Indirect exports - the dispatch of goods via a European Union (EU) country or countries to a third country destination - require special procedures and paperwork. Indirect exports are controlled by the Export Control System which is an EU wide system implemented in July 2009. Indirect exports (whether they are by air, sea or road) must be accompanied by an Export Accompanying Document (EAD) which has a Movement Reference Number (MRN) and Barcode which can be scanned at the Office of Exit in the last member state before the goods exit the EU.
After the UCC was implemented on 1 May 2016 you are only required to present the MRN of the export declaration with the goods at the customs office of exit.
The UK treatment of indirect exports generally depends on their final destination:
- If you're exporting to a country outside the EU, you must complete an export declaration - even though the goods are initially being sent through another EU country.
- Export controls and licensing requirements will depend on the final destination of the goods.
- Goods exported to a customer outside the EU can be zero-rated for VAT even if they initially travel through other EU countries. However, proof of the goods actual departure from the EU will be required.
When exporting outside the EU, you must complete an export declaration, even if the goods are being sent through another EU country first. Indirect exports must be 'Arrived' on CHIEF before they leave the UK. 'Arrival' is the technical term by which goods are presented to Customs via an export declaration - once you have completed this stage, CHIEF will give you permission to progress (also referred to as P2P) your shipment. Failure to comply can lead to trouble in other countries, and even the rejection and the return of your goods. After the implementation of the Union Customs Code on 1 May 2016, exporters now only need to present the MRN of the export declaration with the goods at the customs office of exit.’
Depending on their final destination, you may need to satisfy other regulations and obtain other export licences. Indirect exports can only be zero-rated for VAT if you can prove the goods have been exported. Read more about VAT on exports and other taxes.
In the UK the export declaration submitted electronically to CHIEF will include all the safety and security data required under the Export Control System (ECS). It is therefore a 'combined' declaration ie fiscal and ECS safety and security data are combined on the UK export declaration. In the UK you do not need to submit separate safety and security information to the ECS - CHIEF will pass the relevant data to the EU ECS system. Once your declaration has been accepted by CHIEF a Movement Reference Number Number (MRN) will be issued. This can be used to track the movement across the EU to exit and must be 'closed' on the ECS system by scanning the barcode relating to the MRN at the Office of Exit. Read more about how the Export Control System controls indirect export movement within the EU.
The safety and security legislation that came into force in 2009 set minimum time limits for the lodgement of Export Declarations ahead of their departure as follows:
- for 'deep sea' containerised cargo, at least 24 hours before the goods are loaded
- for 'short sea' containerised cargo, at least 2 hours before leaving the port
- for air traffic, at least 30 minutes before departure from an airport
- for rail and inland waters traffic, at least 2 hours before departure
- for road traffic, at least 1 hour before departure
- for supplies for ships and aircraft at least 15 minutes before departure
As of 1 May 2016, time limits under UCC legislation are for:
- ‘deep sea’ containerised cargo, at the latest 24 hours before the goods are loaded
- ‘short sea’ containerised cargo, at the latest 2 hours before leaving the port
- non-containerised cargo at the latest 2 hours before departure
- air traffic, at the latest 30 minutes before departure from an airport
- road and inland waters traffic, at the latest 1 hour before departure
- rail traffic, at the latest 2 hours before departure
You’ll be covered if you supply an export declaration, you will be covered, but if you’re not declaring goods in the usual way, you must complete an Exit Summary Declaration.
Carnets for non-community goods moving through the EU
The Transports Internationaux Routiers (TIR) procedure is used to move goods, essentially by road, between two countries party to the TIR Convention or between two points in a participating country as long as the movement passes through a third country. The payment of duties and other charges are suspended. For the purposes of TIR, the Community is regarded as a single territory. TIR is only permitted in the EU when the movement either begins, ends or transits a third country.
Goods must be transported in approved vehicles or containers and be accompanied by a TIR Carnet. You, or your freight forwarder, must be authorised to use the TIR system and to purchase a TIR Carnet. The Carnet acts as the customs declaration for movement when outside of the EU and as security for any taxes and duties to which the goods become liable.
All traders moving goods across the EU under the TIR procedure must submit an electronic customs declaration via the NCTS when the consignment reaches the frontier of the EU. You can alsoread more about using the New Computerised Transit System (NCTS) to move goods across the EU and EFTA countries.
If goods originate from outside the EU, the Community Transit procedure can be used to move them within the EU.
If goods are moving to or through a European Free Trade Association (EFTA) country, the Common Transit procedure should be used.