Inward processing

Inward processing is a special procedure where goods are brought to the customs territory of the EU for processing. Goods placed under the procedure can be processed e.g. by manufacture, repair, restoring, putting them in order or some other handling.

All kinds of goods can be placed under the inward processing procedure. Goods with an import duty of zero per cent can also be placed under the procedure.

When goods are placed under the procedure, no import duties, VAT, excise duty or anti-dumping duties are levied on them. These will be levied only when the procedure is discharged, if it is discharged by releasing the goods placed under the procedure or the processed products for free circulation and consumption in the customs territory of the EU.

Goods to be placed under the inward processing procedure are only subject to trade policy measures prohibiting the entry of goods into the customs territory of the EU or their exit from the customs territory of the EU.

The use of the procedure always requires an authorisation granted by Customs. Apply for a written authorisation from the Customs Authorisation Centre. A customs declaration can also serve as an application for authorisation, in which case releasing the goods for the procedure also serves as the authorisation.

Examples of uses of inward processing:

  • The procedure normally begins with import (IM/EX), where goods are imported from outside the EU to the territory of the EU for processing. Example: Fabric is imported to the EU territory as raw material for manufacturing T-shirts manufactured under processing.
  • It is also possible to start the procedure with prior export (EX/IM). First, the finished processed products obtained from equivalent Union goods are exported from the EU. After the export, non-Union goods can be imported from outside the EU in place of the equivalent Union goods used in the manufacture. Inward processing beginning with prior export always requires a written authorisation granted by the Customs Authorisation Centre, indicating prior export and the possibility to use equivalent Union goods. Example: Finished processed products, T-shirts, manufactured from equivalent Union goods – fabric – are exported from the EU. Non-Union fabric, the same amount that was used for manufacturing the exported T-shirts, is imported from outside the EU.

As a rule, the authorisation holder must be established in customs territory of the EU. In occasional cases and where it is considered justified, authorisation may also be granted to a person established outside the customs territory of the Union. In that case, it is usually a question of a private individual and the case is not considered having significant economic importance.

The procedure must be discharged within the time limit indicated in the authorisation for inward processing. The procedure can be discharged by any acceptable customs procedure, usually re-export or release for free circulation. If the procedure is discharged by releasing the goods for free circulation, customs duty and VAT must be paid for the goods. Other alternatives are e.g. the placing of goods under the customs warehousing procedure or the transit procedure.

Inward processing: general information about procedure codes

  • The previous national procedure codes for inward processing beginning with ‘7’ will no longer be in use
    • The procedure codes will first be taken out of use in import declarations that are lodged in the Customs Clearance Service (UTU)
    • The codes will still be in use for procedures that start with export, until the export declarations are also transferred to the Customs Clearance Service (UTU) 
  • The national procedures codes will no longer be in use. In the future, the procedure is supplemented with additional procedure codes
    • The additional procedure code does not specify, whether the authorisation in question is granted by the Customs authorisation centre or if it’s applied for with a customs declaration
  • Provide the additional information required for the special procedure
    • by message with the additional information codes for the goods item (e.g. ‘FIXBQ – proposed means of identification’)
    • in the Customs Clearance Service by writing in the text field, or by selecting the additional information from the drop-down menu

Bill of discharge and time limits for discharging the procedure

  • The bill of discharge can be provided with a document sent separately or with a free-form contact message FI439, with code 007 as reason for contact 
    • The bill of discharge will be getting its own message FI488
  • A reminder message is coming regarding the expiry of the time limit for the procedure and the time limit for providing a bill of discharge
    • Customs procedure 5111 is an exception
  • The customer can request an extension to the time limit for discharging the procedure with message FI439 and reason code ‘003 – Request for time-limit extension’

The most commonly used codes in inward processing

  • Customs procedure code 51xx
  • Additional procedure code 999
  • Preferential treatment 100
  • Nature of business activity (transaction) 11, 41, 42, or 60

Authorisation granted by Customs’ Authorisation Centre

  • Type and number of the authorisation
    • No other authorisation-related details are needed, just the type and number
    • Additional information connected to the procedure, such as the time limit, is generated automatically on the decision according to the authorisation.
    • The authorisation granted by Customs’ Authorisation Centre must be in force when the procedure starts.
    • The details in the declaration are compared to the authorisation, so changes to the authorisation must be made immediately if the changes are related to
      • commodity codes
      • the address of the place of processing

