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HMRC internal manual

Import and National Clearance Hub Procedures

Special directions: post clearance recovery of arrears of duty and VAT: part 2 Post Clearance Demand Notes


Post Clearance Demand Notes (C18) are a means of bringing to account additional revenues found to be due after the processing of the prime entry. C18s are issued centrally by the C18 Team located at Dorchester House, 52-58 Great Victoria Street, Belfast, Antrim BT1 3ET phone: 03000 587533 or email: <> at the request of the officer identifying the debt. This could be as a result of a compliance event or following a frontier examination. The originating officer completes an electronic C18 request and emails it to the NPCC inbox.

The basic rule for duty purposes is that the declarant is the customs debtor. The Economic Operator Registration Identification (EORI) number shown in box 8 or 14 of the SAD may not belong to the name and address shown in the same box if a VAT group registration is involved. EORI numbers are mandatory. The demand for duty should be made of the name and address shown, not the owner of the EORI number, if different.

Joint liability

There are situations where more than one person can be liable for the same Customs debt. They are considered to be jointly and severally liable for the debt. Examples are as follows:

  • A declaration has been made by an indirect representative which means both they and the person being represented are liable for any Customs debt.
  • Customs debt is incurred because goods have been unlawfully removed from Customs supervision, such as removals from Customs warehousing without declarations. This could make the warehouse keeper, consignee, depositor, agent etc liable to the same debt depending on the circumstances. You can find details relating to Customs Warehousing and who is the correct debtor in Customs Warehousing UoE.

In these situations, a C18 is to be issued to each debtor with records clearly cross-referring all the C18s issued for the same debt.

Legislation does not provide a priority order for whom to pursue first so all the C18s should be pursued as far as possible until one of the debtors pays the debt. When the debt is paid, the other C18s can be withdrawn.

If the debt is referred to Debt Management and Banking (DMB), the originating office must give full details of the circumstances of the debt, any information known concerning the debtors’ ability to pay and attach copies of all the associated C18s.


When VAT only is involved C18s must (subject to minimum amount recoverable) still be issued. The fact that VAT registered traders may be able to reclaim any VAT paid as input tax is not taken into account. Form C18 is still required.

Own Resources returns

Finance International Accounting Team, under the provisions of EC Regulation 1550/2000, notify the European Commission of all outstanding own resources debts and frauds / irregularities. The information is compiled using a combination of the returns from the C18 Team, Belfast, C18 spreadsheets and fraud / irregularity cases reporting on DCIS / Centaur.