Outward processing that begins with import (IM/EX)
In the customs procedures 48 and 46, the outward processing begins with the import of the goods.
- In these procedures, an import declaration is submitted first, followed by an export declaration.
- The procedures must be discharged within the prescribed time limit, and finally, a notification of discharge must be submitted to Customs.
- To use the procedures, you must apply for an outward processing authorisation, provide a liability guarantee and keep records of the procedure.
Outward processing: prior import using the standard exchange system (customs procedure 48)
Outward processing that begins with prior import means that a replacement product for defective goods is imported in advance using the so-called standard exchange system.
In this customs procedure, replacement goods are released for home use and free circulation prior to the temporary export of defective goods:
- An intact product is first imported from outside the EU as a replacement for a defective item, and an import customs declaration for procedure 48 is submitted for the product.
- Then, the defective item is exported from the EU and a customs declaration for “temporary export under the outward processing procedure (2148)” is submitted for it.
- Once the defective item has been exported, a notification of discharge must be submitted to Customs.
The defective goods must be exported within 2 months of the import of the replacement goods. In addition, the general customs duty rate for the replacement goods must be higher than 0%.
Example
A company has bought a new device from a seller, but the device is broken. The seller immediately sends the company a new device as a replacement for the broken one based on its warranty.
The replacement device sent by the seller arrives, and the company submits an import declaration (procedure 48) for the device. The company submits an export declaration (procedure 2148) for the broken device (procedure 2148) and promptly returns that device to the seller after receiving the new one.
The replacement product must be the same as the defective goods in following respects:
- The product must have the same 8-digit CN code as the temporarily exported goods if they had undergone repair under the outward processing procedure.
- The product must also have the same commercial quality and technical characteristics.
- Where the export goods have been used before export, the replacement product must also have been used. However, the replacement products can be new if they are supplied free of charge, either because of a contractual or statutory obligation arising from a guarantee or because of a material or manufacturing defect.
You will need an authorisation
You need either a written authorisation applied for in advance from the Customs Authorisation Centre or an authorisation applied for with a standard customs declaration.
The applicant must be established in the customs territory of the EU.
- A legal person is considered established in the customs territory of the EU when it has its registered office, central headquarters or a permanent business establishment in the customs territory of the EU.
- A natural person is considered established in the customs territory of the EU when their habitual residence is within that territory.
In occasional cases where it is deemed justified, the authorisation can also be granted to an applicant established outside the customs territory of the EU. This is possible, for instance, if the authorisation holder is a private individual and the goods are not intended for commercial use.
Note that you can only use replacement goods in the procedure, not equivalent goods. If you’re applying for the authorisation from the Authorisation Centre, select "Vakiovaihtojärjestelmä" (standard exchange system) in the Authorisations and Decisions Service, and provide the replacement goods you have used for the authorisation.
Written outward processing authorisation (OPO) granted by the Customs Authorisation Centre
A written authorisation granted in advance by the Customs Authorisation Centre is usually valid for 5 years. Fill in the application in the Authorisations and Decisions Service (available in Finnish and Swedish). Remember to indicate in the application that you wish to use prior import. You can read more about applying for an authorisation on the page Authorisations and registrations.
Outward processing authorisation applied for with a customs declaration
In certain cases, you can apply for the authorisation with a standard customs declaration. This authorisation only covers the goods declared in the customs declaration. In the customs declaration, you should provide the additional information required for the authorisation. In accepting the customs declaration, Customs also accepts the authorisation application.
Other things to note about the use of the authorisation
An authorisation obtained from the Customs Authorisation Centre must be valid when the goods are placed under the procedure. The authorisation does not necessarily need to be valid when the procedure is discharged as long as the time limit for discharging the procedure has not yet run out.
A customs declaration for prior import can only include goods indicated in one authorisation.
When the procedure is discharged, another person established in the customs territory of the EU can use the authorisation holder’s authorisation provided that that person has obtained the authorisation holder’s consent and the conditions of the authorisation are fulfilled (e.g. that the time limit for discharging the procedure and the competent customs offices indicated in the authorisation are observed). However, only the authorisation holder can declare goods for the procedure. If another person wishes to discharge the procedure in another Member State than where the procedure was started, an authorisation involving more than one Member State is always required for the use of the procedure.
