Maria's Blog

How to find the right Commodity code in the UK?

2011-02-18T03:38:00.000-08:00

Any item imported into the UK has a commodity code (tariff heading) and this must be detailed on the C88 on import.

Although the shipper of the goods is responsible for advising the commodity code and the clearance agent is responsible for completing the import customs clearance, it is the importer who carries the ultimate responsibility to Revenue and Customs of ensuring the commodity code used is the most accurate, regardless of the rate of duty.

To find out which commodity code should be used, go to www.businesslink.gov.uk/tariff and enter the relevant information. There is also a Revenue and Customs Tariff Classification Advice Line on 01702 366077 (as of February 2011). Please note that the information given on the phone (up to 3 items only) cannot be seen as a definite decision. In order to obtain a definite decision, an application needs to be made in writing to Revenue and Customs.

SFDA Ban on Mouthwash containing Alcohol

2011-02-11T08:18:00.000-08:00

The Saudi Food and Drug Authority (SFDA) have issued circular no. 3597 dated 2.2.1432 (or 16th January 2011) banning the import into Saudi Arabia of all mouthwash and related products (used for rinsing, cleaning or sterilizing of the mouth and teeth) containing alcohol. The reason for this ban is because of the existence of permissible and alcohol free alternatives.

Ethiopian Dry Ports

2011-02-11T04:57:00.000-08:00

In 2007 the Dry Port Service Enterprise (DPSE) in Ethiopia started building a dry port at Modjo, 76 km east of Addis Ababa in the Oromia Regional State. The opening of this dry port alone cut the time it took to move cargo from Djibouti to Ethiopia from 30 days down to 10 days.

In March 2010 the DPSE opened a second dry port at Semera, also in the Oromia Regional State, 558 km east of Addis Ababa. Semera was designed to tend to the needs of vehicle importations.

It is estimated that once fully functional these two dry ports will be able to store 70% of Ethiopia’s imports. Studies have also been completed for additional dry ports in Moyale, Woyito, Hawassa, Dire Daw, Jimma and Mekele.

One of the problems recently experienced shipping goods to Ethiopia through these dry ports is that the Ethiopian Shipping Line sometimes requests that the goods be off-loaded from the containers at the dry port. This can cause a problem if the exporter to Ethiopia believes that the goods will be shipped in the container direct to the customer’s premises and has not packed the goods with any additional protection.

Although the Martime and Transit Service (MTSE, which is a big government organization that specialises in moving equipment from the port to Addis Ababa it would be prudent to check before arranging any shipment whether the goods will be offloaded at the port or at the customer’s premises and to pack accordingly. Especially since Modjo Dry Port is 76 km from Addis Ababa and Semera is 558 km away and the road surfaces in between may be problematic especially during the rainy season.

Random Scans at European Seafreight ports

2011-02-11T04:29:00.000-08:00

One of the possible hidden costs when sea-freighting goods from European ports, is that Customs are allowed to seize containers without notice on a random basis for a Customs Scan. In most ports the scanning procedure is completed on site, but some ports, such as Hamburg in Germany (as of January 2011) lack these facilities and the container has to be shipped ex Terminal to an external scan checking point.

This can be expensive. Customs are allowed to charge terminal charges (Gate In/Gate Out) and also trucking charges which together can cost from Euro 550.00 (as of January 2011) upwards. These prices (in ports where the scan check is not on site) include the following procedures.

- Container to be trucked from the Terminal to the Scanning Area
- Trucking back to the Terminal
- Scanning
- Waiting Time
- Gate-In
- Gate-Out
- Additional Terminal Handling
- Release

There is also a chance that if the scan shows an inconsistency between the export documentation and the details obtained through the scan, that the container could be delayed and may miss the vessel it was originally booked on. Apart from the additional costs which could include customs charges, detention charges and also storage and demurrage, there could be an additional problem if the goods are being shipped against a Documentary Credit and the original ship booked was on or close to the last shipment date on the Credit. In which case, the goods may be shipped late which could lead to a discrepant presentation.

Therefore, it is recommended that before arranging a shipment, that there is a check that the port has scanning facilities on site; that the description of goods on the export paperwork must allow Customs to easily identify the goods inside the container and, with Documentary Credit shipments, where possible, there is contingency built into the shipment date in case a check of this type happens.

UK Bribery Act 2010 Implementation delayed

2011-02-11T03:48:00.000-08:00

The United Kingdom Government has delayed the implementation of the Bribery Act which was originally due to come into force in April 2011. The implementation of this Act has been put on hold while the Government rewrites the guidance for businesses on how to comply with the 2010 law.

The Ministry of Justice has not said yet when the new guidance notes will be published, but they advise that three (3) months must pass between the publication of the guidance notes and the implementation of the law.

Hotel in Ethiopia

2011-02-11T03:40:00.000-08:00

An engineer who has just returned from Addis Ababa, Ethiopia, has advised that the best hotel he found in Addis Ababa was the Kaleb Hotel near the international airport. Their telephone number is 011 662 22 13. As of the end of December 2010 the cost of a room in this newly built hotel was USD 60.00. The engineer highly recommends the cleanliness, situation and service of this hotel, and their willingness to find him a room at short notice, when he found himself stuck in Ethiopia trying to return to the UK when Heathrow airport closed before Christmas due to snow and ice conditions.

Shipments from Yemen and Somalia

2010-11-18T08:44:00.000-08:00

New security measures came into force on 8th November 2010 for everyone involved in shipping by air to the USA. The U.S Transportation Security Administration has issued the following additional security measures.

1. There is a full embargo on all cargo originating or transferring from or transiting through Yemen or Somalia.
2. Toner and ink cartridges are subject to enhanced security restrictions based on Government and airline directives.
3. Cargo identified as "high risk" will require additional security measures and will only be permitted on All Cargo aircraft and not allowed to ship on passenger aircraft.

There may be delays shipping certain goods to the USA as a result of the above measures.

There are also UK measures which have been in place since 2nd November 2010 and these are as follows:

1. Suspension of all unaccompanied shipments from Yemen and Somalia destined to or transiting the UK. Shipments from the UK destined for Yemen and Somalia are presently unaffected.
2. There is a weight limit of 0.5 kgs for all shipments containing individual ink or toner cartridges either sent individually or as part of an office equipment package.

Booking Hotels in Ethiopia - new rules for foreign travellers

2010-11-10T01:53:00.002-08:00

In November 2010 the Ethiopian Government imposed a new regulation on Ethiopian Hotels which means that payment for hotel facilities by foreign visitors must be made in either US Dollars, Pounds Sterling or Euros. It is now no longer possible for these facilities to be paid for in Ethiopian Birr.

