Recently Integration Point held a webcast on the European Union’s (EU) Union Customs Code (UCC) and what organizations need to know now that we are almost one year away from implementation.  The presenters were from the United Kingdom’s HM Revenue & Customs (HMRC) team that has been working on the UCC. During the webcast there were several questions that we were not able to answer due to time. The panel agreed to provide answers to those questions to be posted here.  The first set of Q&A dealt with Authorised Economic Operator or AEO and why it is important in the UCC.  You can find that post here.

This second set of Q&A focuses on Inward Processing Relief (IP or IPR) and Processing under Customs Control (PCC).

If you missed the webcast, you can view it on-demand here.

To clarify, does release to Free Circulation for IP goods discharge liabilities on the imported goods or is it merely the intention to re-export which has been removed?

Goods entered to inward processing may be discharged to free circulation paying duties due under Article 85 or 86(3) UCC

 

So Inward Processing and "PCC-Processing under customs control" will be combined, won't they?­

Effectively yes. The option of the two charging rules brings together the two procedures.

 

Where can we get further information about the Inward Processing changes?­

A revised public notice will be available later in the year.

 

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Can goods brought in under the new IP rules, having no intention to export, be imported specifically for destruction?­

Yes. The draft legislation allows goods to be entered to inward processing for the purposes of reduction to waste and scrap, destruction or recovery of parts and components

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The last speaker said that all authorisation will be honored to the date of expiry. We just renewed our IPR and END Use authorisations in November 2014 for a three year period and HMRC only gave us until 30th April 2016. Is this correct? Can we appeal?­

Certain authorisations such as IP Drawback and PCC will no longer exist under the UCC. The authorisations were issued prior to any transitional arrangements being agreed (they are still to be finalised). If you wish to ask for an extension you may do so but if you wish to take advantage of the new facilitations under the UCC (for example, no requirement to re-export IP goods) then a new authorisation based on the UCC will be required from 1 May 2016

 

Please clarify, if import under IP can either re-export or move to free circulation?­

Yes. Goods declared to IP can be re-exported or declared to free circulation

 

Will there still be a through put period for IPR?­

Yes. The rules for calculating the through-put period remain unchanged

 

If PCC is ceasing, how does a business get relief in the case of an inverse tariff?­

Under IP, goods can be declared to free circulation based on the duty elements at the time the goods entered IP (traditional IP) or at the time they are declared to free circulation (reflecting the PCC aspects of IP)

 

The next round of Q&A will focus on Valuation and the UCC.