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Duty/VAT when importing parts from the USA, and the requirement for 8130-3 or EASA-1 forms to get the duty relief

Someone has just sent me this US document on duties on aviation parts. local copy

Administrator
Shoreham EGKA, United Kingdom

IIRC the only issue with buying a Garmin unit for an Experimental application is that you don’t get the code to download FAA STC paperwork for your tail number.

The duty free exemption is supposed to apply only to parts for certified aircraft

That may be why nobody here seems to care; how do you certify the part is destined for a certified aircraft? It would make you liable for import duty if you bought a GTN750 and mounted it in a Vauxhall Viva Or if you bought a GTN750 and never installed it.

In the US, Garmin (and presumably all the others) will ship a GTN etc box directly to an end user, bypassing its dealers, upon evidence that it is destined for a homebuilt/experimental aircraft. This was posted on a US site by a Garmin rep. I asked him what evidence he needs and he never replied Clearly this scheme is full of holes; I was able to buy a Sandel SN3500 ($10k or so) “with an Experimental harness” to meet this requirement, but, hey ho, it came with no harness and an 8130-3

I wonder who thinks up these requirements?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I have imported a whole load of stuff from the US and IME nobody in the system checks for these forms. What really matters is that the paperwork has AIRCRAFT PARTS all over it

That has been my experience too, shipping parts both ways across the Atlantic. The duty free exemption is supposed to apply only to parts for certified aircraft, but in practice its the statement ‘aircraft parts’ on the shipping paperwork, certified or not, that matters.

Last Edited by Silvaire at 04 Dec 16:00

Guess importing aircraft parts is one of the areas where the UK is more reasonable than Poland ;-)

tmo
EPKP - Kraków, Poland

One of the requirements for parts to be duty free is a EASA Form-1 or equivalent (e.g. FAA 8130-3).

I have imported a whole load of stuff from the US and IME nobody in the system checks for these forms. What really matters is that the paperwork has AIRCRAFT PARTS all over it, and unfortunately many US suppliers just can’t be bothered to read one’s instructions to do this. It is an old issue in a country where companies can reach tens of billions of $ sales without having to deal with a foreign customer, and frankly when you compare the US GA scene with the largely broken European GA scene, one can sort of understand why so many in the US can’t be bothered with export markets This subject is of much interest to me as I have been exporting my electronic products all over the world since 1978 so if a customer in The People’s Republic of Upper Volta wants to buy something, I am very happy to sell it to him (bank transfer only, no credit cards since they will usually be stolen ).

Administrator
Shoreham EGKA, United Kingdom

One of the requirements for parts to be duty free is a EASA Form-1 or equivalent (e.g. FAA 8130-3). Since some companies (shame on you, JPI) charge for issuing it, even for new units that cost thousands of dollars (shame on you, JPI) it might be more cost efficient to spend the $200 on duty for “electronics”.

An interesting way to save some money might be to have shipping be billed separately, otherwise you might end up paying duty on it as well.

VAT is due regardless.

tmo
EPKP - Kraków, Poland

lionel wrote:

Airplanes below 2t empty weight (not MTOW) have two tariff codes. 8802 20 00 10 is for “civil use” and 8802 20 00 90 is “other”. Import under the civilian use code is free of duty (but not free of VAT). Civil use has to be proven, but nowadays in the EU, being registered in an ICAO civil register is sufficient proof. “Other” attracts 7.7% duty.

We got burned by this when importing a piece of used avionics from the US. Even though the seller had used the civil use tariff code on the customs declaration, the transport company (which handled the customs formalities) didn’t bother to ask us for proof and simply re-declared it as “other”. The duty we had to pay was low enough that we didn’t bother making a fight, but it was a lesson learned for next time.

ESKC (Uppsala/Sundbro), Sweden

Airplanes below 2t empty weight (not MTOW) have two tariff codes. 8802 20 00 10 is for “civil use” and 8802 20 00 90 is “other”. Import under the civilian use code is free of duty (but not free of VAT). Civil use has to be proven, but nowadays in the EU, being registered in an ICAO civil register is sufficient proof. “Other” attracts 7.7% duty.

I’m fairly sure I posted exact legal references on EuroGA before.

That can be looked up by entering “8802200010” (without the quotes) on https://ec.europa.eu/taxation_customs//dds2/taric/taric_consultation.jsp. The “ERGA OMNES” rate applies to any country not otherwise listed.

Last Edited by lionel at 04 Dec 07:16
ELLX

Someone else recently asked me a Q about import duty on aircraft and aircraft parts and I gave him the standard answer which I have heard many times: parts are duty free, and aircraft below 8000kg are also.

Then he started digging and found no evidence to support this!

There appear to be different tariff numbers for aircraft below 2000kg and below 15000kg, but no duty seems payable below 15000kg. Can anyone confirm this?

Administrator
Shoreham EGKA, United Kingdom
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