Customs procedures and reliefs audit

First — the unpleasant part

A relief that was missed is usually not recoverable afterwards.

The Union Customs Code limits the amendment of a declaration after the goods have been released. Relief for returned goods is granted „upon application by the person concerned“ — which means the application had to be made then. A relief you did not apply for is not a relief you applied for badly.

Whether duty paid because a relief was not claimed counts as an amount that was not legally owed is a genuine legal question, and the answer depends on the procedure and the circumstances. We do not settle it.

That is why we split the result in two and never add the two together:

Value going forward. A procedure you can start using. The arithmetic is real: your actual volumes of the past twelve months multiplied by the verified rate. With no growth assumptions.

Contested claims for the past. Declarations where the relief was not used and whose claim period has not yet expired. For each one we give the circumstances and the legal provisions, so that your customs representative or lawyer can assess it. We do not assess the likelihood.

If someone promises to recover three years of missed reliefs for you, it is worth asking how they get around the limit on amending a declaration.

What we check from the declarations alone

Returned goods. Goods exported from the Union and returned within three years may be relieved of import duty. In practice these are rejected consignments, returns, goods that came back unsold, exhibition items. We match your export and import declarations and show which of them carried the full duty.

Repair abroad. Goods sent out to be processed or repaired and then returned may be charged on less than their full value. Where the repair is under warranty — possibly with no duty at all. A common mistake: the re-import is declared as an ordinary import and duty is paid on the full value of the goods, although the repair cost only a part of it.

Tariff quotas. On the day of the declaration an open quota with a lower rate may have been available for the goods. A quota is claimed in the declaration; without the claim the general rate applies. We check the state of the quota on that specific day — if we do not have the data for that day, we do not run the check and we say so.

Autonomous tariff suspensions. Some industrial raw materials and components have a suspended rate. If it was in force and the general rate was applied — that is a discrepancy.

Scope of anti-dumping measures. A measure applied to goods that do not fall within its scope.

What cannot be checked without further data

Temporary admission, processing, customs warehousing and end-use relief depend not on what is in the declaration but on what happened to the goods after import.

The declaration says the goods were imported. It does not say they left again four months later.

For those procedures we therefore provide a list of candidates — declarations that could fit by the nature of the goods — and state what data is needed to check them. Candidates are not included in any amount.

If you already use the procedures

Then we check something else: whether you use them in good order.

A processing procedure whose records do not match the quantities imported and re-exported is a customs debt that has not yet arisen but will arise at an inspection. A missed time limit for temporary admission — the same.

This part sits separately in the report and is presented as a risk, not as value. It is not added to the value figures.

Clients who already use the procedures usually have a records problem as well — and it costs more than the relief they missed.

Authorisation and time

Most procedures require an authorisation from customs. Relief for returned goods and tariff quotas do not.

That means the value starts not today but once the authorisation has been granted. For every finding we state whether an authorisation is required. How long it will take is a figure that belongs to your customs representative; if we do not have it, we write that we do not set a time rather than guess one.

We neither prepare nor submit the application for the authorisation. In a customs procedure the holder of the authorisation is a defined person, and that cannot be changed.

What this audit does not do

We do not advise on how to restructure your flows of goods in order to pay less duty. That is customs consultancy — a different service, different competences and a different liability.

We establish that a procedure exists and what it would be worth. How to implement it — the conditions of the authorisation, the record-keeping requirements, the guarantees — is your customs representative's work.

Checking before submission

The whole unpleasant part above disappears in one case: when the relief is claimed in the declaration.

A relief claimed in time raises no legal question at all about amending the declaration. For this audit, therefore, continuous control is not an acceleration — it replaces a contested claim with an actual relief.

Technically that requires access to the draft declaration before submission, not to the declaration already filed.

Price

Fixed, based on the number of declarations. The same in all markets.

Up to 50 declarations — 390 €. Up to 250 — 990 €. Up to 1,000 — 2,490 €. More — on request.

Fixed rather than a share of the result, because the greater part of the result is value going forward, from which there is no recovered amount.

For contested claims for the past there is no fee at all — neither a share of the amount nor a separate charge. We have carried out the legal assessment and it is negative: under the Union Customs Code a relief is granted only upon application, so where it was not applied for at import, the amount owed was the full duty. This means we do not sell retroactive recovery. We report gaps in the past as information, with the circumstances and the legal provisions, so that your customs representative can decide for themselves.

All prices

Related

Customs declaration check — the correctness of the declaration: code, value, origin, anti-dumping. A different question from this one.

Methodology — how we separate a finding from a candidate at all.

Exchange rate audit — recalculation of the customs value.

Submit declarations for assessment

You will find this service's pricing model and scope options on the pricing page. The review is free and does not commit you to choosing any of them.