Guarantee
A liability guarantee must always be provided for the procedure. The guarantee remains reserved until the procedure has been discharged correctly and a discharge notification has been submitted to Customs. Read more about the liability guarantee on the page Comprehensive guarantee authorisation.
Records
Records must be kept of the procedure. Read more in the instruction for outward processing on the page Instructions for holders of authorisations.
Submitting the customs declarations
I you’re using a representative:
- The import declarations can be submitted by a direct representative or a direct representative under the responsibility of the guarantor.
- The export declarations can be submitted by a direct representative.
You cannot use an indirect representative to submit the customs declarations.
When you are submitting a customs declaration for outward processing involving prior import, provide the following codes:
- requested procedure “48 – entry for home use with simultaneous release for free circulation of replacement products under outward processing prior to the export of the defective goods”
- previous procedure:
- The possible previous procedures are 51, 53, 54 and 71.
- If the goods do not have a previous procedure, provide “00 – No previous procedure”.
- as the additional procedure code either ”240 – The import of replacement goods is subject to a charge” or ”241 – The import of replacement goods is not subject to a charge”
- nature of transaction “60 – Transactions not involving transfer of ownership, e.g. repair of goods; hire, loan, operational leasing or other temporary uses, for less than 24 months”
- preference code 100.
You are not required to make an INF request to use the procedure. Read more about INF requests
If you have an authorisation granted by the Customs Authorisation Centre
You can submit the customs declaration in one or two stages. Additional information related to the procedure is generated automatically on the decision according to the authorisation.
Provide the authorisation number in the customs declaration as follows:
- in message exchange under “Authorisations”
- in the Customs Clearance Service in the first choices after choosing the procedure.
If you apply for an authorisation with a customs declaration
The customs declaration must be submitted as a standard declaration. Apply for an authorisation as follows:
- When you’re applying for an authorisation with a customs declaration in the Customs Clearance Service, provide the details required for special procedures under “Authorisation request”.
- When you’re applying for an authorisation with a message, provide the detail about applying for an authorisation using the additional information code “00100 – Application for authorisation for the use of a special procedure other than transit based on the customs declaration”.
In addition, provide the additional details required for the authorisation application for the special procedure as follows:
- Customs office(s) of discharge with the customs office identifier. If you are a message declarant, use the code “FIXBJ – Customs office(s) of discharge”.
- The customs office supervising the procedure – only in message exchange – with the code “FIXAA – Supervising customs office”.
- In Finland, always provide “FI002000 – Electronic Service Centre”.
- Rate of yield of the goods as a measurement unit or a percentage (e.g. 100% when all products are used). If you are a message declarant, use the code “FIXBO – Rate of yield”.
- Details of planned activities, e.g. repair of goods based on a warranty. If you are a message declarant, use the code “FIXBN – Details of planned activities”.
- The processed product obtained from the goods with a 10-digit commodity code. Also provide the goods description of the product obtained through the processing. If you are a message declarant, use the code “FIXBP – Processed products (CN code; description)”.
- All places of processing and use as well as their address details. If you are a message declarant, use the code “FIXAC – Place(s) of processing or use”.
- The time limit for discharging the procedure is 2 months. In the Customs Clearance Service, the time limit is filled in automatically in the declaration. If you are a message declarant, use the code “FIXBH – Period for discharge”.
- Always provide the procedure record code “7 – Other means of identification (an explanation to be provided on the means of identification used)” as the identification of goods, as well as the address where the procedure records are stored. You can also enter other identification details by which the goods can be identified even after processing. If you are a message declarant, use the code “FIXBQ – Identification of goods”. Always provide the code “7” as the method for identification of goods, and in addition, you can choose one of the following identification codes:
- “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)
The procedure code for an export declaration for defective goods is 2148.
Determining the customs value in the procedure 4800 for outward processing involving prior import depends on whether the replacement product is subject to a charge or free of charge for the declarant.