This matter is somewhat complicated in that a number of hotels are now not willing to provide a booking confirmation (and hence the confirmation letter that is often required to obtain an Ethiopian visa) until they have collected a down payment (anything between 35% - 50%) in foreign currency from the visitors or their agents.

Suspension of Ugandan PVoC Programme (Nov 2010)

2010-11-10T01:53:00.001-08:00

In June 2010 the Ugandan Government implemented a series of guidelines known as a Pre-Export Verification of Conformity to Standards Programme (PVoC). The PVoC verifies the conformity of all regulated products and enforces their standards, therefore assuring Ugandan consumers of the quality and safety of imported goods.

This means that every consignment of imported goods must be accompanied by a Conformity Certificate which can be obtained from agencies such as Intertek and SGS. These Certificates are required on import to ensure customs clearance of shipments.

However, on 5th November 2010 the Uganda Bureau of Standards (UNBS) advised that the PVoC programme was to be suspended with immediate effect. The reason for this decision is presently unclear, but it means that no new applications for the Conformity Certificate can be accepted until further clarification on this decision is ascertained.

This report is issued on 10th November 2010.

Demurrage discharge costs for containers

2010-10-28T08:20:00.000-07:00

Most shipping lines require their containers to be unloaded and returned back to a port after a short period of time so that they can be re-used quickly for new shipments. If a container is not returned after usually a week (7 running days) after the vessel has discharged its containers, then the importer and sometimes the shipper (depending on the terms of shipment) can find themselves with demurrage costs.

These vary between shipping lines, but can be anything from Euro 20 each for a 20' container and Euro 40 for a 40' container per day for the first seven days after the initial week and then Euro 40 for a 20' container and Euro 80 for a 40' container thereafter. Open top and other specially equipped containers are usually charged at double these rates.

Refrigerated containers (Reefer) are usually required back at the port 3 running days after the vessel has discharged and for days 4-10 after the date of discharge the costs per container can be Euro 70 for a 20' and Euro 110 for a 40' per day and then Euro 110 for each 20' container and Euro 220 for each 40' container.

These rates can be different for different shipping lines and should be checked beforehand and everyone involved should be advised beforehand of these costs and arrangements made for the containers to be unloaded and returned to the relevant port as soon as possible.

Introduction to ISPM 15

2010-10-28T08:19:00.000-07:00

A number of countries around the world require wooden packaging materials to be treated to a standard known as ISPM 15 (International Standards for Phytosanitary Measures 15). This is a regulation which aims to stop the spread of pests and diseases which may inadvertently be transported in unprocessed raw wood used to make various types of packing material.

This regulation is controlled by International Plant Prevention Convention (IPPC) and it applies mainly to the use of untreated coniferous softwood and non-coniferous hard wood, but not to the use of plywood, veneer, constituted wood products or products where glue, heat and pressure or a combination have been applied.

ISPM 15 requires wood packaging material (WPM) to be heated treated to 56 degrees centigrade for 30 minutes at the core of the product or treated with Methyl Bromide as a fumigant. In some circumstances, only a Methyl Bromide treatment is effective, for example, against pests such as the Kappa and Bark beetle.

Treated wood has the IPPC mark which consists of a rectangle with the IPCC “wheat sheaf” logo on the left and an XX-0000 YY code on the right. XX refers to the country code, 0000 is a unique identification mark of the wood treatment agent or packaging manufacturer and YY the type of treatment used (HT for Heat Treatment and MB for Methyl Bromide).

As of October 2010 the ISPM15 regulation is implemented in Argentina, Australia, Bolivia, Brazil, Bulgaria, Canada, Chile, China, Colombia, Costa Rica, Cuba, Dominican Republic, Ecuador, Egypt, European Community, Guatemala, Guyana, Honduras, Hong Kong, India, Indonesia, Israel, Japan, Jordan, Lebanon, Malaysia, Mexico, New Zealand, Nicaragua, Nigeria, Norway, Oman, Paraguay, Peru, Philippines, South Korea, Russia, Seychelles, South Africa, Sri Lanka, Switzerland, Syria, Taiwan, Turkey, Ukraine, USA and North America.

Even though these countries have all implemented ISPM15, some countries require additional and stricter controls. For example, the Australian Quarantine requirements prohibits the entry of wood products infected with non indigenous bluestain. Since ISPM 15 treatments are not lethal to bluestain fungi, and the heat treatment in the absence of moisture reduction could actually increase susceptibility to this infection, it is recommended that for shipments to Australia other treatments for the wood in addition to ISPM 15 should be used. The additional requirement is for the wood to be kiln-dried to below 20% moisture content, which is indicated by the mark ‘KD’ or ‘kiln-dried’ on the wood packaging unit. However, since timber, even if kiln dried, has a tendency to absorb condensation during long container voyages, kiln drying does not guarantee that bluestain infection will not develop.

It is always a good idea to check whether the country being exported to has special requirements for packing at the time of the contract negotiations, since the cost of complying with the regulations can be costly if the shipment is large.

Finacial pitfulls for the Seller with the DDP Incoterm

2010-10-27T03:26:00.000-07:00

According to the International Chamber of Commerce (ICC) Incoterms 2010, DDP (Delivery Duty Paid) means that the seller delivers the goods when the goods are placed at the disposal of the buyer, cleared for import on the arriving means of transport ready for unloading at the named place of destination.

The seller bears all the costs and risks involved in bringing the goods to the place of destination and has an obligation to clear the goods not only for export but also for import, to pay any duty for both export and import and to carry out all customs formalities.

This term carries a number of risks and costs to the seller that may never have been anticipated at the time that the contract was agreed. In fact, the seller may be placed in a position where they become victim to bad management and unless they are protected in their contract with the buyer, they may find no recourse to these costs.

The first problem is that in a number of countries an organization cannot clear goods through customs and pay any duties or taxes due unless they are registered in that country. Since registration can carry other responsibilities such as company account reporting or a liability to various taxes (e.g. Corporation Tax), then becoming a registered company may not be a possible course of action. This is especially the case when there is only one shipment involved.

The best course of action is to use a term such as DAP (Delivered at Place) where the clearance is down to the buyer, but what if obtaining the contract is based on accepting DDP terms only? Does an organization decide to avoid a lucrative contract because of potential risks? Only the organization concerned can make this decision.

It could be that the buyer will offer to clear the goods for the seller and then charge back the costs to the seller. This might be acceptable if the seller can use their own agents for the job, but what if the buyer insists on using their own clearance agent? The problem here, immediately, is that the seller loses complete control on what happens to the goods once they are delivered to this third party, and have no way of determining costs, whilst simultaneously being completely responsible for all costs.

