Information – Questions & Answers

Information

Please refer to the following which we trust will assist our clients understand some of the terminology used within warehousing & logistics, especially when Alcohol (Excise Products) is involved.

Warehousing

WOWGR & AWRS – Trading in Excise Goods

The term WOWGR stands for Warehousekeepers and Owners of Warehoused Goods Regulations.

A WOWGR certificate obtained from HM Revenue & Customs under these regulations allows a UK business to own, trade, store and move excise goods within the UK’s duty suspension system.

The term AWRS stands for Alcohol Wholesaler Registration Scheme.

If you are established in the U.K. and sell alcohol at or after the point where excise duty is due to another business you will need to apply for AWRS and when you purchase from a UK wholesaler, you will need to check that they are also AWRS approved.

Duty Representative Status – Non UK Based Owner of Excise Goods

If you wish to own excise goods and you want to store them in duty-suspension in a UK excise bonded warehouse, you’ll need to be approved by HMRC in order to deposit those goods in an excise warehouse.

If you’re a UK-based owner of excise goods, you will need to be approved by HMRC as a registered owner (WOWGR – Beers & Spirits).

If you are an overseas owner without a fixed UK address, you’ll need to appoint someone who is approved by HMRC as a duty representative to act on your behalf. In general, only the warehousekeeper of the warehouse concerned, a registered owner, or an overseas owner with a duty representative acting on their behalf can deposit goods in an excise warehouse.

Seabrook Export Services hold HMRC duty representative status in liaison with Seabrook Warehousing the warehousekeeper.

Duty representatives must, prior to acting for an owner, carry out full Due Diligence to make sure that any owner that they represent does not have a business establishment or fixed address in the UK. A duty representative will be expected to retain evidence that they have carried out such checks on each principal before they act for them.

Duty Deferment Scheme

Duty is payable when you import goods into the U.K. or remove goods from a customs or excise warehouse.

A deferment approval number (DAN) under the duty deferment scheme will allow you to defer payment to HMRC until a later prescribe payment date which differs for customs and excise duties.

You can defer payment if you are approved to hold a DAN and are an importer, the owner of goods in warehouse, an agent clearing the goods for importers or owners or a warehousekeeper.

For additional information – https://www.gov.uk/government/publications/notice-101-deferring-duty-vat-and-other-charges/notice-101-deferring-duty-vat-and-other-charges

EMCS (EAAD / ARC) - SAAD

EMCS (Excise Movement Control System) was introduced on 1stJanuary 2011 by all EU Member States to replace the old paper Accompanying Administrative Document (AAD) for the movement of duty suspended Beers, Wines & Spirits between excise bonded warehouses, or to port of export with an electronic version, an EAAD.

Once an EAAD is created by the dispatching warehouse a unique ARC number is created which should accompany the movement.

The movement of duty suspended excise goods without a valid EAAD / ARC is illegal and the goods become liable to seizure.

An EAAD must be linked to a valid Movement Guarantee to cover the excise liability should a duty point occur.

The movement of duty paid excise duty should be accompanied by a SAAD (Simplified Accompanying Administrative Document) which is also created by the dispatching warehouse.

U.K. Excise Duty Rate

Excise Duty is chargeable, in addition to any Customs Duty which may be due, on goods with the appropriate commodity code numbers. (click below link)

https://www.gov.uk/trade-tariff

The duty falls due at the time the goods leave duty suspension arrangements, when:

  1. They are release or made available for consumption, via the warehouse system or registered trader (REDS) or an occasional importer receives them into the U.K.
  2. A vendor makes delivery under distance selling arrangements.
  3. Missing consignments and/or dutiable shortages are incurred, duty point.
  4. Imports for personal use are then sold or used commercially.

Different rates apply to different sub categories of goods as per the goods commodity code definition.