Authorisation applied for with a customs declaration

  • When applying for an authorisation with a customs declaration, you must use a standard customs declaration.
  • When applying for an authorisation with a customs declaration in the Customs Clearance Service:
    • After selecting the customs procedure, select the option stating that you have no valid authorisation. You can also copy a declaration you have submitted previously, in which case the details of that authorisation request will be automatically copied to the new declaration.
    • Provide the additional details on the special procedure under “Authorisation request”. Provide the additional detail by selecting it from the drop-down menu or entering the required text.
    • For example, provide the proposed method of identification as follows:
      • Always select the code “7 – Other means of identification”, and as the identification, enter “records” and the address where the records are stored.
      • Two methods of identification are often required, so also select for example the code “1 – Serial number or manufacturer number” and enter the serial number or manufacturer’s number.
  • When you are applying for an authorisation with a message declaration, provide the additional information on the special procedure using the following additional information codes:
    • ”00100 – Application for authorisation for the use of a special procedure other than transit based on the customs declaration” and leave the description field blank
    • one of the customs debt articles:
      • “FID85” (Article 85 UCC)
      • “FID86” (Article 86(3) UCC)
    • “FIXBH – Period for discharge” and as its description the time in whole months
    • “FIXBJ – Customs offices of discharge” and as its description the identifier of the customs office that discharges the procedure
    • “FIXAA – supervising customs office”
      • In Finland, always enter “FI002000 – Electronic Service Centre”
    • “FIXBP – Processed products (CN code;description)” and as its description the commodity code and goods description (in a the format “8901101000;Sea-going vessel” in the XML message)
    • “FIXBO – Rate of yield” and as its description the quantity or percentage of processed products obtained from the goods (e.g. “100%” when all products are used)
    • ”FIXBN – Details of planned activities” and as its description the nature of the use, e.g. repair, cutting, sewing, machining or assembly
    • “FIXBQ – Identification of goods”
      • As the description, provide the code and its qualifier:
        • “1” – Serial number or manufacturer number
        • “2” – Affixing lead seals, seals, stamps or other similar distinguishing signs
        • “4” – Taking samples and using illustrations or technical descriptions
        • “5” – Carrying out analyses
        • “6” – Communication form to facilitate the temporary export of goods sent from one country to another for manufacturing, processing or repairs (only suitable for the outward processing procedure)
        • “7” – Other means of identification (an explanation to be provided on the means of identification used)
        • “8” – No measures of identification in accordance with Article 250(2)(b) of the Code (only suitable for temporary admission)
      • Example of a description of the FIXBQ code when providing methods of identification:
        • Always provide the code “7” followed by a semicolon and the address where the records are stored as a qualifier (in the format “7;place where the records are stored” in the XML message).
        • In the case of for example a car, also provide the code “1” (Serial number or manufacturer number) and the vehicle identification number (VIN) of the car as the qualifier (in the format “1;12356” in the XML message).
  • The place of processing is entered with two additional information codes in the future:
    • Always enter ‘FIXAC – Place(s) of processing.’ 
    • In addition, enter ‘FIFPU – First place of use or processing’ when  
      • the first place of use or processing is in another EU country or
      • the authorisation holder is established outside the Union

Changes to the additional information codes on economic conditions used when applying for an authorisation with a customs declaration