The most unpredictable and potentially costly of all charges is storage (often known as demurrage), especially with airfreight shipments. If the clearance agent of the buyer does not clear the goods in a timely fashion, or “loses” the goods in a bonded warehouse for some time once they have been passed to them by the transport company, (especially with large shipments) then the storage costs that accrue have to be paid by the Seller, even though they have completed all documents correctly and shipped the goods in the agreed manner. These costs can be anything from a few hundred US Dollars to USD 30,000 depending on the size of the shipment.

Unless the Seller has asked for this eventuality to be considered in the contract, and the costs, if any, passed to the buyer due to the mishandling, or worse, from their clearance agent, then the Seller might find their profit margins seriously eroded by such costs. One solution might be to add financial coverage at the time of negotiation, but this could end up with the Seller out-pricing themselves in the market place.

So it would be good practice to negotiate, at the contract stage, for any additional costs, after a period of perhaps 2 days after the goods have been released by the transport company, to be borne by the Buyer, because their clearance agent has misplaced the goods or been tardy in their work. If the Buyer refuses, whilst still insisting on using their clearance agent, then the Seller may have to consider the reasons why and make a commercial decision at the time whether to proceed with the contract.

Cargo Tracking Note (CTN)

2010-10-22T03:25:00.000-07:00

The Nigerian Ports Authority (NPA) requires validated and endorsed Cargo Tracking Notes (CTN) for all consignments (including groupage consignments within containers) to Nigeria. This came into effect on 11th January 2010.

It was introduced to improve cargo security and safety by providing adequate information to help in tracking them, says the NPA. Port Authorities and terminal operators can now be more accurate in taking inventories and locating items in ships at all times. It is also advised that the CTN can help reduce the risk of terrorist attacks and assist with customs clearance procedures.

It is now mandatory for all cargo coming out of or into Nigeria, whether imports or exports, to be accompanied by a cargo tracking note and every bill of lading has to be accompanied by a corresponding cargo tracking note number.

The CTN can only be obtained from the country representative of the Port of Loading.

If cargo arrives in Nigeria without a CTN, the receiver risks demurrages and warehousing costs until a valid CTN has been delivered by the loading port.
The costs for these certificates vary, but it would be good practice to contact the relevant country representative at the contract stage to find the cost and add this to the contract price

Apostille

2010-10-22T03:01:00.000-07:00

An Apostille (a French word meaning certification) is an international certification comparable to a notarisation in domestic law. It came into being as a result of a meeting of a Hague Convention (No 12 in January 1965) which wanted to abolish the requirement of legalisation for foreign public documents. This used to be a complex and time consuming process and has been replaced by a simple certificate issued to a specific format.

Not all countries are members of this convention, but most will accept a foreign document once it has been issued with an Apostille Certificate and then legalized by their own Consulate in the foreign document’s country of origin.

In the UK the Legalisation office of the Foreign and Commonwealth Office (FCO) is the only authority competent to issue Apostilles in the UK.

An issuance of an Apostille is the official confirmation that a signature, seal or stamp on a UK public document is genuine. However, legalisation does not certify the authenticity of a document or give Foreign and Commonwealth Office approval of its content.

Before sending a document to be legalised to the FCO, it is necessary that organizations/individuals first check the legalization requirements of the relevant authority in the country in which their documents are to be presented before submitting their application.

The FCO can legalise most UK documents as long as they bear an original signature or seal from a UK public organization. However, an Apostille cannot be attached directly to a document produced or executed in a foreign country, although a photocopy of this document, if certified by a UK notary public or UK solicitor can be legalised. This is also the case if the original document issued overseas is attached to a UL notarial certificate.

Some documents may have to be certified by a UK notary public or UK solicitor before being submitted for legalisation. Please note that in some countries, such as the USA, Canada and Australia, they may only recognise documents notarised by a qualified notary public and may not accept a document certified by a solicitor who is not a qualified notary public.

Some original documents, such as those issued by a Government Department, may not need to be notarized but can just be presented as they are for the Apostille stamp. Copies, however, nearly always need to be notarised first.

Applicants can legalise documents in Milton Keynes by visiting the office in person (there is a 24 hour turnaround counter service for business customers) or by posting the applications to Milton Keynes. It is also possible for applicants to use the premium same day service in Central London.

This involves registering for the Premium service with the FCO through their website (www.fco.gov.uk), obtaining a registration and password and then paying on-line for the documents required. A voucher is then issued to verify payment and this, along with the documents can be taken to the Central London office (a time slot is given of 90 minutes) and the documents are stamped immediately. Although this is more expensive than the Milton Keynes service, it does provide a faster service.

Alternatively, there are other organizations which will assist applicants with obtaining an Apostille for their documents, such as solicitors and specialist consular agencies who deal with this type of document and it is always useful to check with them first in case they can offer a more competitive service.

CPC for Customs Freight Simplified Procedures

2010-10-21T10:49:00.000-07:00

When importing goods into the UK, a Customs Procedure Code (CPC) must be used to declare the type of procedure being used under which the goods are being imported. Detailed below are codes used with the Customs Freight Simplified Procedures (CFSP). However, please check with HM Revenue and Customs and the Clearance agent before using the code to ensure that it is

a) still the correct code
b) your organization has the right to use this code because of agreements made with
HM Revenue and Customs

Import Customs Procedure Codes.
06 10 040 SDP (Simplified Declaration Procedure) release to free circulation
06 10 061 SDP release to a Customs Procedure with Economic Impact
06 11 000 LCP (Local Clearance Procedure) release to National Transit
06 11 001 LCP release to Community Transit
06 11 002 LCP release to National Transit for goods requiring Conformity
and/or Phytosanitary Certificates
06 12 071 SDP release to types A, C, D and E Warehousing
06 13 040 LCP – Part removals from Temporary Storage (TS)
06 14 078 SDP release into Free Zone
06 19 090 Customs FSD (Final Supplementary Declaration)

06 20 040 Controlled goods released to free circulation (route 1 or 2)
06 20 061 Controlled goods (including alcohol and tobacco products)
released to a Customs procedure with economic impact, RGR
and End Use
06 22 071 Controlled goods (including third country alcohol and tobacco
products) released to Warehouse types A, C, D and E.
06 24 078 Controlled goods (including third country alcohol and tobacco
products) released into Free Zone
06 30 040 SDP Controlled drugs released into Free Circulation
06 30 061 SDP Controlled drugs released to a Customs Procedure with
Economic Impact
06 32 071 SDP Controlled drugs released to types A, C, D and E
Warehousing
06 34 078 SDP Controlled drugs released into a Free Zone
06 40 040 SDP Excise goods released to Free Circulation (route 1 or 2)
06 49 090 Excise FSD (Final Supplementary Declaration)

71 71 000 Used when moving goods from one customs warehouse
authorization holder to another customs warehouse
authorization holder.

