Updated guidance published for declaring reusable packaging for Great Britain imports and exports

Published 23 December 2020

Last updated 11 December 2023 — See all updates

To be able to make an oral declaration or a declaration by conduct, the packaging must be reusable.

In this context reusable packaging are goods that meet all the following. They must:

• be useable for transportation of other goods
• have a relief from import duty at the time of import
• not be intended for sale
• be filled on at least one leg of their import or export journey

Packaging like bubble wrap and cardboard boxes are not included as reusable packaging.

To qualify for a relief from import duty, the reusable packaging must have previously been in UK free circulation. For reusable packaging from the EU, it must have been transported to the EU before 1 January 2021 or have previously been in UK free circulation.

The reusable packaging must be treated as going into free circulation or declared for Temporary Admission. It cannot go into any other customs special procedure.

If you do not use declaration by conduct or an oral declaration you can make a declaration for your reusable packaging using a different process.

Who can make the declaration

The importer and exporter do not need to own the packaging or the goods contained in them but to claim Returned Goods Relief the importer and exporter should be the same person.

Declaring reusable packaging

Reusable packaging requires a declaration.

When you arrive at a point of exit or entry for Great Britain (England, Scotland and Wales), you can make a ‘declaration by conduct’ for reusable packaging by:

• walking through a customs control point (this can be a green channel signed ‘nothing to declare’) with the goods, if you’re an individual on foot
• driving (or being driven) past a customs control point with the goods inside your vehicle, if you’re importing or exporting goods in a vehicle
• continuing your onward journey, if there are no customs control points

You can make an oral declaration for reusable packaging by telling a Border Force officer about it. If you have the authority to import or export reusable packaging for someone else, you also need to identify that person.

A declaration by conduct can be made on someone else’s behalf. For example, a haulier can make a declaration by conduct if they’ve been given authority to do so by an importer.

Not all locations can allow oral or by conduct declarations, so you should check ahead with the location the reusable packaging is moving through if you want to declare it in this way.

If reusable packaging is to be declared by conduct, and the goods are stopped by Border Force, then the driver either carrying the goods, or coming to pick the goods up, must advise a declaration by conduct is being made for the packaging.

Once an oral or by conduct declaration has been made no further information needs to be sent to HMRC.

Imports

On import, the packaging can be declared for free circulation by conduct or orally to a Border Force officer. The goods can also be declared for Temporary Admission. These goods are intended to be re-exported.

You will not need to pay Customs Duty or import VAT on them. But to make sure that no VAT is due, the importer and the exporter of the packaging must be the same.

No new import controls will be introduced in 2022 for imports into Great Britain from:

• the EU
• Andorra
• Monaco
• Norway
• Liechtenstein
• Switzerland
• Ceuta and Melilla
• Heligoland
• San Marino
• the Vatican City State
• the municipalities of Livigno Campione d’Italia
• the Italian national waters of Lake Lugano, which are between the bank and the political frontier of the area between Ponte Tersa and Porto Ceresio

A new target operating model of border controls will be published in Autumn 2022, with an aim to introduce the new rules by the end of 2023.

Iron and steel measures

In response to Russia’s invasion of Ukraine, the UK government has imposed a range of sanction measures. Prohibition on the import of Russian iron and steel products processed in a third country came into effect on 30 September 2023 and added to measures banning the import of Russian origin iron and steel introduced in 2022.

A Sanctions General Import Licence (SGIL) has been introduced that permits the import of reusable packaging, of Russian origin or which is a relevant third country processed iron or steel product, that:

• falls within commodity code 7326904000 (pallets and similar platforms for handling goods)
• is imported into the United Kingdom for the purpose of facilitating international trade of other goods, and
• is not consigned from Russia.

Where the SGIL is being used, declaration by conduct and oral declarations cannot be made, and an electronic form of declaration is required to declare the open licence.

If you are authorised for Entry in Declarants Records, as part of your Simplified Customs Declaration Process authorisation, and are also authorised for Temporary Admission, you will be able to declare via an Entry in Declarants Records followed by a Supplementary Declaration.

If you are not authorised for full Temporary Admission, you can use authorisation by declaration, which is when we allow you to import goods under TA without holding a TA authorisation. When moving reusable packaging under the SGIL and by authorisation by declaration for temporary admission:

• There is no cap on the yearly usage or value of the goods.
• You will not need a guarantee.
• You must declare to TA by making a full import entry.

Where you have documentary evidence that the packaging does not originate from Russia, a declaration by conduct or oral declaration can still be made.

Exports

If you are declaring exports of reusable packaging by conduct you will not need to make them available for examination. This is unless Border Force stop you and want to make an inspection.

A safety and security declaration will be required for exports of packaging from Great Britain from 1 January 2021.