Importing Robots from China into Great Britain: Customs, VAT and Product Marking

1. Register for customs and choose who declares

To import goods into Great Britain, you need an EORI number that starts with GB. If you move goods to or from Northern Ireland, you may also need one that starts with XI. GOV.UK: Get an EORI number

You can make customs declarations and arrange transport yourself, or hire someone, such as a customs agent or a freight forwarder with a customs service, to deal with both for you. GOV.UK: Import goods into the UK, step 3

What an agent can do for you, and who is liable for the declaration, depends on the services they provide, what you ask them to do and your commercial agreement with them. Settle direct or indirect representation in writing before the first shipment. HMRC: Appoint someone to deal with customs on your behalf

2. Find the UK commodity code

Your import declaration needs a commodity code. The code sets the rate of Customs Duty you pay and shows whether you need an import licence. GOV.UK: Import goods into the UK, step 4

Only the first six digits of a commodity code are used worldwide. Each country makes its own product-specific decisions. Treat the HS code on a Chinese export invoice as a starting point, not as the UK code. HMRC: Finding commodity codes for imports or exports

Search the UK Trade Tariff using the product's function and materials and the way it is presented for import. If the classification is uncertain, you can apply to HMRC for an Advance Tariff Ruling: a legally binding decision on the commodity code for goods imported into Great Britain. GOV.UK: Trade Tariff, HMRC: Apply for an Advance Tariff Ruling

The details below help your agent or HMRC classify robot equipment. The same robot can be presented in different ways: as a complete unit, as an arm without a controller or as separate modules. State exactly what is in each shipment. HMRC: Finding commodity codes for imports or exports

3. Work out the customs value, duty and import VAT

Customs Duty and import VAT are calculated from the customs value. HMRC publishes guidance on the six valuation methods and on which delivery costs to include. Agree the Incoterm with your supplier and keep the freight and insurance invoices with the commercial invoice. HMRC: Working out the customs value of your imported goods

You may pay less or no Customs Duty if the UK has a trade agreement with the country you import from. A preferential rate applies only when the goods meet the rules of origin for that agreement, and the Trade Tariff shows the rule and the proof required. GOV.UK: Pay less Customs Duty on goods from a country with a UK trade agreement

Import VAT is normally charged at the same rate as if the goods were supplied in the UK. VAT-registered businesses can use postponed VAT accounting to declare import VAT and reclaim it as input tax on the same VAT Return. Alternatively, they can pay it at importation. HMRC: Paying VAT on imports

4. Check product marking and conformity documents

UKCA and CE markings show that the manufacturer considers the product meets the relevant requirements. For England, Scotland and Wales, government guidance explains when either marking can be used. It also lists the product types each regime covers in a product marking table. DBT: Placing UKCA or CE marked products on the market in Great Britain

The regulations below often come up when robots and robot components are placed on the GB market. Which of them apply depends on the product, its power supply and its radio functions. The manufacturer's declaration of conformity should name each piece of legislation it covers. DBT: Placing UKCA or CE marked products on the market in Great Britain

Manufacturers and importers must indicate their name, registered trade name or trade mark, and postal address on the product. In some cases, the importer's details can be given elsewhere instead of on the product itself. Agree with your supplier where your details will appear before production starts. DBT: Placing UKCA or CE marked products on the market in Great Britain

Ask the manufacturer for the declaration of conformity that names the exact model and configuration you are buying. Also ask what the technical documentation contains: test reports, design documents and risk assessments are normally part of it. DBT: Placing UKCA or CE marked products on the market in Great Britain

5. Ship lithium batteries as dangerous goods

Legged robots, humanoids and most mobile robots carry lithium battery packs. Whether a lithium battery can travel by air depends on its configuration and its watt-hour rating, and shippers must declare dangerous goods correctly. Give your forwarder the pack's specifications before booking. IATA: Lithium batteries

6. Clear the goods and reclaim VAT

After the earlier steps, you or your agent make the import declaration and get the goods cleared by UK customs. VAT-registered businesses can then claim back VAT paid on imported goods, subject to the normal VAT rules. GOV.UK: Import goods into the UK, steps 8 and 9

Before you ship

1. Agree the commodity code and the customs value with your customs agent before you place the order, especially when a robot ships with its controller, charger and spare batteries.
2. Request the declaration of conformity, a list of test reports and the battery shipping documents with the quotation, not after dispatch.
3. Confirm the Incoterm, who acts as importer and whose EORI number goes on the declaration.
4. Check that chargers and control boxes come with UK plugs or suitable adapters and accept UK mains voltage.
5. Keep the supplier's commercial invoice, packing list, transport document and conformity documents together for each shipment.

This guide summarises official guidance as of the date shown. It does not decide how the rules apply to a particular product. Your customs agent and, where needed, a product compliance specialist should confirm that before you order.

Sources

• GOV.UK: Import goods into the UK, step by step
• GOV.UK: Get an EORI number
• HMRC: Appoint someone to deal with customs on your behalf
• HMRC: Finding commodity codes for imports or exports
• GOV.UK: Trade Tariff
• HMRC: Apply for an Advance Tariff Ruling
• HMRC: Working out the customs value of your imported goods
• GOV.UK: Pay less Customs Duty on goods from a country with a UK trade agreement
• HMRC: Paying VAT on imports
• DBT: Placing UKCA or CE marked products on the market in Great Britain
• Supply of Machinery (Safety) Regulations 2008
• Electrical Equipment (Safety) Regulations 2016
• Electromagnetic Compatibility Regulations 2016
• Radio Equipment Regulations 2017
• IATA: Lithium batteries