The new Union Customs Code, AEO and Special Procedures for repairing aircraft and aircraft parts

As the transition period of the 'new' Union Customs Code (UCC) now enters its final stage, those traders who have not yet renewed any customs approvals or applied for any they require only have a matter of months to get these in place.

In May 2016 the UCC came into effect with a new set of regulations and a tightened approach to customs approvals (now known as Special Procedures); part of these changes introduced mandatory customs guarantees for duties and taxes. April 2019 will see the end of any old Community Custom Code (CCC) approvals and the UCC will be fully effective.

Additionally, Authorised Economic Operator (AEO) certification was firmly put front and centre. Essentially, if you import or export goods (aircraft parts) for repair or installation to aircraft, AEO is effectively critical to manage the financial impact of the new Special Procedures and smooth the flow of goods and customs procedures.

Martyn Fiddler Aviation has been working with MRO's for a number of years and assisting them with customs matters for aircraft. In the last few months we have additionally been speaking with parts organisations and it has become clear that in the UK there is still a significant lack of appropriate customs approvals (Special Procedures), and indeed an understanding of what should be in place for many traders. HMRC seemed to have been behind the curve with pushing the requirements of the UCC and the advantage of AEO status.

Many traders are now facing an uncertain future in customs compliance with potential impact on their cashflow. Coupled with Brexit uncertainties, traders have been left with difficult decisions on where to focus their resources.

Within the Martyn Fiddler Aviation group, MFIOM holds AEO status and has recently expanded the Inward Processing (IP) Special Procedure which is specifically designed to cover repair and overhaul of parts and aircraft. In the past this has been particularly useful to MRO's as we have been able to extend this cover to facilitate their work on third country aircraft. Now, it could become invaluable to parts companies and traders overhauling aircraft parts.

If the UCC and customs duties, guarantees or compliance has been a problematic topic over the last few months, please do not hesitate in contacting Martyn Fiddler Aviation to discuss the solutions and options we can assist with.