  • The economic condition codes used previously, such as “XAU”, “XAS” and “XBG”, will no longer be used.
  • In the Customs Clearance Service, select the economic condition code from the drop-down menu.
  • In a message declaration, provide the additional information code “FIXBG” and as its description the code stating what economic condition is used. The following codes are possible:
    • code “1” – the processing of goods not listed in Annex 71-02
    • code “2” – repair
    • code “3” – the processing of goods directly or indirectly put at the disposal of the holder of the authorisation, carried out according to specifications on behalf of a person established outside of the customs territory of the Union, generally in return for payment of processing costs alone (=processing under contract)
    • code “10” – the processing of goods to ensure their compliance with technical requirements for their release for free circulation
    • code “11” – the processing of goods of a non-commercial nature (for example, goods placed under the procedure by a private person)
    • code “12” – the processing of goods obtained under a previous authorisation, the issuing of which was subject to an examination of the economic conditions
    • code “13” – the processing of solid and fluid fractions of palm oil, coconut oil, fluid fractions of coconut oil, palm kernel oil, fluid fractions of palm kernel oil, babassu oil or castor oil into products which are not destined for the food sector
    • code “14” – the processing into products to be incorporated in or used for civil aircraft for which an authorised release certificate has been issued (i.e. an EASA Form 1 or an equivalent certificate referred to in Article 2 of Council Regulation (EU) 2018/581)
    • code “15” – the processing into products benefitting from the autonomous suspension of import duty on certain weapons and military equipment in accordance with Council Regulation (EC) No 150/2003 ( 1 )
    • code “16” – the processing of goods into samples
    • code “17” – the processing of any electronic type of components, parts, assemblies or any other materials into information technology products
    • code “18” – the processing of goods falling within CN codes 2707 or 2710 into products falling within CN codes 2707, 2710 or 2902
    • code “19” – the reduction to waste and scrap, destruction, recovery of parts or components
    • code “21” – usual forms of handling referred to in Article 220 of the Code
    • code “22” – the aggregate value of goods to be placed under the inward processing procedure per applicant and calendar year for each eight-digit CN code does not exceed EUR 150 000 with regard to goods which are covered by Annex 71-02 to Delegated Regulation (EU) 2015/2446 and EUR 300 000 for other goods, except where the goods intended to be placed under the inward processing procedure would be subject to a provisional or definitive anti-dumping duty, a countervailing duty, a safeguard measure or an additional duty resulting from a suspension of concessions if they were declared for release for free circulation.

Inward processing where prior export of equivalent goods ends with import

  • Customs procedure 5111, will also in the future require an authorisation from Customs’ Authorisation Centre
  • The authorisation must also in the future have a mention of the use of equivalent goods 
  • When the goods are placed under the procedure, an INF number must be entered in the customs declaration, so that no bill of discharge has to be provided 
  • No reminder message is sent regarding the expiry of the time limit for the procedure

Points to consider

Provide the following details in the customs declaration, when the goods are being released for free circulation from the customs procedure for inward processing (4051) and the customs debt is being incurred based on Article 85 of the UCC.

Provide the following details:

  • procedure 4051
  • commodity code of the goods being declared
  • value and quantity of goods at the time of declaration
  • details of the authorisation, if you have a written authorisation granted by the Customs Authorisation Centre
    • Provide the authorisation using the additional document code “C601 IPO – authorisation for the use of inward processing procedure” and enter the authorisation number as the description.
  • previous document
    • Provide the previous document with the code “IM” and, as identification, the customs clearance number you received from the service Import declarations for businesses – special procedures (ITU).
  • additional procedure code 644, when the inward processing procedure ends with release for free circulation and you wish to apply Article 85(1) of the UCC for determining the customs debt
  • additional information code “00700 IP – Discharge of inward processing (Article 241(1) first sub-paragraph of Delegated Regulation (EU) 2015/2446)”
    • Provide one of the following as the description for the code “00700”:
      • inward processing authorisation number, if you have a written authorisation
      • customs clearance number, if the authorisation has been applied for with a customs declaration
    • In addition to the additional information code “00700”, provide the additional information code “00800 IP CPM / Discharge of inward processing (specific commercial policy measures) / Article 241(1) second sub-paragraph of Delegated Regulation (EU) 2015/2446”, if certain commercial policy measures were applied to the goods originally placed under the inward processing procedure and these measures are still applied when the goods (including the processed products) are placed under the following customs procedure. In the description, indicate which commercial policy measure is applied to the goods.
      • Please note: Commercial policy measures are non-tariff measures (UCC Article 5(36)). Commercial policy measures include e.g. required documents such as surveillance documents, health certificates, import licences as well as import prohibitions and restrictions. However, e.g. anti-dumping duties and safeguard measures are tariff measures, which are not considered as commercial policy measures.

Provide the following details in the customs declaration, when the goods are being released for free circulation from the customs procedure for inward processing (4051) and the customs debt is being incurred based on Article 86(3) of the UCC. The customs debt is incurred based on this article, if the customs debt article UCC 86(3) is indicated in the authorisation and processed products in accordance with the authorisation are being released for free circulation.

