The following guidance comes from Susan Morley FCILT, Chair, Customs & International Trade Compliance Forum, CILT(UK).  Following recent government changes to customs authorisations. These temporary changes may affect you if you are authorised or applying to be authorised by customs to:

• use temporary storage or customs special procedures such as inward processing or customs warehousing
• use simplified declarations such as entry in your records
• have a guarantee
• operate as an Authorised Economic Operator (AEO)

If you’re no longer able to comply with a condition of your authorisation because of COVID-19, you must get permission from your supervising office in HMRC or Border Force to temporarily vary the conditions of your authorisation.

You can apply to temporarily vary the following conditions of your customs approvals:

• changes to site opening hours
• the need for staff to be on site in order to carry out a particular function if that function can be completed remotely
• the specific areas within an approved location in which customs controls must be conducted
• reducing dwell times to allow quicker permission to progress
• time limits for bills of discharge and period of discharge (throughput period) for special procedures such as inward processing relief
• how to process goods that will now be held in temporary storage over 90 days

You can apply to temporarily change your authorisation by emailing your supervising office with the subject ‘COVID-19 customs easement request’.

HMRC advise that applications for a temporary variance to authorisations will be looked at on a case by case basis and may be declined if there are concerns about the impact on customs controls.

Where an application for an authorisation would normally have been sent by post you can temporarily send it by email instead. You will need to send your postal application form with an original signature once the COVID-19 controls are lifted.

If applying for a Customs Comprehensive Guarantee HMRC will also accept an electronic copy of your financial guarantee form (CCG2), transit guarantee form (C1146) and Joint Contractual Liability Form.

HMRC will confirm most authorisation applications during the COVID-19 outbreak without a site visit.  However if an HMRC visit is required in order to comply with international standards e.g an AEO audit, and it is not possible to conduct that visit, HMRC will contact you to discuss temporarily suspending the process.

If your authorisation is due for renewal and HMRC are unable to renew your authorisation that is due to expire, HMRC will automatically extend your authorisation to ensure you have continuity.

HMRC will let you know if they have granted an automatic extension.

Full details can be found here.

Further easements:

HMRC have announced some easements to help traders cope during the COVID-19 pandemic:

1. Exports valued at Euro3000 or less:

If you have a consignment that is less than €3000 in value and is not subject to prohibitions or restrictions this can be declared for export in the UK even if the exporter is established in another EU member state
If the export is to be conducted under simplified procedures, you must contact your supervising office.

2. Using the Transit Procedure

If you are transporting goods, the expected journey time entered on a transit declaration can reflect anticipated delays. The New Computerised Transit System will accept journey times of up to 14 days.

3. Completing Supplementary Declarations (CFSP)

If you’re unable to accurately calculate your supplementary declaration by your due date as a result of the COVID-19, you may submit an estimated figure.
Note that if your declaration includes an amount of Excise duty, you must submit a supplementary declaration as normal.
To submit an estimated figure you must email Cfsp_cope@hmrc.gov.uk and provide the following:

• company name
• EORI number
• deferment account number
• estimated customs duty amount owed
• estimated VAT owed
• the number of supplementary declarations not submitted

You must provide a reasonable estimate of the amounts due and keep records that explain your calculation.

Full details can be found here.

HMRC has announced that medical supplies, equipment and protective garments for use in the COVID-19 pandemic can be imported duty and VAT free with immediate effect.

This relief can be claimed by:

• state organisations, including state bodies, public bodies and other bodies governed by public law
• other authorised non-state bodies
  (non-state bodies should obtain authorisation by contacting the National Import Relief Unit (NIRU) by emailing niru@hmrc.gov.uk for an application form)
  
  

Goods imported into the UK for donation or onward sale to the NHS are also eligible for this relief and can be imported free of import duty and import VAT.

You can also claim relief if you’re a disaster-relief agency and are importing goods for free circulation to meet your needs during the COVID-19 outbreak.
The relief applies until 31 July 2020.

You can claim relief on your declaration in CHIEF by entering in:

• box 37 the customs procedure code 40 00 C26
• box 44, declaration/notes, enter document codes 9AID and/or 9AIV and status codes JP or UP as appropriate

Full details of this easement can be found here.