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HMRC internal manual

ATA/CPD Carnets Manual

Disposal other than by re-export

Alternative methods of disposal
Release to free circulation
Destruction under customs supervision
Transfer to another customs procedure
Transfer of benefit
Selling goods in a third country - UK issued carnets

{#IDA2G54B}Alternative methods of disposal

The usual method of discharging an ATA carnet is by re-exporting the goods from the country where the goods were temporarily admitted.

However, in certain circumstances, alternative methods of discharge may be available. These are:

  • release to free circulation
  • destruction under customs supervision
  • transfer to another customs procedure
  • transfer of benefit.

{#IDA3H54B}Release to free circulation

Note: The release to free circulation of goods imported under a carnet may only be allowed in exceptional circumstances and only with the prior permission of the National Carnet Unit (NCU), see paragraph 009450. If a carnet holder is authorised to release the imported goods to free circulation, the goods will become liable to:

  • all customs duties
  • VAT
  • in most cases, compensatory interest, see Section 10200

Any VAT due will be calculated using the VAT rate applicable on the date the goods entered free circulation.

The duty rate used will be based on the rate applicable at the time the goods entered the UK/EC (that is the date they entered temporary admission).

The value of the goods will be based on a current valuation and not necessarily the figure on the front of the Carnet.

Duty, VAT and compensatory interest is not due when the goods were imported for display or use at an exhibition, fair, meeting or similar event and were consumed, distributed free of charge to the public at the event (Istanbul Convention Annex B1 Article 5.). This is based on the proviso that the goods are samples and are in proportion to the nature of the event and the number of people attending the event.

Where any other goods are released to free circulation in the UK, whether or not the goods entered the EU through the UK, the carnet holder must present an entry on Form C88 using CPC 40 53 000. The carnet holder must send the entry, together with the carnet, to the NCU who will process the declaration and return the carnet to the holder suitably endorsed (see Section 09450). If the goods were entered to the EU through another Member State, it is the responsibility of the carnet holder to notify the responsible office in that Member State of the diversion.

Works of art, collectors items and antiques released to free circulation

Where the approved diversion to free circulation involves works of art, collectors items or antiques, as defined by Annex I of Directive 77/388/EEC (as amended by Directive 94/5/EC), special rules can apply when calculating the import VAT due.

The 7th VAT Directive allows certain works of art, collectors pieces and antiques to be subject to an effective VAT rate of 5 per cent. Full details can be found in Notice 702 Imports (HMRC web)


{#IDAB03RC}Destruction under customs supervision

Istanbul Convention Article 14(1)(c)

The carnet holder may elect to destroy the goods rather then re-export them. In such cases, the carnet holder must seek prior written permission from the NCU by applying five working days before the planned destruction.

The NCU will liaise with customs staff to decide, on a risk basis, whether or not destruction should be supervised by a Customs official. The NCU will issue a written authorisation to the holder indicating if attendance is necessary. The letter will also include any other conditions such as the need to declare any waste and scrap resulting from destruction and to notify NCU when destruction is complete, see paragraph 09300


{#IDAV03RC}Transfer to another customs procedure

Istanbul Convention Article 12

If the circumstances surrounding the temporary importation change, it may be appropriate to transfer the goods to another customs procedure such as inward processing or customs warehousing.

In such cases, the carnet holder must submit a C88 (SAD) to the NCU with a written explanation as to why the transfer is needed. The declaration must be made under the CPC normally used for moving Temporary Admission goods into the relevant procedure, for example, for a movement to inward processing (suspension), 51 53; for customs warehousing 71 53 and so on. Any charges due must accompany the declaration.

The NCU will provide written authority to the carnet holder and permit the transfer to take place, see paragraph 09550.


{#IDAJ13RC}Transfer of benefit

Istanbul Convention Article 8

Where approved by customs and the issuing authorities in the countries involved, the benefit of a carnet can be transferred, see paragraph 09700


{#IDAV13RC}Selling goods in a third country - UK issued carnets

Although goods under a carnet should not normally be sold, there will be some instances where this will happen. The EU issued carnet will be signed off and discharged in the third country in a similar way to the procedures described under ‘release to free circulation’. The customs authorities in the country where the goods are will note on the carnet which goods are not being returned.

In addition, the carnet holder will be required to submit, to the NCU, a retrospective export entry using a C88 with the Carnet. This should quote CPC ‘10 00 001’ in box 37 and ‘Z-955’ in box 40 followed by the carnet number. Once the carnet has been endorsed it will be retuned to the carnet holder.