 Provide the following details:

  • procedure 4051
  • the commodity code of the finished processed product in accordance with the authorisation
  • the value and quantity of the finished processed product in accordance with the authorisation
  • details of the authorisation, if you have a written authorisation granted by the Customs Authorisation Centre
    • Provide the authorisation using the additional document code “C601 IPO – authorisation for the use of inward processing procedure” and enter the authorisation number as the description.
  • previous document
    • Provide the previous document with the code “IM” and, as identification, the customs clearance number you received from the service Import declarations for businesses – special procedures (ITU).
  • additional procedure code F44, when the inward processing procedure ends with release for free circulation of the processed products in accordance with the authorisation and UCC Article 86(3) has been determined as the customs debt article.
    • For the levy of customs duty, provide the following details with the additional information code ”FIXXX” for each goods item:
      • the commodity code and goods description of the goods placed under the inward processing procedure
      • how much of the goods placed under the inward processing procedure has been used for the manufacture of the product being released for free circulation
      • the value and origin of the goods placed under the inward processing procedure.
  • additional information code “00700 IP – Discharge of inward processing (Article 241(1) first sub-paragraph of Delegated Regulation (EU) 2015/2446)”
    • Provide one of the following as the description for the code “00700”:
      • inward processing authorisation number, if you have a written authorisation
      • customs clearance number, if the authorisation has been applied for with a customs declaration
    • In addition to the additional information code “00700”, provide the additional information code “00800 IP CPM / Discharge of inward processing (specific commercial policy measures) / Article 241(1) second sub-paragraph of Delegated Regulation (EU) 2015/2446”, if certain commercial policy measures were applied to the goods originally placed under the inward processing procedure and these measures are still applied when the goods (including the processed products) are placed under the following customs procedure. In the description, indicate which commercial policy measure is applied to the goods.
      • Please note: Commercial policy measures are non-tariff measures (UCC Article 5(36)). Commercial policy measures include e.g. required documents such as surveillance documents, health certificates, import licences as well as import prohibitions and restrictions. However, e.g. anti-dumping duties and safeguard measures are tariff measures, which are not considered as commercial policy measures.

Provide the following details in the customs declaration, when the goods were imported for repair and placed under the inward processing procedure (4051), but they could not be repaired and the defective product is released for free circulation. In this case, the customs value is determined based on UCC Article 85.

Follow the guidance according to whether you have paid the owner for the defective goods or not.

If you have paid for the defective goods

Provide the following details when you are declaring defective goods which have not been repaired and for which you have paid a compensation to the owner or you have bought the goods:

  • procedure 4051
  • additional procedure code 644
  • commodity code of the goods, which must be the same as when placing them under the inward processing procedure
  • nature of transaction
    • If the transaction is based on a purchase or sale, enter “11 – Outright purchase/sale”
  • value of the goods
    • As transaction price (invoice price), provide the value of the goods and add the repair costs if they are not already included in the transaction price.
    • Provide the items to be added to the transaction value:
      • When the value does not exceed 20 000 euros, provide e.g. freight and insurance using the code “1A – Total to be added”.
      • When the value exceeds 20 000 euros, provide e.g. freight and insurance using the code “AK – Transport costs, loading and handling charges and insurance costs up to the place of introduction in the European Union”.
  • valuation method
    • If the nature of transaction is “11 – Outright purchase/sale”, provide the code “1 – Transaction value of the imported goods”.
  • details of the authorisation, if you have a written authorisation granted by the Customs Authorisation Centre
    • Provide the authorisation using the additional document code “C601 IPO – authorisation for the use of inward processing procedure” and enter the authorisation number as the description.
  • previous document
    • Provide the previous document with the code “IM” and, as identification, the customs clearance number you received from the service Import declarations for businesses – special procedures (ITU).
  • additional procedure code 644, when the inward processing ends with release for free circulation and you wish to apply Article 85(1) of the UCC for determining the customs debt.
  • additional information code “00700 IP – Discharge of inward processing (Article 241(1) first sub-paragraph of Delegated Regulation (EU) 2015/2446)”
    • Provide one of the following as the description for the code “00700”:
      • inward processing authorisation number, if you have a written authorisation
      • customs clearance number, if the authorisation has been applied for with a customs declaration
    • In addition to the additional information code “00700”, provide the additional information code “00800 IP CPM / Discharge of inward processing (specific commercial policy measures) / Article 241(1) second sub-paragraph of Delegated Regulation (EU) 2015/2446”, if certain commercial policy measures were applied to the goods originally placed under the inward processing procedure and these measures are still applied when the goods (including the processed products) are placed under the following customs procedure. In the description, indicate which commercial policy measure is applied to the goods.
      • Please note: According to UCC Article 5(36), the commercial policy measures are non-tariff measures. Commercial policy measures include e.g. required documents such as surveillance documents, health certificates, import licences as well as import prohibitions and restrictions. However, e.g. anti-dumping duties and safeguard measures are tariff measures, which are not considered as commercial policy measures.

