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Temp export UK to USA for overhaul

General discussion of import duty from the US, and whether parts certification is required, is here

Administrator
Shoreham EGKA, United Kingdom

You got ripped off on the shipping cost, for sure.

That is a DHL price, with insurance for about 2k value.

Administrator
Shoreham EGKA, United Kingdom

OK.
After consulting with my usual shipping provider https://www.worldwide-parcelservices.co.uk I’ve sent it with them at a cost of £176.91inc VAT and insurance one way.
The box has been labelled as Peter has suggested, “TEMPORARY EXPORT FOR REPAIR, COMMODITY CODE 88033000” in big letters. The repairer in the USA has agreed to make sure that not only the invoice but the packaging is labelled with "Aircraft parts for overhaul and return to UK and
“UK HMRC export code: 88033000
UK HMRC import code: 8803300010” written on both the package and the documentation.
We’ll see what happens.
Overhaul cost is only $185.00 each!

Forever learning
EGTB

Every day is a school day Might explain why an engine doesn’t get shipped out the same day.

But normally that doesn’t matter.

Why does the EU care what you are shipping out? It may be to do with the customs pre-clearance, where goods are cleared for the destination well before they get there and thus without being eyeballed, so you can understand the sending end may want to do spot checks.

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

The issue there is return to Europe.

The problem is that it should be below 1000 Euro. Once you export something over 1000 Euro from the EU things get complicated (actually all shippings the same day from the same sender are added). Over 1000 Euro the products have to be declared electronically using an agent and held available for customs inspection a few days before shipping.

www.ing-golze.de
EDAZ

Peter wrote:

I’ve never heard a beep from the US destination saying they had to pay import duty on it.

I’ve never paid any duty or tax on any vehicle parts I’ve imported to the US over 35 years, obviously including civil aircraft parts as these are duty free by two way treaty. The issue there is return to Europe.

DHL will get the parts to a US address eventually but they often use USPS for delivery (DHL infrastructure in the US is not extensive) and that process is cumbersome in my experience. Cost allowing, I’d recommend Fedex for shipments to the US and DHL for shipments to Europe.

I just send the parts to the US labelled as value 0 for repair.

I send stuff to the US routinely, for overhaul etc, and I make up a Commercial Invoice with some nominal value like $100 (for a magneto) and in big letters I put on it

TEMPORARY EXPORT TO THE UNITED STATES FOR REPAIR AND RETURN

and that seems to work. I’ve never heard a beep from the US destination saying they had to pay import duty on it.

When it comes back, there may or may not be import duty levied depending on whether the magic words AIRCRAFT PARTS have been put on the paperwork Given the “facebook generation reading only one line”, about 50% of the time they are not… Obviously if it was an engine then I would kick up a fuss with the courier and make then get it re-classified. It happened with the TKS system and got it corrected; the crates had AIRCRAFT PARTS all over them but not on the paperwork, and in modern times customs clearance does not involve looking at the goods… it gets done by muppet+computer while the goods are on the 747 at FL300.

The company we got good rates from for outbound shipping was this one and hey they are carbon neutral so Greta will love too

Administrator
Shoreham EGKA, United Kingdom

Stickandrudderman wrote:

“outward processing relief”

The problem is to do this properly you have to file a case with a central customs system through an agent etc. As a result for smaller items up to maybe 10k or Euro it is not worth the effort. I just send the parts to the US labelled as value 0 for repair. Once they return they will usually charge me the import vat on the total of the invoice attached for the shipping which will be the overhaul cost. That is not the perfect procedure but the easiest.

The risk is that customs could say you did not export it properly and now you have to pay import VAT on the whole thing, core value plus overhaul price. Did never hppen to me but I would be afraid on a whole engine and similar items.

When buying overhauled parts and returning your core later try to make them put only the price excluding core value on your invoice and to take a security on your credit card for the core. Else you will end paying import VAT on the core value which can be significant.

Finally aircraft parts are duty free but some providers like UPS/FedEx charge extra for that procedure. So for smaller items it is easier to pay the general duty of 2,7% instead of paying UPS/FedEx for the special aircraft parts procedure.

www.ing-golze.de
EDAZ

Thanks wbardorf, very helpful.

Forever learning
EGTB

Regarding getting preferential and competitive air freight rates from/to the UK and Germany, try https://www.transglobalexpress.co.uk/.

I have my own DHL account with preferential rates (essentially a discount of 50-70% over published rates) and their rates are pretty much the same as the DHL rates I get and they (and other similar companies) essentially pass on preferential rates of various express air freight carriers. I have used them a few times within the EU when the rate of a different carrier was cheaper than DHL but have not had experience with customs clearance with them for shipments from/to outside the EU.

I therefore don’t know how well they handle “outward processing relief”. In the DHL account case, I have got DHL doing that and the customs process in general for me. Not sure whether TG Express does it themselves or whether they rely on DHL, UPS etc to do it for them. It’s probably worth checking with them how they deal with OPR for magnetos you are looking to ship.

A very important aspect to avoid “import duty” (different from VAT) is to ensure the right HS code which carries the civil aircraft exemption based on the TARIC database (https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp?Lang=en#) is listed in the commercial invoice and that a relevant Authorised Release Certificate is clearly included as an attachment to the commercial invoice. Please also see https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=uriserv:OJ.L_.2018.256.01.0058.01.ENG which has the official statutory exemption text which shows which HS headings/subheadings that are covered by the exemption (essentially always make sure you use the duty-exempt HS code) and the list of acceptable ARCs.

EGTF, EGLK, United Kingdom
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