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Knowledge base

Customs value: what to include beyond the price of the goods

The customs value is more than the invoice amount. Freight, insurance, commissions, royalties and so-called assists can lawfully raise the duty base. We explain what to add, what to leave out and why mistakes surface at audits.

The primary method of establishing UK customs value is the transaction value: the price paid plus defined additions. You include freight and insurance to the UK border, most commissions, royalties conditioning the sale, packing and assists supplied free to the producer. Costs after arrival, and duty and VAT, stay out. An understated base is a frequent audit finding.

Assists are goods and services supplied to the seller by the buyer free or at reduced cost for production purposes: moulds, tools, dies, materials, design work undertaken outside the UK. Their value is added to the customs value proportionally.

What must be added to the price of the goods?

  1. Transport and insurance to the place of entry into the UK: road freight, the crossing, loading and handling en route.
  2. Commissions and brokerage, except buying commission paid to the buyer's own agent.
  3. Royalties and licence fees, where paying them is a condition of the sale, for example a trademark licence built into the contract terms.
  4. Packing and containers treated as one with the goods.
  5. Assists: injection moulds, tools, designs and materials handed to the producer free of charge, apportioned across deliveries.
  6. Any part of the resale proceeds due back to the seller, where the contract says so.

What is left out?

The customs value excludes costs arising after the goods reach the UK: domestic freight from port to warehouse, unloading at the consignee, assembly and commissioning, as well as the duty and VAT themselves. Interest on deferred payment shown separately and charges for the right to reproduce the goods in the UK are also deductible. There is one condition: the items must be separated out in the documents, because a cost rolled into one amount with the goods price is included in full. We show the practical effect on the duty bill, with numbers, in how UK customs duty is calculated: value, rate and VAT.

Why is freight a trap on imports from Poland?

Under terms where the seller pays for transport, the freight sits inside the goods price and the problem disappears. But when the buyer arranges transport separately, for example under EXW or FCA, the cost of carriage to the UK border must be added to the customs value by the declarant. The frequent mistake looks like this: the goods invoice goes into the declaration, the transport invoice goes to accounting, and the base is understated by the whole freight. Who is responsible for what under each rule is described in our article on Incoterms 2020 and customs responsibility.

How do errors surface, and what is at stake?

Customs value is verified in post-clearance audits: HMRC compares declarations with accounts, contracts and payments. An understated base means paying the missing duty and VAT with interest, and in glaring cases penalties too. Royalties and assists are caught most often, because they show in contracts and rarely in declarations. The safety rule is simple: write down all financial arrangements around the supply in one place and check them against the catalogue of additions, ideally before the first delivery leaves. We run that review with clients when setting up clearance, together with the document set described in documents for export to the UK.

A simple example: how the additions change the base

Assume a delivery of components for GBP 10,000 on FCA Kielce terms. The buyer pays separately for transport: GBP 700 for the leg to the UK border and GBP 200 for domestic carriage to a Birmingham warehouse, plus GBP 40 of insurance for the whole route. A year earlier the buyer also handed the producer an injection mould worth GBP 5,000 free of charge, apportioned over 10,000 units, of which 2,000 travel in this delivery. The customs value comes out as: GBP 10,000 for the goods, plus GBP 700 freight to the border, plus GBP 40 insurance, plus GBP 1,000 as the assist proportion, one fifth of the mould's value. Total: GBP 11,740. The GBP 200 of domestic freight stays outside the base, because it arose after arrival in the UK and is shown separately. Whoever counts only the goods invoice understates the base by a double-digit percentage, and the difference surfaces at the first post-clearance audit.

Sources

Unsure what to add to the customs value of your deliveries? Write via our contact form: we will review the delivery terms and documents while setting up your clearance.

Frequently asked questions

Is freight from Poland to the UK included in the customs value?
Yes, up to the place of entry into the UK customs territory. If you pay for transport separately, for example under EXW or FCA, the carriage cost to the border must be added to the base in the declaration. UK domestic freight stays outside the customs value, provided it is shown separately.
What are assists and why do they raise the customs value?
Items handed to the producer free or at reduced cost for production: moulds, tools, materials, design work done outside the UK. Economically they are part of the cost of the goods, so their value is added proportionally to the customs value even though they never appear on the invoice.
What is the risk of an understated customs value in the UK?
Paying the missing duty and VAT with interest, and penalties for serious discrepancies. Errors surface in post-clearance audits, when HMRC compares declarations with contracts, accounts and payments, often many months later.

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