Customs value of a product subject to a charge
If the replacement product is subject to a charge, the customs value and the statistical value in the customs procedure 4800 for outward processing involving prior import are determined as in the outward processing procedure 6121. The additional information code 240 has been provided in the customs declaration.
An import duty in accordance with outward processing is levied on the product. Upon import, a liability guarantee is also reserved for the amount of import duties not levied when the goods are placed under the procedure (= the difference between the standard third country import duty and the import duty levied in accordance with the tax calculation rules for the outward processing procedure).
See the guidance on how to provide the customs value under “Providing the value details” on the page Outward processing.
Customs value of a product free of charge
The replacement product is free of charge for you, so the additional procedure code 241 has been provided in the customs declaration. The customs value of a product free of charge in the customs procedure 48xx involving prior import is based on the usual transaction value or selling price of the product. A liability guarantee is reserved for the customs duty according to the transaction value of the product.
Value added tax (VAT)
If you are a VAT-registered operator, declare the import VAT to the Finnish Tax Administration.
If you are an operator not registered for VAT, provide the following details in the customs declaration as adjustments to the transaction price for the calculation of the taxable amount for VAT. See the guidance on how to provide the taxable amount for VAT under “Providing the value details” on the page Outward processing.
The value added tax is determined, for both deliveries subject to a charge and deliveries free of charge, on the basis of the customs value provided for in section 88 of the Value Added Tax Act (Articles 69–76 UCC, Article 71 DA and Articles 127–146 IA). The items referred to in sections 91–93 a of the Value Added Tax Act are added to this value.
Read more about import VAT on the Tax Administration website:
- Value added taxation of imported goods
- Taxable amount for import VAT (tax basis) (available in Finnish and Swedish, link to Finnish)
An export declaration cannot be submitted in two stages; it must always be submitted as a complete declaration.
In some cases, the declaration may also be submitted retrospectively. In these cases, Customs checks whether there are prerequisites for submitting the declaration retrospectively, and Customs either accepts or rejects the declaration.
The following details must be provided in the export declaration
- customs procedure code 2148 – outward processing procedure, export after prior import.
- additional procedure code
- “240 – Outward processing, prior import; the import of replacement goods is subject to a charge”
- “241 – Outward processing, prior import; the import of replacement goods is not subject to a charge”
- nature of transaction
- “60 – Transactions not involving transfer of ownership, e.g. repair of goods; hire, loan, operational leasing or other temporary uses, for less than 24 months”
- authorisation details
- if you have a written authorisation from the Customs Authorisation Centre, provide the authorisation using the additional document code “C019 – OPO – Authorisation for the use of outward processing procedure (Column 8b, Annex A of Delegated Regulation (EU) 2015/2446)”, and provide the authorisation number and date as the description.
- If the authorisation was applied for with the customs declaration for import, provide the additional information code FISAP in the declaration header details.
- previous document
- “NMRN – Declaration/notification MRN”, and provide the MRN and goods item number as the reference.
- value details
- Statistical value
- Provide the invoiced price as the total amount invoiced and the invoice currency. The price is the amount actually paid or to be paid for the goods, taking into account any cash, quantity or other discounts. Unlike regarding the statistical value, no additions or deductions are made regarding the total amount invoiced, and it is not converted into euros if the invoice currency is not euro.
- additional documents
- other documents relating to the export declaration, e.g. export licences and commercial invoices.
Any export restrictions that may apply should be handled in the same way as for exports in general and the related condition codes must be used.
If you have a written authorisation granted by the Customs Authorisation Centre
- You can only declare goods indicated in one authorisation in a single export declaration.
- In the export declaration, you can provide several customs declarations for special procedures as previous documents.
If you have an authorisation applied for with a customs declaration
- You can provide several customs declarations for special procedures as previous documents in the export declaration.
Discharge of the procedure
The procedure must be discharged within the prescribed time limit, and a discharge notification must be submitted to Customs. Read more on this page under “Discharge of the procedure and notification to Customs”.
Outward processing: use of equivalent goods (customs procedure 46)
In customs procedure 46 for outward processing, equivalent non-Union goods are used in the production of goods that are to be imported to the customs territory of the EU. After that, Union goods in place of which non-Union goods were used are exported outside the EU within a prescribed time limit.
