"I'm a worthless piece of shit that weighs 21lbs and is from California. Please let me in."
If you were Irish customs in Dublin, what would you make of the following? Someone's clearly taking the piss. Audio speakers for fifty bucks the pair?
"I’d like to inform you that your shipment is being held by customs. Customs suspect that the items being imported may have been undervalued. Please see attached commercial invoice received from the shipper. Please be aware that this is now beyond FedEx control and we need to comply with their requirements to release the shipment. We need invoice/order details (pro-forma not acceptable) and proof of payment. If the required documents are not received within 5 days of this email, the consignment will either be sent back to the shipper or destroyed."
It took exactly two weeks past the ship date before I even got the above. Until then calling FedEx netted no answers on why the freight just sat in Dublin for 10 days. I'd been told that this invoice would be at importer cost. It's obviously not retail and still below dealer cost. But it fairly compensates the firm by insurance claim were their shipment to be lost or damaged. That's how fair value is assessed. What would it cost the maker to replace it? Calling it $50 was stupidity of the highest order. I'm mystified why it's only Americans who commit this mistake though clearly not all US brands do. Everyone else understands that despite endless jokes to the contrary, Irish customs aren't morons to believe a declared throwaway value that's disproportionate to a shipment's weight, size and country of origin.
Given that I'd covered all of it upfront to be assured proper valuation for zero customs hassles, it was clearly no more than a breakdown of communication between the company boss I'd communicated with and the day's shipping elf. Still it rankles that said elf was so ignorant of the serious business of import/export and the principle of value-added tax. Wherever a custom's inspector suspects foul play to deflate our 23% import tariff for non-EU shipments, he will freeze a shipment until reparations are made. That he won't be in a rush goes without saying. Once played, twice suspicious. With this now having happened one time too many, I decided to publish this brief article for reference and new clients.
So what about commercial samples which aren't purchased for any price but are simply on short-term loan?
"Please note that if the shipment is a free sample, customs requires a formal letter from the shipper to clarify that the goods are samples. This formal letter is required even if 'sample' was written on the commercial invoice. Please note that the letter must be signed and dated. Please forward together with the commercial invoice/order details a formal letter written by the shipper saying that the goods are samples, gifts or free goods instead of a payment transaction. You can also send the emails/chat between yourselves and the shipper mentioning what the goods are when placing the order. Screenshot is acceptable. Irish customs do not accept paperwork in any language other than English and all documents must be in PDF format."
After my shipper submitted said letter inexplicably still with the original €50 value, customs turned the screws: "As this declaration is claiming a relief of samples (C30), before we proceed please refer to the Revenue website for guidance on importation of samples. Please note that these goods must only be used as samples; be of negligible value; and be used to obtain orders of goods they represent. Please also note that Revenue may request that the samples be rendered permanently unusable. The samples may be torn, perforated or indelibly marked. If the consignee is happy to proceed, please revert back with the required documentation and consignee confirmation that they're happy with the goods being marked/torn etc and we may proceed with the next steps."
Getting defaced was a no-go. In their correspondence with the shipper, FedEx eventually keyed into the 'will be returned' aspect. They offered to formally change the shipment's status to a temporary importation. If you're a non-EU manufacturer, save us the headache. Either execute proper temporary importation docs called an ATA carnet or commodity's passport—saying 'will be returned' is far from enough!—or import the product with a fair value whilst having applicable VAT billed to your account. How was Audience advised to wiggle out of the tight spot they created for themselves? From the Irish customs exam team: "To clear this as temporary import we need a C516 authorization and TEA authorization for the use of temporary admission (column 8d, annex A of delegated regulation (EU) 2015/2446). Apply by Customs Decision System aka CDS. With this we can clear your shipment without issue just by adding a C516 document and reference and using 5300 CPC. If C516 is not available, we need additional information for 'occasional' temporary storage declaration." To assist with this jargon and paperwork is why professionals have a FedEx or UPS account manager to call on for support when the resident shipping elf is way in over his/her head. The elf must simply be smart enough to know they're in over their head and ask for help.
How did my Audience holdup end? Exactly a month after my shipment departed the US and 27 days after it landed in Dublin, it finally cleared customs under revised temporary importation papers with a declared importer-cost value. Cheers to helpful FedEx personnel who made all of it happen…