When you have not paid for the defective goods

Provide the following details when you are declaring defective goods which have not been repaired and for which you have not paid any compensation to the owner of the goods:

  • procedure 4051
  • additional procedure code 644
  • commodity code of the goods, which must be the same as when placing them under the inward processing procedure
  • nature of transaction
    • If the ownership of the goods has been transferred without financial compensation, provide as nature of transaction “34 – Transactions involving transfer of ownership without financial compensation”.
  • value of the goods
    • there must be written proof of the value of the goods that is verifiable afterwards
    • the value of the goods must always also include the repair costs
    • If the goods are free of charge, you can provide 0 as the transaction price (invoice price) and the currency.
      • If no customs duty is levied on the goods and their the value does not exceed 20 000 euros, provide the value of the goods including the repair costs and the additional costs incurred outside the EU, such as freight and insurance, as an item to be added using the code “1A – Total to be added”.
      • If customs duty is levied on the goods or their value exceeds 20 000 euros, provide the value of the goods including the repair costs and the additional costs incurred outside the EU, such as freight and insurance, as an item to be added using the code “AK – Transport costs, loading and handling charges and insurance costs up to the place of introduction in the European Union”.
  • at goods item level, with the additional information code “FIXXX – Other additional information” the reason why the goods are free of charge.
  • as attachment a document containing a calculation or basis for the value of the goods
    • The document must clearly show what the value declared to Customs is based on.

 

  • valuation method
    • When 34 has been provided as the nature of transaction, provide one of the following code as the valuation method:
      • ”2 – Transaction value of identical goods”
      • ”3 – Transaction value of similar goods”
      • ”4 – Deductive value method”
      • ”5 – Deductive value method”
      • ”6 – Value based on the data available (‘fallback’ method)”

 

  • details of the authorisation, if you have a written authorisation granted by the Customs Authorisation Centre
    • Provide the authorisation using the additional document code “C601 IPO – authorisation for the use of inward processing procedure” and enter the authorisation number as the description.
  • previous document
    • Provide the previous document with the code “IM” and, as identification, the customs clearance number you received from the service Import declarations for businesses – special procedures (ITU).
  • additional procedure 644, when the inward processing procedure ends with release for free circulation and you wish to apply Article 85(1) of the UCC for determining the customs debt.
  • additional information code “00700 IP – Discharge of inward processing (Article 241(1) first sub-paragraph of Delegated Regulation (EU) 2015/2446)”
    • Provide one of the following as the description for the code “00700”:
      • inward processing authorisation number, if you have a written authorisation
      • customs clearance number, if the authorisation has been applied for with a customs declaration
    • In addition to the additional information code “00700”, provide the additional information code “00800 IP CPM / Discharge of inward processing (specific commercial policy measures) / Article 241(1) second sub-paragraph of Delegated Regulation (EU) 2015/2446”, if certain commercial policy measures were applied to the goods originally placed under the inward processing procedure and these measures are still applied when the goods (including the processed products) are placed under the following customs procedure. In the description, indicate which commercial policy measure is applied to the goods.
      • Please note: Commercial policy measures are non-tariff measures (UCC Article 5(36)). Commercial policy measures include e.g. required documents such as surveillance documents, health certificates, import licences as well as import prohibitions and restrictions. However, e.g. anti-dumping duties and safeguard measures are tariff measures, which are not considered as commercial policy measures.

Destruction or scrapping of goods that have been under inward processing

If the purpose is to destroy goods placed under the inward processing procedure, declare the goods again for the inward processing procedure 5151. Provide “19 – the reduction to waste and scrap, destruction, recovery of parts or components” as the economic condition for the new inward processing procedure. The person placing the goods under the procedure does not have to be the authorisation holder that originally placed the goods under the inward processing procedure.

Any scrap or waste resulting from the destruction of the goods must be declared for free circulation. Use the customs procedure 4051 and the additional procedure 644. You can use the commodity code and value of waste or scrap in the customs declaration.