Customs Freight Simplified Procedures (CFSPs)

2010-10-21T10:43:00.000-07:00

HM Revenue and Customs devised the CFSP’s to facilitate the movement of goods through Customs faster and more easily. This is quite a complicated procedure and by necessity this report is an introduction only to CFSP.

There are presently two types of CFSPs, both of which are covered through the Customs Handling of Import and Export Freight (CHIEF) system. These are the Simplified Declaration Procedure (SDF) and the Local Clearance Procedure (LCP).

The relevant HMRC notice for these procedures is Notice 760 Customs Freight Simplified Procedures (CFSP).

Anyone using CFSP must be pre-authorized by Revenue and Customs to do so, and anyone wishing to apply to use these systems needs to complete a C&F 48 application form. This can be downloaded from the HM Revenue and Customs website.

There are certain qualification criteria for organizations to use a CFSP.

a) Organizations must be registered as a sole trader, partnership or limited
company and must have an EORI registration against which they declare
imports from outside the EC on a regular basis.
b) Organizations must be financially solvant and have a good compliance record
with Customs and other regulatory bodies.
c) Organizations must have access to an electronic reporting system, be
able to maintain a set of documented procedures which accurately
describes the accounting and logistical processes of the business and
enables Customs (if required) to perform audit-based controls.
d) Organizations must be able to use a duty deferment facility or that of
a third party for payment and security purposes.

Certain categories of goods, such as meat or animal products, which are subject to border health checks, are excluded from the full CFSP procedure.

It is important to remember that Authorized CFSP traders are expected to take full responsibility and complete control over the import of their goods, ensuring all goods are declared accurately and in a timely fashion.

1. Simplified Declaration Procedure (SDP)

SDP is used for releasing goods at the frontier to another customs procedure such as free circulation, IPR (Inward Processing Relief), Processing under Customs Control, End Use, Temporary Imports, movement into a Free Zone or into Customs Warehousing.

This procedure must be used when importing (amongst other items) firearms and licensable weapons as controlled goods, fireworks, hydrocarbon oil products and fresh fruit and vegetables which are subject to CAP licences.

All traders using this procedure must be approved as an Authorized Consignee for Common/Community Transit (CT) or National transit (for UK only movements) and hold a transit guarantee before they can use the LCP. Authorized Consignee status allows traders to nominate their control office as the Office of Destination on the transit movement. The goods don’t have to be physically presented at this office, but it is necessary that all copies of transit documents are lodged with the Office of Destination within one working day of the arrival of the goods at the premises. If traders wish to use CT, they are required to communicate with Customs and end their transit movements electronically on the NCTS (New Computerized Transit System).

When the goods arrive at the frontier, the trader provides minimum details using the Simplified Frontier Declaration (SFD). The trader must allocate a Declaration Unique Consignment Reference (DUCR) to each consignment, which must be entered in box 44 of the SFD and SD (Simplified Declaration)

The SD is an electronic message sent to CHIEF which contains fiscal and statistical information and allows Customs to calculate the tax and duties due. The SD must be sent to and accepted by CHIEF before the end of the fourth working day of the month following acceptance of the SFD.

2. Local Clearance Procedure (LCP)

This procedure allows traders to remove their goods from the frontier and clear them at a designated premises inland. Please note, however, that to use LCP, the trader needs additional authorization for the transit procedures as well as the authorization for CFSP. In addition, the trader must be authorized to hold a comprehensive guarantee or guarantee waiver to become an authorized consignee.

This procedure cannot be used to import firearms or any licensable weapon, hydrocarbon oil products or fireworks (amongst other items).

On arrival at the frontier, the trader provides minimum details of the shipment using Simplified Frontier Declaration (SFD). The date on the SFD creates the base for a more detailed declaration and also the tax point for paying duty and taxes (unless the goods are entering a Customs warehouse). For controlled goods allowed under this procedure, the trader must present import licences or certificates with the hard copy of the SFD.

Generally speaking, however, most controlled goods cannot be imported under LCP. The exception is with controlled goods where authorization to enter under LCP has been pre-agreed with HM Revenue and Customs

Imports move from the frontier under either the New Computerized Transit System (NCTS) or National Transit. Once the goods have arrived at the designated premises, the transit movement is ended by the trader notifying the NCTS or the CNAT (CFSP National Assurance Team) depending on the type of transit movement used.

Once the goods have arrived and notification has been made the goods are deemed to be in Temporary Storage (TS) and the consignment details are entered into the TS records held by the trader. In most cases, consignments will be assigned immediately to a customs procedure, e.g. free circulation, providing all supporting documentation required under that procedure is available. To ensure the goods are released quickly, the correct customs procedure codes (CPC’s) must be used.

If the documentation is not available, or the trader does not wish to enter the goods immediately, the goods may remain in TS for up to 20 days, by the end of which the goods must be entered to a customs procedure.

If it appears likely that the trader cannot meet this 20 day deadline, then CNAT must be advised no later than 5 days before the 20 day deadline is due to expire, either by e-mail, fax or post. The Trader submits the Supplementary Decarlation (SD) on the import before the end of the 4th working day of the month following the month of acceptance of the SFD.

Definitions of Terms used in UK Import Procedures

2010-10-21T10:37:00.000-07:00

This report sets out to define some of terms used in UK Import Procedures.

Authorized Economic Operator (AEO)
An AEO is an economic operator who, by satisfying certain criteria, is considered to be reliable in their customs operations throughout the European Community and is therefore entitled to a number of benefits such as a lower risk score, fast tracked consignments, recognised status across the EC, and an industry ‘kite mark’ and useful marketing tool. Depending on the type of AEO certificate applied for and granted, these can include either easier access to certain customs simplifications or certain facilitations from customs security and safety controls, or both. There are three types of Certificate: Security and Safety, Customs Simplification and Customs Simplification/Security and Safety. HMRC Notice 117 (February 2010) refers.

C88
The C88 is the customs declaration form completed by importers or their agents to declare goods to Customs. It contains information about the parties involved in the import, the means of transportation of the goods and statistical data. Agents can input the data direction through the CHIEF system and produce a ‘plain paper’ print which contains all the same information as a C88. This is called a Trader input Plain Paper C88. All entries, whether input electronically or through submitting a C88 will, once accepted by Customs, be issued with a unique entry number. This number is printed on the Entry Acceptance Advice and is the proof that the entry was input and accepted by Customs.

