Guidance
Declaring reusable packaging for Great Britain imports and exports
From 1 January 2021 reusable packaging requires an import or export declaration, but if you are claiming Returned Goods Relief or temporary admission you can make this declaration by conduct or orally.
To be able to make an oral declaration or a declaration by conduct, the packaging must be reusable.
In this context reusable packaging are goods that meet all of the following. They must:
- be useable for transportation of other goods
- have a relief from import duty at the time of import
- not be intended for sale
- be filled on at least one leg of their import or export journey
Packaging like bubble wrap and cardboard boxes are not included as reusable packaging.
To qualify for a relief from import duty the reusable packaging must have been in UK free circulation from 1 January 2021. For reusable packaging from the EU, it must have been transported to the EU before the end of the transition period and returned before 31 December 2021.
The reusable packaging must be treated as going into free circulation or declared for temporary admission. It cannot go into any other Customs Special Procedure.
If you do not use declaration by conduct or an oral declaration you can make a declaration for your reusable packaging using a different process.
Who can make the declaration
The importer and exporter do not need to own the packaging or the goods contained in them but to claim Returned Goods Relief the importer and exporter should be the same person.
Declaring reusable packaging
Reusable packaging requires a declaration.
At Great Britain locations you can make a declaration by conduct for reusable packaging by either:
- disembarking from a vessel
- driving past a Customs office
- loading the goods on to the relevant vehicle
On export the declaration by conduct will be driving across the boundary of a port or driving past a customs office.
You can make an oral declaration for reusable packaging by telling a Border Force officer about it. If you have the authority to import or export reusable packaging for someone else, you also need to identify that person.
A declaration by conduct can be made on someone else’s behalf. For example, a haulier can make a declaration by conduct if they’ve been given authority to do so by an importer.
Not all locations can allow oral or by conduct declarations so you should check ahead with the location the reusable packaging is moving through if you want to declare it in this way.
If reusable packaging is to be declared by conduct and the goods are stopped by Border Force then the driver either carrying the goods, or coming to pick the goods up, must advise a declaration by conduct is being made for the packaging.
Once an oral or by conduct declaration has been made no further information needs to be sent to HMRC.
Imports
On import, the packaging can be declared for free circulation by conduct or orally to a Border Force officer. The goods can also be declared for temporary admission. These goods are intended to be re-exported.
You will not need to pay Customs Duty or import VAT on them. But to make sure that no VAT is due, the importer and the exporter of the packaging must be the same.
Safety and security declarations will not be required until 1 January 2022 on imports into Great Britain from:
- the EU
- Andorra
- Monaco
- Norway
- Liechtenstein
- Switzerland
- Ceuta and Melilla
- Heligoland
- San Marino
- the Vatican City State
- the municipalities of Livigno Campione d’Italia
- the Italian national waters of Lake Lugano, which are between the bank and the political frontier of the area between Ponte Tersa and Porto Ceresio
Exports
If you are declaring exports of reusable packaging by conduct you will not need to make them available for examination. This is unless Border Force stop you and want to make an inspection.
A safety and security declaration will be required for exports of packaging from Great Britain from 1 January 2021. However, for the period 1 January 2021 to 30 September 2021 this requirement is waived for reusable packaging carried in Roll on Roll off (RoRo) vehicles that would otherwise need to make an exit summary declaration. The requirement for safety and security declarations on these movements will only start to apply from 1 October 2021.
Last updated 11 May 2021 + show all updates
ake a declaration for your reusable packaging using a different process.
Who can make the declaration
The importer and exporter must be the same person, so you can qualify for VAT relief and do not need to submit an import or export declaration.
The importer or exporter of the reusable packaging can be different to the importer or exporter of the goods they protect.
The person making the declaration by conduct does not need to be the owner of the packaging.
Declaring reusable packaging
Reusable packaging requires a declaration.
If the importer and exporter of the reusable packaging is the same person, you can make a declaration by conduct (whether filled or empty).
At Great Britain locations without customs controls you can make a declaration by conduct for all reusable packaging, the declaration by conduct will be by either:
- disembarking from a vessel
- driving past a Customs office
- loading the goods on to the relevant vehicle
On export the declaration by conduct will be driving across the boundary of a port or driving past a customs office.
At locations in Great Britain with customs controls the declaration will be made by driving across the boundary of the port. You will only be able to make a declaration by conduct for packaging from the EU at locations with customs controls, because they will not be ready to manage this process for goods from other locations from 1 January 2021.
Someone can make a declaration by conduct on someone else’s behalf, for example a haulier can make a declaration by conduct on behalf of the importer.
If the goods are stopped by Border Force then the driver either carrying the goods, or coming to pick the goods up, must advise a declaration by conduct is being made for the packaging.
Imports
On import, the packaging is declared for free circulation by the conduct described above. These goods are intended to be re-exported.
You will not need to pay Customs Duty or import VAT on them. But to make sure that no VAT is due, the importer and the exporter of the packaging must be the same.
Safety and security declarations will not be required until 1 July 2021 on imports into Great Britain from:
- the EU
- Andorra
- Monaco
- Norway
- Liechtenstein
- Switzerland
- Ceuta and Melilla
- Heligoland
- San Marino
- the Vatican City State
- the municipalities of Livigno Campione d’Italia
- the Italian national waters of Lake Lugano, which are between the bank and the political frontier of the area between Ponte Tresa and Porto Ceresio
Exports
You will not need to make the reusable packaging available for examination unless Border Force stop you and want to make an inspection.
However, a safety and security declaration will be required for all exports from Great Britain from 1 January 2021.
How to send information to HMRC
You must send HMRC information about the packaging every quarter:
- January to March
- April to June
- July to Sept
- October to December
The information must reach HMRC within 15 days of the end of the quarter.
The quarterly report must be sent by e-mail with the individual or business name, and the EORI number show in the subject of the email. The e-mail address to send this information will be published shortly.
The email must contain the:
- name of person or company importing or exporting the packaging (this should be the same person so that the goods qualify for relief from import VAT)
- EORI number of person or company importing or exporting
- commodity code of packaging
- date of import or export (this can be the month that the import or export took place)
- number of units imported or exported (this can be the total number of units in the month that the import or export took place)
You must also confirm in the email if:
- your claim for returned goods relief is valid – for imports
- commercial evidence has been retained – for exports
For each type of packaging, you should provide an aggregated summary each calendar month within the quarter. This should show, for each packaging type, the actual or estimated number of units imported or exported during the month.
If HMRC tells you to make normal declarations
If HMRC tells you that you cannot declare reusable packaging this way, you’ll need to make a normal import or export declarations for the packaging. If you disagree with the decision you can request a review by HMRC or appeal straight to the tax tribunal.