The inward processing procedure can be discharged by the customs warehousing procedure. If the goods placed under the customs warehousing procedure, which have previously been placed under inward processing, are released for free circulation, provide the details in the declaration in accordance with the inward processing procedure.

Provide the following details in the customs declaration:

  • customs procedure code 4051 (customs procedure code 4071 is not used)
  • customs debt article according to the inward processing authorisation with the additional procedure code 644 or F44 as well as the details required by the customs procedure and the additional procedure
  • the customs warehousing MRN as the previous document
  • the code “FICWD – Release from customs warehouse” in the additional information for the goods item
  • as additional document for the goods item the transaction identifier of inward processing with the code “1ZZZ”.

See the other additional information to be provided in the declaration according to customs debt article indicated in the authorisation. If the customs debt article is UCC 85, read “Discharge of inward processing by release for free circulation (UCC 85), additional procedure code 644”. If the customs debt article is UCC 86(3), read “Discharge of inward processing by release for free circulation (UCC 86(3)), additional procedure code F44”.

Don’t forget to provide the additional information codes:

  • Always provide the additional information code “00700 IP – Discharge of inward processing (Article 241(1) first sub-paragraph of Delegated Regulation (EU) 2015/2446)”
    • Provide one of the following as the description for the code “00700”:
      • inward processing authorisation number, if you have a written authorisation
      • customs clearance number, if the authorisation has been applied for with a customs declaration
    • In addition to the additional information code “00700”, provide the additional information code “00800 IP CPM / Discharge of inward processing (specific commercial policy measures) / Article 241(1) second sub-paragraph of Delegated Regulation (EU) 2015/2446”, if certain commercial policy measures were applied to the goods originally placed under the inward processing procedure and these measures are still applied when the goods (including the processed products) are placed under the following customs procedure. In the description, indicate which commercial policy measure is applied to the goods.
      • Please note: Commercial policy measures are non-tariff measures (UCC Article 5(36)). Commercial policy measures include e.g. required documents such as surveillance documents, health certificates, import licences as well as import prohibitions and restrictions. However, e.g. anti-dumping duties and safeguard measures are tariff measures, which are not considered as commercial policy measures.

When the goods are released from the inward processing procedure for free circulation, provide the statistical value as follows:

In the customs declaration for customs procedure 4051, provide as the statistical value the value of the imported goods including the processing costs of the goods, the value of added materials as well as the freight and insurance costs. The statistical value is provided in the same way regardless of the customs debt article.


The use of equivalent goods requires an authorisation applied for in advance from the Customs Authorisation Centre. It must be indicated in the authorisation that the use of equivalent goods is allowed.

Equivalent Union goods can be used in the inward processing procedure (51xx) (IM/EX) for obtaining products that will be exported from the EU.

The equivalent Union goods and the non-Union goods placed under the procedure must have the same eight-digit commodity code as well as the same commercial quality and the same technical characteristics.

Using equivalent goods

Using equivalent goods means that Union goods are used in the processing instead of non-Union goods (customs procedure code 51xx, national procedure code 7SA).

Finished processed goods obtained from equivalent Union goods are re-exported (customs procedure code 3151, national procedure code 7SA). An import declaration must be submitted at the same time as the re-export declaration for the non-Union goods placed under the inward processing procedure. The non-Union goods placed under the inward processing procedure become Union goods and they must be declared for free circulation (customs procedure code 4051, additional procedure code 160). The declaration is submitted for establishing the prohibitions and import restrictions, although no import duty is levied for the goods.  

Example: 100 kilos of non-Union sugar is placed under the inward processing procedure (customs procedure code 51xx, national procedure code 7SA). Strawberry jam is produced through the processing by using 100 kilos of equivalent Union sugar. The strawberry jam produced using Union sugar is re-exported (customs procedure code 3151, national procedure code 7SA). At the same time, an import declaration is submitted for the non-Union sugar placed under the inward processing procedure (customs procedure code 4051, additional procedure code 160). The non-Union sugar placed under inward processing becomes Union goods. 

Using equivalent goods when prior export is used

If you use prior export in inward processing, you need a written authorisation granted by the Customs Authorisation Centre, indicating prior export in addition to the use of equivalent goods.