Common Agriculture Policy (CAP) Licence
The system of CAP licensing provides much of the information needed for the management of the European Community’s agricultural market sectors. Many agricultural commodities cannot be imported into the European Community without a valid licence. Licences may also be used to restrict imports by imposing quantitative limits, or allow a reduced rate of duty. They are usually issued by RPA (Responsible Paying Authority) on request against a security, which is forfeited if the quantity of goods for which the licence was issued is not imported. Licences issued in other Member States are valid in the UK. HMRC Notice 780 (May 2003) refers.

Community System of Duty Reliefs (CSDR)
Subject to varying conditions, CSDR provides a range of reliefs from import duty on goods imported for specific purposes. In some cases, there are parallel reliefs for VAT and Excise Duty. Organizations providing educational, scientific, medical or cultural services or involved in the testing of goods for information or commercial research can benefit, as can individuals importing personal belongings, inherited goods, specialised goods for the disabled, private gifts or awards or decorations conferred on the individual.

Community Transit (CT)
CT is a Customs procedure, which allows goods not in free circulation (goods imported from outside the European Community (EC) on which no customs formalities have been completed and no duty has been paid), and those few Community goods for which CT is required, to move within the EC. Whilst under the procedure the payment of any customs duty or other charges is duty suspended. CT is also used to control the movement of such goods to and from Andorra, San Marino and the “special territories” of the Community such as the Channel Islands. The procedure has also been extended to cover the movement of goods across the EFTA countries (Iceland, Lichtenstein, Norway and Switzerland) by virtue of a separate customs convention and is then known as “Common Transit”.

Customs Freight Simplified Procedures (CFSP)
HM Revenue and Customs devised the CFSP’s to facilitate the movement of goods through Customs faster and more easily. There are presently two types of CFSPs, both of which are covered through the Customs Handling of Import and Export Freight (CHIEF) system. These are the Simplified Declaration Procedure (SDF) and the Local Clearance Procedure (LCP). The relevant HMRC notice for these procedures is Notice 760 Customs Freight Simplified Procedures (CFSP).

Customs Handling of Import and Export Freight (CHIEF)
This is the name of the computer system used by HM Revenue and Customs to log all imports and exports into the United Kingdom

Customs Procedure with Economic Impact (CPEI)
The CPEI procedures are a set of procedures, all of which are designed to help businesses based in the European Community to compete in the global market economy. Importers can suspend paying duty and VAT on goods covered by CPEI arrangements. The procedures that are covered by CPEI are Outward Processing Relief (OPR), Temporary Imports (TI), Inward Processing Relief (IPR) and Processing under Customs Control (PCC).

Customs Warehousing
A full description of Customs Warehousing can be found in HMRC Notice 232.
Customs Warehousing is a storage arrangement where the payment of import duties and/or VAT is suspended or delayed when non-Community goods are stored in premises or under and inventory system authorised as a Customs Warehouse. A Customs Warehouse can either be a defined location (such as premises or place) or an inventory system authorised by HM Revenue and Customs for storing non-Community goods. Depending on the circumstances, a defined location can be the whole of a building, an open site, a silo or a storage tank.

There are 6 different types of Customs Warehouses in the European Community classified as A – F. Types A, C, D and E are available in the UK.
A is a Public Warehouse, which is authorised for use by warehouse keepers whose main business is the storage of goods deposited by other traders (depositors).
C is the basic Private Warehouse, where goods are stored which have been deposited by an individual trader authorised as the warehouse keeper. The warehouse keeper need not necessarily own the goods but must be the depositor.
D is an alternative Private Warehouse, appropriate to traders who primarily import goods for free circulation. Any removals to free circulation must be made using the local clearance procedure using the rules of assessment established when the goods are entered to the warehousing procedure. The rules of assessment cover the nature, value and quantity of the goods.
E is another form of Private Warehouse in which a company and its commercial accounting and stock control systems are authorised rather than a defined location. The rules of assessment arrangements applicable in a type D Warehouse can also apply if requested.

Different types of Duty chargeable on UK Imports
Anti-Dumping Duty (ADD) is an import duty charged in addition to normal customs duty and is applied across the whole European Community. It is designed to allow the European Community to take action against goods that are sold at less than their normal value – that being defined as the price for ‘like goods’ sold in the exporter’s home market. It is possible for goods charged anti-dumping duty to also be charged Countervailing duty.
Countervailing duty (CD) is a customs duty imposed on goods which have received government subsidies in the originating or export country. For customs purposes it is treated in the same way as anti-dumping duty. It is possible to have both anti-dumping duty and countervailing duty on the same product.
Customs Duty is a tax charged on importation of goods produced outside the European Community and is charged as a percentage of the total value of the goods (sterling equivalent if the goods are imported in a currency other than sterling).
Excise Duty is a tax on certain goods such as alcohol and tobacco. The rate of Excise Duty on alcohol products is based on their alcohol content and volume and, in the case of wine and cider the rate also depends on whether they are still or sparkling. The rate of Excise duty on cigarettes is based on a percentage of the retail price. For other tobacco products such as cigars, Excise Duty is charge at a flat rate per kilo.

End Use Relief
End-use is a Customs procedure which provides relief to promote certain European Community industries and trades. To qualify for relief the goods and/or processes must be eligible for end-use, the trader must be authorised for the relief (except for certain goods detailed in the Customs Tariff) and the goods must be put to their prescribed end-use within agreed time limits. HMRC Notice 770 refers.

Free Zone
A Free Zone is a designated area in which non-Community goods are treated as being outside the Customs territory of the Community for purposes of import duties. This means that import duties (including agricultural charges) are not due provided the goods are not released for free circulation. Import VAT is also suspended until the goods are removed to the UK market or used or consumed with the Free Zone. UK Free Zones are controlled principally on the basis of the requirements of customs warehousing procedures. There are no special reliefs in Free Zones from other taxes, excise duties or local authority rates. There are currently 5 Free Zones in the UK located at Liverpool, Prestwick, Sheerness, Southampton and Tilbury. To operate within Free Zones a trader need prior authorization from Customs and a supporting letter from the Free Zone Manager. HMRC Notice 344 Free Zones, refers

Inland Clearance Depot (ICD)
An ICD is an inland site, usually made up of individual transit sheds, approved by Customs for the temporary storage, examination and clearance of goods controlled by customs officers at the local customs office. An ICD may be used for the storage of freight not subject to temporary storage control. The area used for holding goods in temporary storage must be clearly demarcated from any other area within a transit shed and this information clearly shown on the site plan.