Please note: If you’re importing an intact product and sending a defective product for repair, you must use customs procedure 48. Read more about it on this page.
Customs procedure 46 involves the use of equivalent goods.
- To use equivalent goods, you need a written authorisation from the Customs Authorisation Centre that mentions the use of equivalent goods.
You should also check if you can use equivalent goods in the outward processing. Read more in the guidance on the use of equivalent goods in special procedures (in Finnish)
Example of the use of equivalent goods
A company has an outward processing authorisation that allows the manufacture of T-shirts outside the territory of the EU, in India.
Material that was not at first exported to India under outward processing is used in manufacturing T-shirts. The material used is an Indian-made knitted fabric of 100% cotton with red and white stripes. The height of each colour stripe in the material is 2 cm.
The red-white-striped T-shirts manufactured in India are imported to Finland and released for free circulation under outward processing procedure 4600 999 (IM/EX). After that, Union goods consisting of the same red-white-striped knitted fabric made of 100% cotton, where the height of each knitted colour stripe is 2 cm, are placed under the outward processing procedure (21xx) and exported outside the EU.
In outward processing, equivalent goods are non-Union goods which are processed outside the customs and fiscal territory of the EU instead of Unions goods placed under the outward processing procedure. The use of equivalent goods requires an authorisation granted by the Customs Authorisation Centre. The use of equivalent goods must be indicated in the written authorisation granted by the Authorisation Centre.
You will need an authorisation
To use the procedure, you need a written outward processing authorisation granted by the Customs Authorisation Centre. You cannot apply for authorisation with a customs declaration. You may need an authorisation involving more than one Member State.
The applicant must be established in the customs territory of the EU.
- A legal person is considered established in the customs territory of the EU when it has its registered office, central headquarters or a permanent business establishment in the customs territory of the EU.
- A natural person is considered established in the customs territory of the EU when their habitual residence is within that territory.
In occasional cases where it is deemed justified, the authorisation can also be granted to an applicant established outside the customs territory of the EU. This is possible, for instance, if the authorisation holder is a private individual and the goods are not intended for commercial use.
Written outward processing authorisation (OPO) granted by the Authorisation Centre
Apply for the authorisation from the Customs Authorisation Centre in advance via the Authorisations and Decisions Service (available in Finnish and Swedish). Remember to indicate in the application that you wish to use both prior import and equivalent goods.
Please note: When the intention is to use equivalent goods, a written authorisation must always be applied for in advance from the Authorisation Centre; you cannot apply for authorisation using the customs declaration.
You may need an authorisation involving more than one Member State
If the import and export of the goods takes place in different EU countries, you need an authorisation involving more than one Member State. Submit the application in the EU’s Customs Decisions Service. This type of authorisation cannot be applied for with a customs declaration.
Guarantee
A liability guarantee must always be provided for the procedure. The guarantee remains reserved until the procedure has been discharged correctly and a discharge notification has been submitted to Customs. Read more about the liability guarantee on the page Comprehensive guarantee authorisation.
Records
Records must be kept of the procedure. Read more on the page about outward processing and in the instruction for outward processing on the page Instructions for holders of authorisations.
Submitting the customs declarations
I you’re using a representative:
- The import declarations can be submitted by a direct representative or a direct representative under the responsibility of the guarantor
- The export declarations can be submitted by a direct representative.
You cannot use an indirect representative to submit the customs declarations.
The use of equivalent goods always requires a written authorisation granted by the Authorisation Centre. If you have an authorisation granted by the Authorisation Centre, additional information related to the procedure is generated automatically on the decision according to the authorisation.
In your customs declaration for outward processing starting with import, include the following details:
- The number of the authorisation granted by the Authorisation Centre under “Authorisations”
- procedure
- requested procedure “46 – Import of processed products obtained from equivalent goods under the outward-processing procedure before exportation of goods they are replacing”
- The previous procedure can be one of the following: 51, 53, 54, 71 or 78. If the goods do not have a previous procedure, provide “00 – No previous procedure”.