In inward processing involving prior export, products obtained from equivalent Union goods have been exported from the EU. Based on the export of these Union goods, an import allowance is created for the same quantity of non-Union goods, that have been included as Union goods in the exported products. The finished products have first been exported from the EU using prior export under the customs procedure 11xx (EX/IM). In addition to the export declaration, an electronic INF must always be submitted for the goods. The non-Union goods imported on the basis of the import allowance are declared under the customs procedure 51xx, and the national procedure is 7SE. The non-Union goods must be imported to the Union within 6 months of the acceptance of the prior export.

Example: 100 kilos of strawberry jam is exported using prior export under inward processing (customs procedure 11xx and national procedure code 7SE), and equivalent Union goods (50 kilos of Union sugar) have been used in the production of the jam. Based on the export of the strawberry jam, an import allowance is created for the same quantity of non-Union goods, i.e. for 50 kilos of non-Union sugar.

The authorisation holder must have chosen in their authorisation application which customs debt article shall primarily be applied. The customs debt article indicated in the authorisation must be used, when main processed products in accordance with the authorisation are cleared for free circulation and a customs debt is incurred.

In inward processing, the customs debt article is one of the following:

  • Article 86(3) of the Union Customs Code (UCC 86(3))
  • Article 85 of the Union Customs Code (UCC 85)

Customs debt article UCC 86(3)

  • When you have chosen UCC 86(3) as the customs debt article and the procedure is discharged by releasing the processed products in accordance with the authorisation for free circulation, the customs debt that is incurred is determined based on the products placed under the inward processing procedure.
  • When you have chosen UCC 86(3) as the customs debt article, the products to be released for free circulation must be finished processed products in accordance with the authorisation. If the products are not finished processed products in accordance with the authorisation (they are e.g. secondary processed products or waste from the processing), the customs debt article UCC 85 is applied to them. 
  • If a customs debt is incurred, it will be levied in accordance with the import duty levels applicable on the day when the customs debt is incurred.
Example: Fabric (commodity code 5209xxxx, value 1000 euros, 100 kg) has been imported from India to the Union on 1 January 2022 and placed under the inward processing procedure (51xx). Blouses under commodity code 6206xxxx are produced under processing. The blouses are cleared for free circulation (4051) on 2 February 2022. The import duties are determined in accordance with the duty level applicable on 2 February 2022 for the goods placed under the procedure, that is, fabric (commodity code 5209xxxx, value of the goods used in the production 1000 euros, the quantity of goods used in the production 100 kg and origin India). 

Customs debt article UCC 85

  • When you have chosen UCC 85 as the customs debt article, and the procedure is discharged by releasing the processed products in accordance with the authorisation for free circulation, the customs debt that is incurred is determined based on the goods released for free circulation (4051). This means that customs debt is levied on the goods, quantity and value being released for free circulation. This customs debt article is used if the customs debt is incurred for finished processed products, secondary processed products or any waste from the processing.
  • If a customs debt is incurred, it will be levied in accordance with the import duty levels applicable on the day when the customs debt is incurred for the goods actually presented to customs. In the case of finished processed goods, the duty level is determined in accordance with the commodity code of the finished goods. In that case, the value of the finished processed goods, including the processing costs, is used as the customs value.
Example: Fabric (commodity code 5209xxxx, value 1000 euros, 100 kg) has been imported from India to the Union on 1 January 2022 and placed under the inward processing procedure (51xx). Blouses under commodity code 6206xxxx are produced under processing. The blouses are cleared for free circulation (4051) on 2 February 2022. The import duties are determined in accordance with the import duty level applicable on 2 February 2022 for the goods produced under the procedure, that is, blouses (commodity code 6206xxxx, value of the processed goods 12 000 euros, the quantity of the processed goods 120 kg and origin India).

The authorisation holder must keep records of the goods placed under the procedure. Records are necessary, because the customs authority must be able to supervise and control goods placed under the procedure.

If the use of the procedure is small scale, the records don’t necessarily have to be electronic, but Customs may also accept records in paper form.


Using the inward processing procedure always requires an authorisation.

Who can get an authorisation?

An authorisation for inward processing can be granted to a business established in the Union which carries out the processing or arranges for it to be carried out. An authorisation is not granted e.g. to an importer who sells or uses the goods as such or who doesn’t have any connection with processing operations.

In occasional cases and where it is considered justified, authorisation may also be granted to a person established outside the customs territory of the Union. In that case, it is usually a question of a private individual and the case is not considered having significant economic importance.

What kind of authorisation is required?

