The phrase 'the devil is in the detail' is of particular relevance to the new EU Import Control System (ICS) effective from the start of the year.
The legislation is applicable to all UK businesses importing products from outside the EU. It is of major importance to the grocery industry, which has an obligation to regularly review HMRC commodity codes to ensure they are completely accurate from detailed descriptions of the cargo and the importer's country of destination to the importer's Economic Operator Registration Identifier (EORI) and other relevant details. If any details are incomplete or inaccurate, grocery consignments entering the EU may be mis-declared or cause costly delays.
UK Customs, which is actively conducting a campaign to eliminate erroneous declarations, will not extend any concessions to importers who have imported and cleared consignments with incorrect codes. Records going back three years may be inspected to expose inaccuracies, and underpayments of additional duties reclaimed. Conversely, overpayments will be refunded.
Processed foodstuffs are particularly difficult to classify accurately and can be suffixed by additional codes based on specific ingredients: starch, sugar, milk fat and milk proteins, by percentage, for example. Independent analysis of these agricultural products may be required to guarantee accuracy.
Importers worried about eliminating accuracies have the option of switching terms from Cost and Freight to Free on Board (FOB) and employing an experienced forwarder who can assist in all aspects of the supply chain. FOB will guarantee that goods are delivered to deadlines, at a fixed price, with paperwork and codes all in order. Reputable forwarders have the expertise to advise importers who lack knowledge of this complex area.
Faced with the revised ICS, importers should ask themselves: does our import supply chain guarantee full compliance; is it cost-effective; and do our consignments always arrive on time? If the answer to one or more of these questions is no, it may be time to rethink logistics operations. n
Philip Edge is director of Edge Worldwide Logistics