- additional procedure code “999 – No additional procedure”
- one of the following as the nature of transaction code:
- “51 – Returning goods after processing under contract to the initial Member State/country of export”
- “52 – Returning goods after processing under contract, not to the initial Member State/country of export”
- preference “100 – Erga Omnes third country duty rates”
- value details:
- The customs value of the goods, the statistical value and the taxable amount for VAT are provided in the same way as in the customs procedure 6121.
The procedure is discharged by lodging an export declaration (procedure code 2146 and additional procedure 999). In order for preferential treatment to be applied, the Union goods must be exported within 6 months of the import of the processed products. Read more on the page How to make an export declaration.
The procedure must be discharged within the prescribed time limit, and a discharge notification must be submitted to Customs. Read more on this page under “Discharge of the procedure and notification to Customs”.
Discharge of the procedure
The procedure must be discharged within the prescribed time limit and a discharge notification submitted to Customs. Read more below.
Discharge of the procedure and notification to Customs (48 and 46)
An outward processing procedure that begins with import usually ends with the export of Union goods.
- The procedure must be discharged within the prescribed time limit. The time limit is indicated in the written authorisation granted by the Customs Authorisation Centre or in the import declaration if the outward processing authorisation was applied for with the customs declaration.
- In individual cases, you can request an extension of the time limit for discharging the procedure.
- The company must submit a notification of discharge to Customs in the Customs Clearance Service or through message exchange. Even though the customs declaration discharging the procedure can be an export declaration, the notification of discharge does not refer to a certification of exit of the export declaration. You can submit the notification of discharge in the Customs Clearance Service or as a message.
Outward processing procedure using the standard exchange system (48)
When using the standard exchange system for outward processing, the time limit for discharging the procedure must be the time that the exchange procedure is expected to take at its longest. However, the defective goods must be exported within 2 months from the day when the replacement goods were imported. Only in exceptional circumstances can Customs grant an extension to the 2-month time limit.
Outward processing procedure with prior import (46)
The maximum time limit for discharging the procedure for goods placed under the outward processing procedure IM/EX is 6 months, and it is confirmed in the standard authorisation for the procedure. The procedure is discharged by lodging an export declaration (procedure code 2146). In order for preferential treatment to be applied, the Union goods must be exported within 6 months of the import of the processed products.
You can request an extension of the time limit for the procedure from the supervising customs office (FI00200). You should request an extension before the time limit has run out, as the maximum time limits for the procedure are short.
If you have submitted an electronic customs declaration, request the extension as follows:
- In the Customs Clearance Service, the extension is requested in the “Summary and submission” section of the customs declaration. Click on “Request an extension”, then enter the new time limit and send the request to Customs.
- If you are a message declarant, request an extension of the time limit with the message “Free-form contact” and choose the reason code “003 – Request for time limit extension”.
- If you are unable to request an extension electronically, you can request it using customs form 975e “Extension of procedure time limits”. Send the application to the Electronic Service Centre (valvovatulli@tulli.fi).
If the holder of the authorisation personally requests an extension in the Customs Clearance Service, and the customs declaration was submitted via message exchange by using a direct representative on guarantor’s responsibility, Customs will ask for the representative’s consent.
If you wish to extend the time limit of an authorisation applied for from the Customs Authorisation Centre, submit an amendment application in the Authorisations and Decisions Service.
A notification of the discharge of the procedure must be submitted to Customs no later than on the day following the expiry of the time limit.
If the procedure is not appropriately discharged, the authorisation holder can be deemed to have violated the conditions and obligations for the procedure, and as a result, a customs debt is incurred. Read more about customs debt.
Submit the discharge notification in one of the following ways:
- In the Customs Clearance Service, click on “Contact Customs”. Provide the MRN and click on “Other reason”. As the reason for contact, choose “007 – Bill of discharge / notification of discharge”.
- If you are a message declarant, send a “Free-form contact” message and choose “007 – Bill of discharge / notification of discharge” as the code for the reason for contact.
- Email the information in a separate document to the Electronic Service Centre at valvovatulli@tulli.fi.
The liability guarantee reserved upon import clearance will be released when Customs has processed the notification.