Using Returned Goods Relief within the EU

[AdamCD]

Hi
We are a clothing retailer that has all of our production made in the EU, and then shipped under preference to our shop in the UK for free circulation. We can then sell online back to retail customers in the EU and ship DDP via DHL. As the goods are not UK origin we can not use preference, but is it possible to use RGR for say Ireland, so that we do not have pay duties, or are able to claim them back later? I keep being told no, but it would be helpful if there are any e-com business that are utilising this procedure successfully that could add anything. We have a high order value.
The long term solution would be to have a physical fulfilment centre in the EU but the production numbers are too small to justify this for some time yet.
The second question is has anyone figured out to reclaim EU duties or VAT back on returns as we currently lose that.
Just to be clear it is EU D&T I need help with, the UK side of things is all good.
Thank you!

 

[Customs Geek]

Hi

In theory using RGR is possible but in practice it’s difficult when you are talking about sales to individuals. To claim RGR you would need to provide evidence of the previous export from the EU so details can be entered on the import declaration. It also needs a non standard import declaration so outside of the courier companies highly automated and simplified systems. They may therefore charge more.
If your volumes are significant then it may be cost effective to introduce some automation and agree a simplified method of providing evidence with the Irish revenue.

A reclaim of duty is permitted in EU law for return s within 90 days by invalidating the original import entry. It is only usually the named importer who can claim. So if your customer is the importer rather than yourself then you would have no entitlement even if you actually paid the duty on your customers behalf.

Again there are options but you may need to invest in considering your business model or automation. Again this may not make commercial sense unless you can save more than it costs.
Perhaps other members can comment on parties that may offer services in this area.

 

[AdamCD]

Many thanks for your reply.
We could provide the evidence of previous export. But I think your second point is where we hit a wall. Courier companies as you say, have simplified systems, and I am not sure they would even offer this service. Getting an answer out of DHL is like pulling teeth.

As regards the returns, do you know if it is possible for us to act as the IOR given we ship DDP, or if courier companies can act as the IOR, for a fee perhaps? Though then they would also need to claim back the duty too.

It is all definitely a cost/benefit analysis, and the ease of just using DHL vs something more complicated.

 

[Customs Geek]

Many thanks for your reply.


As regards the returns, do you know if it is possible for us to act as the IOR given we ship DDP, or if courier companies can act as the IOR, for a fee perhaps? Though then they would also need to claim back the duty too.

The couriers only act as representatives an never to my knowledge as the importer

It is all definitely a cost/benefit analysis, and the ease of just using DHL vs something more complicated.

 

[AdamCD]

Hi

I have been in touch with German customs and I have not had a flat out no that we can claim relief from import duty when exporting goods to the EU that have an EU COO, even if they have been in the UK. It is as always quite difficult to a straight answer, but I have been told the following:

Under certain circumstances, products, that have once been exported from the EU can be reimported into the EU as so-called “returned goods” free of import duties. It’s a complex procedure.

For the goods to be accepted the status of returned goods and thus granted the duty relief there are several requirements:

1. goods are reimported into the EU within 3 years AND
2. it hasn´t been altered except for traces of normal usage -a damage does not count as an objectionable alteration AND
3. it can be proven that the imported product is the same one that has previously been exported from the EU. As proof, the export declaration can be used.

I did specify the purpose of how we wanted to use this (buying from manufacturers and selling to retail).

I am still trying to cut my way through the complexities, but hoping there is a solution at the end.

thanks

 

[Will.Lu]

Hi
We are a clothing retailer that has all of our production made in the EU, and then shipped under preference to our shop in the UK for free circulation. We can then sell online back to retail customers in the EU and ship DDP via DHL. As the goods are not UK origin we can not use preference, but is it possible to use RGR for say Ireland, so that we do not have pay duties, or are able to claim them back later? I keep being told no, but it would be helpful if there are any e-com business that are utilising this procedure successfully that could add anything. We have a high order value.
The long term solution would be to have a physical fulfilment centre in the EU but the production numbers are too small to justify this for some time yet.
The second question is has anyone figured out to reclaim EU duties or VAT back on returns as we currently lose that.
Just to be clear it is EU D&T I need help with, the UK side of things is all good.
Thank you!

Hi, may I know your brand? your products for who? male? female ? thx