Changes to duty rates are normally advised in the Budget. Current alcohol duty rates as from 13th March 2017.  (click below link)

https://www.gov.uk/government/publications/rates-and-allowance-excise-duty-alcohol-duty/alcohol-duty-rates-from-24-march-2014

U.K. Excise Duty Stamp Scheme

Spirits – all bottles of spirits with a strength of 30% alcohol by volume or above, with a capacity of 35cl or more, are required to have affixed a Duty Stamp for removal into UK home use.

Exports, it is illegal to remove from the UK Spirits bearing a UKDS, these must be removed in accordance with appropriate guidelines prior to departing the UK.

For full information please refer HMRC Excise Notice DS5 – Sept17 –https://www.gov.uk/government/publications/excise-notice-ds5-uk-duty-stamps-scheme/excise-notice-ds5-uk-duty-stamps-scheme

Imports from outside the EU

Imports from overseas are treated differently depending if the goods originate from countries from within the EU or from outside.

EU Goods – are in free circulation, can be imported with minimal customs control, are not liable import duty or import VAT.

Direct imports from outside of the EU are treated differently – they require an import declaration to customs and are subject to pay import duty & import VAT, in order to clear them to free circulation status.

For full information please refer to HMRC Guidline –https://www.gov.uk/guidance/importing-goods-from-outside-the-eu

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Logistics

INCOTERMS

Issued by the International Chamber of Commerce (ICC), incoterms provide a three letter abbreviation confirming the standardised terms of sale, commonly used in international sales contracts.

Incoterms are recognised worldwide by legal entities and traders to eliminate uncertainties arising from potential miss-interpretation of shipping terms, in order to establish who is responsible for each of the cost elements of a door to door shipment.

The most common incoterm recommended for the export of alcohol is CFR (Cost & Freight) covering the movement from bonded warehouse through to arrival destination port.

For a full list of Incoterms, their definition and additional information, go to – www.incoterms.com

SOLAS – VGM (Verified Gross Mass)

Effective July 2016  it is the responsibility of the ‘Shipper’ sending goods via sea to declare the verified gross mass of a loaded container prior to the prescribed vessel cut off date before it can be loaded on board.

The VGM must be with the legal road weight and not exceed the gross carrying weight of that specific container.

Mis-declaration of VGM imposes an obligation on the carrier and port operator not to load, resulting in delays and additional charges to the shipper.

For additional information – www.solasvgm.com

ISPM15 – International Standard Phytosanitary Measure

ISMP15 developed by IPPC (International Plant Protection Convention) to control the treatment of wood products used to ship products between countries signed up to be ISMP15 compliant.

ISMP15 requires that wooden pallets and or dunnage be either chemically fumigated using Methyl Bromide, or heat treated to a minimum core temperature of 560c  to eliminate the spread of pests.

To confirm compliance wooden pallets must be clearly stamped on 2 sides showing the official IPPC logo, or use plastic pallets.

In some countries ISMP15 compliant (IPPC) pallets are mandatory, in others it can vary dependent upon the region or port, so always double check with your client if required as the standard pallets upon which your product is palletised may not comply which can lead to additional costs.

Example Mandatory Countries:- USA, Australia, New Zealand, Taiwan, Japan.

For additional information – www.ippc.net

Equipment Types – Container Loading Pallet Configuration

Ocean Containers – Sea Freight

20ft – Standard Dry Container (Ave Internal: W2.35m x L5.895m x H2.392  – 33m3 ) (Max Weight: Approx. 28,000kgs subject to TARE)

Loading Options – 10  VMF Pallets (1000mmx1200mm) + (Space overtop subject to weight) or 11  Euro Pallets (800mmx1200mm) + 1 loose loaded on floor or overtop + (Space overtop subject to weight) or Loose Loaded to Max Fill/Weight

40ft – Standard Dry Container (Ave Internal: W2.35m x L12.03m x H2.392 – 67m3 ) (Max Weight: Approx. 26,000kgs subject to TARE)

