There are almost never any duties or charges on exports. In some exceptional circumstances such as under the common agricultural policy issues of export refunds (subsidies) can still arise, although there are being phased out. Equally where goods are re-exported having been imported duty considerations can arise in a marginal way. Apart from this however export duties as such are not a feature of international trade.

The reasons for customs control upon export might not be immediately apparent. Broadly the requirement for detailed information in each case for detailed export requirements relate to

  • verification that the goods have left for the purpose of the zero rate VAT
  • compliance with sanctions and trade policy generally or in relation to certain sensitive goods
  • EU laws on export relief in particular agricultural refunds where they still apply
  • statistics and information gathering
  • policing of controls and restrictions on exports (e.g. dangerous products, weapons, and dual-use goods, counter feet pirated goods, pornography, endangered species, and others)
  • ensuring compliance with safety and security requirements
  • ensuring compliance with customs import duty reliefs which require re-exportation in the context of common agricultural policy subsidies and controls animal health and safety

Export Declaration

On each export, the customs declaration requires 20 to 30 pieces of information to be completed in the single administrative document. It must be completed through software that can communicate with the revenue systems. The export declaration is lodged through the AEP (Automated entry processing) system

The full information corresponds to those requires for imports but is less. The entries required are as follows; many of the items are contingent on the circumstances.  They correspond directly to the boxes mentioned above, and they are completed in the same way.

Information about the parties

  • consignor
  • consignee

information about the goods

  • type of package
  • unique  package reference
  • number of packages/pieces
  • marks and numbers of packages
  • description of goods
  • packages in item
  • item number
  • customs code
  • country of origin code
  • region of origin code gross mass
  • gross mass
  • net mass
  • summary number of units
  • identifier code
  • description /additional information

Information about the movement

  • office of dispatch/export –
  • mode of transport at the border
  • flight no./ ship/truck registration
  • time of arrival
  • transport document reference
  • inland mode of transport
  • office of exit
  • location of goods
  • container numbers

Information about the value and terms of sale

  • currency code/
  • total amount invoiced-
  • nature of transaction
  • statistical value
  • deferred payment
  • invoice reference

Information about the customs treatment requested

procedure requested

  • procedure category previous procedure
  • previous declaration
  • identification of warehouse

As with the import declaration, some items are mandatory, and some are conditional. Some items that appear to be conditional are, in fact, mandatory in the particular circumstances where they apply. They are conditional in the sense that they are not always applicable.

As on the import side, the declarations are completed through filling in codes. Both the Irish and UK guides set out details of the codes which are now in common EU format. The process is made more intuitive via the relevant customs software or in the communications with the logistics provider.

Many / most of the codes are likely to be repetitive and can be standardised. Several of the codes will be inapplicable to cases, and others are got to do with the logistics provider routing and other requirements.

Supporting Documents

Supporting documents must also be held. This will include a commercial invoice and the transport document such as a CMR consignment note (road)) Bill of lading or other sea transport document or airwaybill. A packing list is required where applicable. They are to be referenced on the return to that they can be cross-checked in an audit.

Certain goods require licenses and authorisations and they must be available and furnished electronically. In relation to agricultural and food products, veterinary and Plant health certificates are required.

There are both EU and national controls on the export of goods. The EU rules may arise from international agreements and obligations entered. For example, there are detailed EU regulations on dual-use goods (potentially military use).

Export controls may be determined by the type of product but also by its destination the end-user what might be done with it. It may also be relevant pays for the product and who is responsible for compliance obligations that might apply.

The particular tariff heading from the EU tariff will set out whether restrictions, licensing or other special requirements apply in relation to the export of the goods to the contrary identified. This may require in turn particular licences. The EU tariff, the Taric will identify particular conditions licenses or certifications which will be required. For example, it may be required to insert by way of a code set out in the tariff that particular conditions or licensing requirements do not apply, or where they do apply, that the required licenses are held.

In some cases, the licenses must accompany the documents when they move. More commonly the documents must be held and can be requested by way of orange routing. In any event, they must be retained for a period of years for subsequent inspection in an audit if required.

Exports Systems

The basic obligation on the export side is to make an exit summary declaration (a safety and security declaration) and a customs declaration to Revenue in the case of export and the Republic of Ireland and to HMRC in the case of exports from the United Kingdom. They must be lodged / returned to the customs office of exit. They can be combined as a single declaration.

As with the entry summary declaration, the making of the exit summary declaration rests primarily with the carrier but they may delegated to the exporter who may make a single customs declaration including it.

In effect, goods will not be allowed onto a means of transport unless the exit summary declaration has been accepted by Revenue and /or HMRC as the case may be. The dataset involved is a subset of the full export declaration set. In effect, a full export customs declaration combines both.

As with the import declaration, it could in principle be the case that the exit summary declaration is given but that the export customs declaration is not given, in which case the goods would remain at the border in customs premises until the export customs declaration is given. In practice, the exits and export declarations are usually combined and done in advance.

Import and Export Declaration

The data required overlaps for import and export declarations. The data is reported through the automated entry processing procedure (AEP) via custom software in accordance with the single administrative document procedure on the Irish side.

On the UK side data is transmitted to the equivalent UK system via custom software or port systems for which there is no direct equivalent in Ireland, to the UK system now CHIEF in the course of change to the customs declaration system (CDS)

On every movement from Ireland to the UK, there is each of the above returns to Irish Revenue and HMRC. Conceivably in the future, there may be some UK to Ireland simplification or even a single EU or RoI / UK window for making returns.

The trader may  need to liaise with its UK supplier and logistics provider in relation to the practicalities of making the relevant customs and security declarations on both the Irish and UK side as well as the carrier’s obligations to provide an  emanifest with  much of the same information.

The solution may involve one or other party nominating a freight forwarder is who is to undertake declarations for both or alternatively the trader or the trader ’s UK supplier make the trader ’s own export or import declarations in agreement with the carrier and supply the relevant information or copy SAD to them. This requires getting information from the carrier about the transport movement.

UK Import Waivers

The basic obligation on the import side is to make both a safety and security declaration and a customs declaration to HMRC. HMRC on imports into the United Kingdom proposed to waive the safety and security declaration for a period of nine months at least and probably more for a hard Brexit scenario.

The UK has offered complete simplifications subject to conditions in relation to import declarations effectively allowing all the trader s to use the entry in own records procedure which normally requires highly trusted the trader status and quite detailed security and organisation requirements. This does not apply to Northern Ireland, which would appear is intended to benefit from much greater simplifications. See other chapters HMRC  13th March 2019 statement.

Republic of Ireland

The Republic of Ireland is bound by EU law and cannot give broad waivers in the same way as the UK respect of either exports or imports on the Republic of Ireland side. In particular, on the export side, it is not on a position to give corresponding waivers that have been given under the UK import side.

There is however significant scope within the existing EU laws for Revenue to offer a certain amount of simplifications sometimes on a case-by-case basis and sometimes generally, much more than has been announced to date. However, nothing as dramatic as the UK complete waivers simplifications is possible without a change in EU law.

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