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We process a product that is not considered a simple process (we use specialist/expensive equipment and skilled labour to process the product). When the product is imported it is of EU preferential origin and free of any tariff.
After processing we export the product back to the EU and declare the material of EU preferential origin. However, some of our EU customers are being charged duty because the material is not of UK Preferential origin.
When checking the EU/UK trade agreement it indicates that for our products to be of UK preferential origin the product classification (first 4 digits level of the Harmonised System) must change following processing. When we process the product, we are changing it dimensionally, but the product classification remains unchanged.
If the product is of EU preferential origin and we have a free trade agreement why have EU customers been charged duty?
As the only input is EU content, and the process is not simple and goes beyond insufficient processing can the product can be declared as originating in the UK?
Do you have to notify HMRC if you appoint a Direct Representative and if this is a requirement how do you officially notify HMRC?
Can you appoint more than one Direct Representative to make customs declarations/clearance?