Inward Processing Relief (IPR)
IPR provides relief to promote exports from the European Community and assist Community processors to compete on an equal footing in the world market. Duty is relieved on imports of non-European Community goods which are processed in the Community and re-exported provided the trade does not harm the essential interests of Community producers of similar goods. It can provide relief from customs duty, anti-dumping duty and countervailing duty. Import VAT and excise duty is not due when entered to IPR Suspension but is due if entered to IPR drawback. HM Revenue and Customs Notice 221 (September 2007) refers.

Local Clearance Procedures (LCP)
This is one of the Customs Freight Simplified Procedures (CFSP) which allows traders to remove their goods from the frontier and clear them at a designated premises inland. Please note, however, that to use LCP, the trader needs additional authorization for the transit procedures as well as the authorization for CFSP. In addition, the trader must be authorized to hold a comprehensive guarantee or guarantee waiver to become an authorized consignee.

National Transit
This relates to the transport of goods within the United Kingdom only. The National Transit declaration takes the form of a simplified Single Administrative Document SAD known as a Simplified Frontier Declaration (SFD), which must be submitted electronically to CHIEF via Direct Trader Input (DTI) to effect release of the goods. This SFD only requires a minimum number of boxes to be completed. For CFSP purposes the CT comprehensive guarantee/guarantee waiver is restricted for use with National Transit movements only. Any goods released from the frontier using national Transit must move directly to the trader’s designated premises inland. A time limit is set within which the goods must be presented at the office of destination and for the purposes of National Transit this time limit must not exceed three working days.

New Computerized Transit System (NCTS)
NCTS is a European Community wide system, based on electronic declaration and processing, which is designed to provide better management and control of goods under CT (Community/Common Transport) procedures. Where an NCTS declaration has been made, official evidence of export will be confirmation that the CT procedure has been discharged.

Outward Processing Relief (OPR)
OPR provides duty relief on imports from third countries of goods which have been produced from previously exported Community goods. It enables businesses to take advantage of cheaper labour costs outside the EC, while encouraging the use of EC produced raw materials to manufacture the finished products. Goods may be also temporarily exported to undergo processes not available in the European Community.
The procedure also enables faulty goods to be returned to a third country for repair, or for replacement with equivalent goods under the Standard Exchange System (SES).
HMRC Notice 235 (April 2005) refers.

Phytosanitary Certificate
This is a certificate required when importing plants and certain plant products into England and Wales. A phytosanitary certificate is a statement issued by the plant health authorities in the exporting country that the material to which it relates has been officially inspected in the country of origin or country of despatch, complies with legal requirements for entry into the European Community and is free from certain serious pests and diseases. From November 2008 all controlled plant health imports into England and Wales will be customs cleared only on receipt of a completed faxed copy of a Quarantine Release Certificate (QRC). This certificate can be obtained from the Defra PEACH system. Please note that Customs will no longer clear consignments with a phytosanitary certificate.

Processing under Customs Control (PCC)
Generally speaking imported goods carry higher rates of duty than the raw materials or components from which they are manufactured. In some cases, however, processed products attract a lower rate of duty than the goods from which they are made. In some cases these tariff anomalies tend to make it more economical to import finished products directly from outside the European Community, than to import the raw materials and manufacture the products in the Community. The PCC procedure is a trade facilitation measure, intended to encourage processing in the Community by allowing certain raw materials or components to be imported under duty suspension arrangements. After processing, the finished products may be declared to free circulation at the lower rate that applies to them rather than the rate which applies to the raw materials. HMRC Notice 237 (June 2003) refers.

Rejected Imports
It is possible to obtain repayment or remission of import charges on imported goods which are rejected because they are not in accordance with the contract or are defective.

Returned Goods Relief (RGR)
This is a procedure which allows traders to import returned goods free of duty and tax. RGR is available to goods being re-imported to the European Community which, at the time of export were in free circulation, or were compensating products resulting from an inward processing operation, or had previously been imported at a reduced rate of duty. HMRC Notice 236 refers.

Simplified Declaration Procedure (SDP)
SDP is one of the Customs Freight Simplified Procedures and is used for releasing goods at the frontier to another customs procedure such as free circulation, IPR (Inward Processing Relief), Processing under Customs Control, End Use, Temporary Imports, movement into a Free Zone or into Customs Warehousing.

Temporary Storage (TS)
Goods have the status of goods in temporary storage from the time they are presented to Customs until they are assigned to a Customs approved treatment or use. A temporary Storage or approved depository facility is a place situated inside or outside the approved area of a sea or airport, where non-Community goods may be placed in storage prior to being assigned to a Customs approved treatment or use. Such facilities are authorized by HM Revenue and Customs for this purpose. An approved depository can only be used for the storage of personal effects whilst temporary storage facilities are generally used to store commercial non-European Community goods. HMRC Notice 199A (May 2009) refers.

RIA Special Procedures

2010-10-21T10:36:00.001-07:00

When importing into the United Kingdom, there are presently 12 different Customs suspensive regimes, each with its own set of unique rules and requirements, such as CPEI (Customs Procedures with economic interest), IPR (Inward Processing Relief), PCC (Processing under Customs Control), TI (Temporary Imports), Customs Warehousing, Free Zones, End-Use and Temporary Storage and Transit.

The problem is that these are costly, difficult and time consuming to administer and traders in the United Kingdom have often expressed their desire for a single suspensive arrangement to be developed, within which they may process, use, move or store goods, without the need to enter goods to a specific regime and transfer goods between procedures.

The objective of Revenue and Customs with any change to these systems is to

- ensure greater consistency in the application of Customs rules amongst Member
States (MS)
- simplify legal requirements
- streamline processes
- provide for greater use of electronic systems

The creation of these special procedures aims to

- group together as ‘special procedures’ all customs procedures other than simple
release for free circulation or export
- reduce the number of procedures currently in existence and create a smaller
number of streamlined procedures.

More Information on Incoterms 2010

2010-10-14T08:35:00.000-07:00

The International Chamber of Commerce (ICC) has now published their Publication No. 715E on Incoterms 2010. These rules can be used from 1st January 2011, although there is nothing to stop organizations from using previous Incoterms as long as this is stated in the contracts in the correct manner and all parties in the contract agree to their use.

There have been a number of changes between Incoterms 2000 and Incoterms 2010 although not as dramatic as the changes between Incoterms 1990 and Incoterms 2000 when, amongst other changes, the phrase C & F was supposedly abolished. We mention this, because even today C & F is often used in contracts world wide.

