Customs Comprehensive Guarantee and Brexit

Currently you need a CCG (via a bank) in place if the business engages in any of the following. The bank makes a charge to the business for the guarantee.

• Has a Deferment Account Number (DAN) which defers import VAT and customs duty.  There are systems currently to reduce the guarantees required for both VAT (SIVA) and excise duty (EPSS) for compliant businesses.  The guarantee is by default (unless reduced by one of these schemes) twice the monthly deferment limit, termed actual debt.
• Uses one or more the temporary import reliefs such as inward processing, and the potential duty at stake is termed potential debt.
• Imports goods to a customs or excise warehouse in the UK, and the potential duty at stake is termed potential debt.

From 1 January 2021, HMRC are reducing the need for so many CCG’s and only if the business engages in the following may a CCG be required.

• Has a DAN for customs duty (not import VAT as this will be subject to postponed accounting) in the UK (Scotland, England or Wales)
• Uses one or more of the temporary import reliefs such as inward processing
• Imports goods to a customs or excise warehouse
• Imports goods directly into Northern Ireland from outside the UK under a DAN

However as a mitigation measure post Brexit, HMRC are writing to CCG holders to advise them if their CCG is still required.  HMRC review the importers financial standing remotely (from accounts submitted to Companies House presumably) and if they judge that the risk of insolvency is low, coupled with a good compliance record with them, they are withdrawing the need for a CCG.  The importer is invited to write to the HMRC CCG team in Manchester after 1/1/21 and ask for its removal.