there are larger sums involved your customers could look to use the rejected import procedures to claim back duty paid on faulty goods.
     
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    japancool

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  • Jul 11, 2013
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    The problem is that customs do not recognise anything as having a zero value . They don’t take into account whether it is being charged for or a free replacement. It is also not appropriate to put a made up value.

    Hmm, I've had this with my European suppliers.

    What happened was they originally sent a consignment wihch had the item listed at its normal on the commercial invoice, but the item was missing from the consignment. So I paid VAT for something that wasn't there.

    They then included the missing item on the next consignment at 0 value. It was included with a load of other items as well.

    It didn't seem to cause an issue.
     
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    Customs Geek

    Free Member
  • Oct 27, 2022
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    Hmm, I've had this with my European suppliers.

    What happened was they originally sent a consignment wihch had the item listed at its normal on the commercial invoice, but the item was missing from the consignment. So I paid VAT for something that wasn't there.

    They then included the missing item on the next consignment at 0 value. It was included with a load of other items as well.

    It didn't seem to cause an issue.
    If you had goods included on a consignment with other goods it is unlikely that it will be noticed at the time of import as it would have been just one of a number of invoice lines. The price you paid would be regarded as the total price paid . HMRC rarely look at documents at the time of import an even more rarely look at goods.

    Presumably if you are VAT you also reclaimed the input VAT based on what you paid So you shouldn’t have been out of pocket. If goods are genuinely short shipped there is a mechanism to make a reclaim for anything overpaid.


    The difference for Kristen Lee is that the goods are being sent separately with a zero value which is causing problems for the reasons I mentioned. If these are parts are genuinely low value there shouldn’t be any customs charges when showing a correct value.

    No one said there is any logic or consistency of application in some of the customs rules but they are what they are.
     
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