Interestingly enough, the ICC have stated on the front of their publication that these are the ICC rules for the use of domestic and international trade terms. For some time there has been a movement towards Incoterms being used with domestic contracts involving the shipment of goods, as well as international ones, and in fact there is nothing to stop a company using these terms in a domestic context. The proviso being, as usual, that everyone in the contract chain is aware of the meaning of the Incoterm, if used.

Another interesting point is that the ICC have changed the format of presenting the Incoterms, arranging these now in two groupings.

The first grouping consisting of EXW (Ex-Works), FCA (Free Carrier), CPT (Carriage Paid To), CIP (Carriage and Insurance Paid To), DAT (Delivered at Terminal), DAP (Delivered at Place) and DDP (Delivered Duty Paid) can be used for any mode of transport or multi-modal transport contracts.

The second grouping consists of those terms that should only be used for Sea and Inland Waterways Transport. These include FAS (Free Alongside Ship), FOB (Free on Board), CFR (Cost and Freight) and CIF (Cost Insurance and Freight).

We may be throwing a rather controversial spanner into the works here, but if we have a set of incotems which can be used for any form of transport, then do we really need to have additional terms that are used for only seafreight and inland waterways? The real problem here is that some phrases, such as FOB, are so ingrained in International Trade language, that trying to get rid of them might be a step too far. Also, as we have seen with C & F, if there is a market desire to continue using this Incoterm, then it will continue to exist.

There is no legal reason why these familiar terms should not be used, but anyone doing so may be storing up litigation problems for themselves if something should go wrong with the shipment, and the contracts have not been correctly worded.

With regards to FOB, it is with sadness that we announce the demise of the ship’s rail, that generally non existent and invisible point on a vessel (especially container ships) that marked the passing of risk and responsibility from the shipper to the buyer. It has been replaced with on board the vessel, which although more practical, does actually carry its own risks. The advice here is that anyone using the FOB Incoterms should also, separately and clearly in the contract, specify exactly the point at which the shipper and buyer agree the loading of the goods is complete and risk and responsibility has passed from one to the other. As the ICC point out, the Incoterms rules do not give you a complete contract of use.

The main difference between Incoterms 2000 and Incoterms 2010 is that DAT and DAP have replaced DAF, DES, DEQ and DDU. The demise of DAF and DEQ seemed to bother no-one mainly because they appeared to have been rarely used. DAT effectively replaces DES and DAF replaces DDU. The main problem with DDU was the phrase Delivered Duty Unpaid, where the word Duty caused confusion especially when the term was used with domestic contracts.

There have been other developments. One is the acknowledgement that international trade shipments now require more information than ever due to security issues and various laws which have developed worldwide during the last decade. The new Incoterms, therefore, allocate the obligations to supply this necessary information between the seller and the buyer which is useful.

There is also acknowledgement that the use of Incoterms in String sales, a series of contracts where there is one cargo, but a string of buyers and sellers in a chain, also needed clarification. We are also pleased to note that the previous sticky problem of packing (who is responsible for it, and who pays for it, where necessary) has also been clarified.

Importing into Nigeria - New Rules

2010-07-26T06:23:00.000-07:00

Nigerian Customs have just implemented a new ruling (July 2010). An electronic manifest showing true weights of shipments must be submitted to Nigerian Customs prior to the flight departing for Nigeria. Software was sent to all airlines to enable them to comply.

Unfortunately, the software is not compatible with any airline computer system, which means that presently no cargo can fly to Nigeria.

This new ruling may also result in increased Customs Clearance charges at Lagos Airport once Cargo can fly.

Exporting New Vehicles to Saudi Arabia

2010-07-26T06:17:00.000-07:00

Exporters are no longer able to issue self Certificates of Conformity to clear their shipments through Saudi Customs as per the MoCI decree 6386 for clearing shipments of new vehicles.

It is now mandatory for exporters to obtain Certificates of Conformity from inspection bodies. All new vehicles arriving in Saudi Arabia without a Certificate of Conformity issued by a recognised Inspection Body such as SGS, Intertek, etc could find their import subject to delays in clearance and possible fines.

Saying "Regards" in Turkish

2010-07-26T06:14:00.000-07:00

"Saygilar" means regards
"Saygilarimla" means my regards (personal)
"Saygilarimizla" means our regards (general)

Found to be very useful when sending e-mails to Turkey

New US Sanctions against Iran

2010-07-15T09:28:00.000-07:00

Iran announced on 16th April 2010 that it had produced 5 kgs of 20% enriched uranium but it denies allegations that this is for the use of manufacturing atomic weapons. This is the latest stage in Iran’s nuclear programme which since 2006 has caused a great deal of international concern.

So much so that the United Nations (UN) have issued a number of resolutions. In July 2006, Resolution 1696 requested that Iran “suspend all enrichment-related and reprocessing activities including research and development” after the International Atomic Energy Agency (IAEA) was unable to provide assurances about Iran’s undeclared nuclear material.

In December 2006 the UN issued Resolution 1737 called on Countries to block Iran’s import and export of “sensitive nuclear material and equipment” and to freeze the financial assets of those involve in Iran’s nuclear activities. All Countries were urged to prevent the supply or sale of equipment and technology that would aid Iran’s nuclear programme.

In 2007 these sanctions were toughened under Resolution 1747 when the Security Council voted to ban all of Iran’s Arms exports. It also voted to freeze the assets and restricted the travel of people it deemed involved in the nuclear programme.

Further restrictions were issued in March 2008 under Resolution 1803 for countries to scrutinize the activities of Iranian banks and to inspect cargo planes and sea vessels entering or leaving Iran if there were ‘reasonable grounds’ to believe they were carrying goods prohibited by previous resolutions.

New UN resolutions are now being considered to expand sanctions against Iran even further, the news agency Reuters advise, mainly to support measures against new Iranian banks abroad if a connection to the nuclear or missile programmes is suspected, as well as vigilance over transactions with any Iranian bank, including its Central bank. There are also calls to countries to blacklist entities linked to Islamic Republic of Iran Shipping (IRISL) and the Iranian Revolutionary Guard.

In the meantime, the European Community are considering their own sanctions which reportedly include actions against entities such as Iranian banks and insurance companies involved in trade finance. The USA have already acted.

On 16th June 2010 the US Treasury imposed new sanctions on Iran. The US Treasury Secretary, Timothy Geithner stated that, “our actions today are designed to deter other governments and foreign financial institutions from dealing with these entities and thereby supporting Iran’s illicit activities.”

