Exporting beer to France using an SAD
I am in the process of arranging for a consignment of beer to sent to a customer in France for the first time. As we do not send produce under bond, we have been using an SAD (Single Admin Document) in its place, and then claiming duty back from HMRC. This has been fine for all other export markets we deal with, such as the US, Canada and Central and Northern Europe. However it appears that in France’s case the customer has to pay the relevant taxes in advance of receiving the consignment into Calais, and all because we cannot raise EADs.
Anyone’s advise for exporting to France under these circumstance would be greatly appreciated. Trying to decipher the HMRC website is tough, but doing the same with the French customs website using my Franglaise is extremely challenging to say the least!
I’m not sure of the answer, although I can see the logic of excise goods being in ‘free circulation’ duty paid for the UK market and then arriving in France needing to be duty paid in that market. I’m going to make a couple of enquiries with existing customers and our local Craft Brewery Group in the South West. Drop me an email if you would like me to pass on your contact details.
Looking on the HMRC website I believe Notice 207 and Notice 226 are relevant, if you haven’t seen them already. And also form EX46 for Beer Duty Drawback.
If you get yourself setup with an excise warehouse this issue will disappear and you can use our system to manage your movements and get confirmation from destinations like France that the goods have arrived and that you are no longer liable for the duty.
Further to my comments above I have taken advice from an experiences exporter and they support your original post that getting excise goods into France is particularly difficult. Other EU countries have better procedures in this area to allow duty to be paid upon import via a form.
I believe in HMRC/customs terminology the process can be referred to as Distant Selling and is raised on a regular basis as an issue for exporters with HMRC at trade association meetings and is fed back via the EU for review.
One suggestion was that you seek a tax representative in France who manages the release and distribution of your product, for a percentage or fee.
I believe another common practice, although I am not endorsed it, is to use a courier service for smaller shipments, use the UK drawback scheme between your site and the port and once delivered to your customer they can pay the duty, I guess avoiding any issues at port in the main.
Hope this helps. If you would like a good contact please drop me an email.
The French excise duty needs to be secured before the goods are dispatched and payment is due when the goods arrive in the France, unless you intend to place them in an excise warehouse, where the duty can be suspended until they are released for consumption.
HM Revenue & Customs
Customs International Trade & Excise