Authorisation for the procedure can also be applied for with a customs declaration. In that case, the required additional information is provided when you are submitting the declaration in the service Import declarations for businesses – special procedures, with a message or with the SAD form at a customs office. The authorisation has been granted when the customs declaration is accepted and the goods are released for the inward processing procedure.

However, you must always have a written authorisation granted by the Customs Authorisation Centre, if you submit a simplified customs declaration or use centralised clearance or entry in the declarant’s records. A written authorisation is also required if you are going to use equivalent goods in the activities or if the processing operations are carried out in more than one member state.

Extending the authorisation to include further processing

You can apply for an extension of a written authorisation for the inward processing procedure, if you wish to export goods placed under the procedure temporarily from the Union for further processing.

However, further processing can be performed outside the Union also without extending a written authorisation. In such case, do this:

  • inward processing is discharged by re-export 3151 from the Union
  • after further processing, the goods imported from outside the Union are placed under the inward processing procedure again.

How to apply for an authorisation

If you are applying for a written authorisation from the Customs Authorisation Centre, apply for it in advance. In that case, apply for an authorisation for the use of inward processing procedure in the online Authorisation Service via the front page of Customs’ e-services.

If you are applying for an authorisation involving more than one Member State, submit your application in the Customs Decisions System (CDS).The issuing of authorisations involving more than one Member State requires, among other things, agreement by all the participating Member States and the creation of a system for exchange of information between the holder of the authorisation and the Member States. 


The holder of the authorisation must provide the supervising customs office with the bill of discharge within 30 days of expiry of the time limit for discharging the procedure.

Unless otherwise instructed by the supervising customs office, the details mentioned in Annex 71–06 of the Delegated Regulation (EU) 2015/2446 shall be provided in the bill of discharge. The details required in the bill of discharge are also descried in the instructions for the holder of authorisation for the inward processing procedure.

After the bill of discharge has been approved, the reserved guarantee is released or refunded.

The authorisation holder or their representative must send the bills of discharge to the customs office supervising the procedure indicated in the authorisation. If you are a credit customer, the supervising customs office is the Electronic Service Centre (valvovatulli(at)tulli.fi). If you have lodged a liability guarantee in cash and the procedure has been started at a customs office, the bill of discharge must be sent to the customs office where the goods were placed under the inward processing procedure.

If the time limit for discharging the procedure or the time limit for providing the bill of discharge is not sufficient, you can apply for extension of the time limit from the supervising customs office with Customs form 975e ”Application, extension of procedure time limits”. If direct representation on guarantor’s liability was used when the goods were placed under the procedure, the guarantor’s agreement to extend the time limit is required.


There are also certain simplifications by which the inward processing procedure (IM/EX) can be discharged. Article 324(1) of the Implementing Regulation (EU) 2015/2447 (Implementing Act, IA) lists six cases regarded as re-export, that is, cases of discharge of the inward processing procedure.

Example: The start of a handling that leads to the manufacture of a part of an aircraft can be deemed equivalent to re-export that discharges the inward processing procedure (IA, Article 324(1)(c) and (3)). The procedure is considered as discharged also with regard to all secondary processed products, such as cuttings and leftover pieces resulting from the handling. When the handling is started, a customs declaration must be submitted to Customs (customs procedure code 4051, additional procedure code 150).

You can apply for an authorisation for simplified discharge of the inward processing procedure from the Customs Authorisation Centre in advance. The decision on authorisation must indicate that a simplified procedure is allowed (UCC Article 256 and IA Article 324).

For more information, see the instructions for inward processing (pdf) (available in Finnish).


Inward processing can be discharged by transit only if the goods are transferred to another authorisation holder within the Union. In the transit declaration, in the box for additional information, enter the following information:

  • “ZZZ” (other) and “IP” and the electronic INF reference number (if any).

As the previous procedure, enter the number of the customs clearance decision concerning the inward processing procedure.

If the goods placed under the inward processing procedure are subject to commercial policy measures (e.g. surveillance document), enter also “C P M” in addition to “IP”.


  • The applicant is established in the territory of the Union (the authorisation may, on special grounds, also be granted to an applicant established outside the Union).
  • The applicant has a valid comprehensive guarantee.
  • The applicant’s economic conditions are fulfilled.
  • The applicant shall not have committed any serious infringements of customs or tax legislation.
  • The applicant keeps sufficient records, which allow customs controls.
  • The applicant is able to submit a sufficient bill of discharge.