Effectively these US Sanctions prohibit US transactions with blacklisted entities and they seek to freeze any assets these entities may have under US jurisdiction. The US Treasury is also trying to squeeze Iran’s energy sector by identifying some 20 petroleum and petrochemical companies which are under Iranian Government control, 2 insurance companies including one based in the United Kingdom, the Post Bank (the 16th bank in Iran the US has sought to cut off from the international financial system and 5 companies which have been identified as being front companies for IRISL.

The consequence is that many European banks have halted trade with any company on the Treasury black list and in some cases, will not involve themselves in any trade deal with Iran at all.

Sanctions are always a tricky path for international traders to tread. If in doubt, get legal advice immediately. The consequences of falling foul of either EU, UN or US sanctions can be catastrophic for a company based in the UK.

Transferable Letters of Credit - Problematic Documentary Clauses

2010-07-12T04:09:00.000-07:00

Occasionally a Letter of Credit might have a documentary clause which could state, for example (or a variation thereof):

“Beneficiary must advise us (usually name of issuing bank) value of the consignment, name of the carrying vessel/agent, voyage number/Flight number, Bill of Lading number and date/Airway Number and date, Container Number/Flight Number, if any, and actual date of shipment on board by fax within seven working days after shipment of goods and documents must include a copy of such advice along with the fax transmission report.”

These clauses are included because this is the information that the Issuing bank and/or the Applicant requires to arrange suitable Marine Insurance for the shipment. However, if the contract is CIF, CIP or DDU/DDP with insurance, then this clause is effectively redundant and, if required, the Beneficiary should ask for the Applicant to remove this particular documentary requirement through an amendment.

However, if the Letter of Credit is a Transferable Letter of Credit, this type of clause (regardless of the terms of shipment) can cause serious problems to either the First Beneficiary or the Second Beneficiary when trying to supply conforming documents under the Letter of Credit.

This is because when a Letter of Credit is transferred by the First Beneficiary to the Second Beneficiary, it is transferred in its entirety. The only details the First Beneficiary can change is the value of the consignment (on invoices and drafts), the last shipment date, the expiry date and the percentage on the insurance certificate (if insurance is included). The problem arises when, for example, the Second Beneficiary is charging £10,000.00 but the First Beneficiary is charging £15,000.00.

If there is a documentary clause asking for a fax to be sent showing the details of the shipment, including the value of the consignment, the Second Beneficiary has to send a fax to the Issuing Bank stating that the value of the shipment is £10,000.00.

However, when the First Beneficiary obtains these documents and makes their presentation, they have a problem. If they submit the fax from the Second Beneficiary, showing a consignment value of £10,000.00, but their invoice is for £15,000.00, then this will cause a discrepancy in the documents being presented.

Even if the Second Beneficiary offers to state £15,000.00 on their fax, the fact their invoice only states £10,000.00 means that their presentation will then be discrepant.

The way forward here is to watch out for these types of clauses on Transferable Letters of Credit and to discuss solutions with the Advising Bank and the Applicant beforehand and to have amendments in place that will allow both the First and Second Beneficiaries to present conforming documents.

Certificates of Conformity

2010-07-07T09:04:00.000-07:00

A number of countries require specialist certification which relates to verifying the quality and safety of imported goods prior to export. These documents are normally known as Certificates of Conformity (CoC).

Certificates of Conformity are needed to ensure customs clearance of shipments, may be required as a Letter of Credit document and as as a documentary requirement for Cash against Document payments, as well as confirming to the buyer that the products comply with the relevant regulations and standards in the country of Import. Shipping goods that require these Certificates without the relevant Certificate of Conformity can result in severe delays in Customs clearance (and the resultant demurrage costs as well as upsetting the buyer), financial penalties (fines or increased duty costs) or even refusal to allow the goods to enter the country.

Some countries require by law for their exporters to issue Certificates of Conformity for various products, (such as vehicles) although this can sometimes cause accusations that the requirement of such Certificates are damaging. Recently Moldova amended their law on the production of ethyl alcohol and alcohol products, allowing the export of wine products without the need to issue Certificate of Conformity to facilitate the export of Moldovian wine-cognac products.

Where Certificates of Conformity are required by importers, a number of different agencies, such as Intertek, Cotecna and SGS (Societe Generale de Surveillance), depending on whether they have been granted authorization by the relevant importing Government, can assist with the issuance of these documents.

It is quite important that these Certificates are obtained only from authorized agencies. It is also quite important that before the issuance of a Certificate of Conformity is agreed in any contractual agreement that checks are done to ensure that such Certificates are required and can be obtained through legal sources.

The countries which presently require a Certificate of Conformity to facilitate import customs clearance procedures include, (but are not limited to):

Algeria
Required for all exports and will be a documentary requirement under Letters of Credit which is the only payment method available at this time.

Belarus
Required for goods including household appliances, foodstuff, textiles, cosmetics, goods for children, lighting products, agricultural machinery, welding equipment, fire safety equipment, lifts, products for the construction industry and vehicles.

Kenya
Some goods may not require this certificate, although this is something that the Kenyan importer must obtain permission for before the goods are physically shipped from the country of export.

Kuwait
Required for all exports

Mongolia
Shipments of subject goods with an FOB value of less than US$ 500 will not require verification by an authorized Agency, but must still comply with the requirements of the Mongolian Agency for Standardisation and Metrology (MASM).

Products requiring Certification include certain types of Food and Agricultural Products, Beverages, Tobacco Products, Chemical Products (HS Code 25.23), Fuels and Petroleum Products, Vaccines and Medicaments, Paints and Varnishes, Perfumes and Cosmetics, Soaps and Washing Preparations, Leather (HS 41.04), Paper Products (HS 48.03), Articles of HS Chapter 68, Iron and Steel Products (HS Chapter 72), Tubes, Pipes and Products (HS Chapter 73), Miscellaneous Articles of Base Metal (HS Chapter 83), Machinery for Food Use (HS Chapter 84), Domestic Appliances (HS Chapter 85) and Toys (HS Chapter 95)

Russia
Requires a GOST R CoC for all exports

Saudi Arabia
Required for all exports but still expect random shipments to be subject to sampling on arrival to confirm compliance.

Syria
Required for goods including toys and childcare products, electrical and electronic products, vehicles and automotive components, building tools and equipment and chemical and household products.

Uganda
Required for all goods except products from East African Partner States of Kenya, Tanzania, Rwanda and Burundi.

Yeman
Required for products such as food stuffs (except prohibited items), steel bars for reinforcement of concrete and construction timber.