40ft – High Cube Dry Container (Ave Internal: W2.35m x L12.03m x H2.697 – 76m3 ) (Max Weight: Approx. 26,000kgs subject to TARE)

Loading Options – 22  VMF Pallets (1000mmx1200mm)  (Space overtop subject to weight) or 24  Euro Pallets (800mmx1200mm) + 1 loose loaded on floor or overtop (Space overtop subject to weight) or Loose Loaded to Max Fill/Weight

 

Ocean Refrigerated Containers – Sea Freight

20ft – Reefer (Ave Internal: W2.25m x L5.45m x H2.1 – 28m3 ) (Max Weight: Approx. 27,000kgs subject to TARE)

Loading Options – 9 VMF Pallets (1000mmx1200mm) + 1 loose loaded on floor (Space overtop subject to weight) or 10  Euro Pallets (800mmx1200mm) + 2 loose loaded on floor or overtop (Space overtop subject to weight) or Loose Loaded to Max Fill/Weight

 

40ft – High Cube Reefer (Ave: W2.25m x L11.8m x H2.425 – 67m3 ) (Max Weight: Approx. 25,000kgs subject to TARE)

Loading Options – 21  VFM Pallets (1000mmx1200mm) (Space overtop subject to weight) or 23  Euro Pallets (800mmx1200mm) + 1 loose loaded on floor or overtop (Space overtop subject to weight) or Loose Loaded to Max Fill/Weight

 

Short Sea Pallet Wide Containers – EU Movements

45ft – Dry P/W (Ave: W2.44m x L13.55m x H2.694 – 89m3 ) (Max Weight: Approx. 27,500kgs subject to TARE)

Loading Options – 26  VMF Pallets (1000mmx1200mm)  (Space overtop subject to weight) or 33  Euro Pallets (800mmx1200mm) (Space overtop subject to weight)

Trailers – UK & EU Movements

Curtainside – (Ave: W2.48m x L13.62m x H2.7 – 91m3 ) (Max Weight: Approx. 32,000Kgs subject to TARE)

Box – (Ave: W2.46m x L13.62m x H2.7 – 90m3) (Max Weight: Approx. 31,000Kgs subject to TARE)

Loading Options – 26  VMF Pallets (1000mmx1200mm)  (Space overtop subject to weight) or 33  Euro Pallets (800mmx1200mm) (Space overtop subject to weight)

Movement Guarantee – ‘Alcohol - Duty Suspended’

Seabrooks have a valid Movement Guarantee  for the holding and movement of excise goods in duty suspension within the UK and the EU.

This applies to an approved excise warehouse keeper, owner or duty representative of excise goods, registered consignor or transporter of excise goods and you want to:

  • receive and place duty-suspended excise goods into an excise warehouse
  • import excise goods – customs clear then deliver in duty suspension from the UK port of arrival to an excise warehouse
  • remove excise goods in duty suspension from an excise warehouse to other approved persons or premises in the UK or EU
  • export excise goods in duty suspension from an excise warehouse outside of the EU

All duty-suspended movements from an excise warehouse or for imports from port of arrival ,must be covered by a valid UK Movement Guarantee underwritten to HMRC by a financial security.

The movement guarantee required for duty-suspended movement from an excise warehouse may only be provided by:

  • the warehouse keeper of dispatch
  • the last owner of the goods whilst warehoused (not a duty representative)
  • the transporter

Each party is joint & severally liable should a duty point arise.

We at Seabrooks do NOT allow the use of 3rd party guarantees nor 3rd parties to use our own guarantee, due to joint & several liability should a duty point occur than we have no control over but still be liable.

For full details – https://www.gov.uk/government/publications/excise-notice-197-receipt-into-and-removal-from-an-excise-warehouse-of-excise-goods/excise-notice-197-receipt-into-and-removal-from-an-excise-warehouse-of-excise-goods

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