Returning Repaired Goods to the EU

Returning Repaired Goods to the EU: Key Customs Rules for UK Businesses

Returning repaired goods across international borders can be complex, particularly when moving items back into the European Union. However, with the correct customs procedures in place, businesses can avoid unnecessary duty and VAT charges.

According to Arne Customs Manager Ltd, understanding and correctly applying Returned Goods Relief (RGR) is essential for businesses looking to move repaired items back into the EU efficiently and compliantly.

What Is Returned Goods Relief (RGR)?

Returned Goods Relief allows goods that were originally exported from the EU to be re-imported without paying customs duty or VAT, provided specific conditions are met.

When goods are sent out of the EU for repair and then returned, RGR can apply as long as the items return in the same state, aside from the necessary repair work. This relief is typically available if the goods are re-imported within three years of the original export and supported by appropriate documentation.

Customs declarations must also include the correct Customs Procedure Codes (CPCs), such as 61 23 F01, to ensure the relief is correctly applied.

Key Conditions for Claiming Returned Goods Relief

To qualify for RGR, the following principles must be met:

1. EU Origin

The goods must have originally been exported from the EU.

2. Returned in the Same State

Only repairs that restore the item to working order are permitted. Any processing or enhancement that changes the nature of the product will disqualify the goods from RGR.

3. Time Limit

Goods must usually be returned within three years of the original export, although limited exceptions may apply.

4. Proof of Original Export

Clear evidence of the original export is essential. This may include export declarations, commercial invoices, or transport documents.

5. Same Exporter and Importer

Ideally, the same legal entity should export and re-import the goods. If a different party imports the goods back into the EU, VAT may be payable on the full value.

How to Claim Returned Goods Relief (UK to EU Movements)

For UK exporters returning repaired goods to the EU, the following steps are critical:

  • Use the correct customs codes
    Declare the goods using the appropriate RGR Additional Procedure Code, such as 61 23 F01, on the import declaration.
  • Maintain full documentation
    Retain records of the original export, including invoices and export declarations, as well as details of the repair work undertaken.
  • Declare the repair value correctly
    Where RGR conditions are met, duty and VAT are usually calculated only on the cost of the repair, plus any inward freight and insurance charges—not the full value of the goods.
  • Check the EU–UK Trade and Cooperation Agreement (TCA)
    Under Article GOODS.8 of the TCA, many repaired goods can benefit from duty and VAT relief without prior approval under Outward Processing Relief, simplifying the process in many cases.

When Returned Goods Relief May Not Apply

RGR does not apply in every situation. Businesses may face additional charges if:

  • The goods have been processed rather than repaired
    Any transformation or enhancement beyond restoration disqualifies the goods, meaning duty and VAT may be charged on the full value.
  • A different importer is used
    If the goods are re-imported by a different company, VAT may become payable.
  • Original export evidence is missing
    Without proof of the original export, customs authorities are likely to charge full duties and VAT.

Practical Action Steps for Businesses

To minimise risk and ensure compliance when returning repaired goods to the EU:

  1. Confirm the work qualifies as a repair, not processing
  2. Gather original export documentation before shipment
  3. Work closely with your freight forwarder to apply the correct RGR customs procedure codes
  4. Declare only the repair cost and associated freight for duty and VAT calculation

Final Thoughts: Why This Matters for Import Compliance

Correctly applying Returned Goods Relief can deliver significant cost savings and prevent customs delays. However, errors in classification, valuation, or documentation can quickly result in unexpected duty and VAT liabilities.

Staying informed and working with experienced customs professionals is key to maintaining compliance and protecting your supply chain when returning repaired goods to the EU.