UK SPS: Common User Charge Guidance

Aug 22, 20249 min read

Learn how to avoid unnecessary charges by understanding DEFRA’s invoicing for plants and plant products, along with critical billing details and contact points for queries.

What Questions We Will Answer in this blog

Where can I learn more about the Common User Charge (CUC) and watch the webinar that DEFRA recorded recently?
How are low and medium-risk plants and plant products (P&PP) handled in the Import of Products, Animals, Food, and Feed System (IPAFFS)?
What are the billing requirements for agents raising import notifications?
How can you resolve issues with incorrect billing details or invoice queries?
When am I required to pay the common user charge?
How Can You Resolve Issues with Incorrect Billing Details or Invoice Queries?
What to do if I am handling POAO or HRFNAO products and submitting notifications for multiple clients?
How to proceed if I am If you’re an agent submitting P&PP products under Delegation of Authority (DoA) ?
Who to contact with invoice queries?

Introduction

Navigating DEFRA's Common User Charge (CUC) invoicing can be complex, especially when dealing with plants, plant products, and billing details for import notifications. Clarity and precision are essential to avoid unnecessary charges and ensure compliance.

"To avoid unnecessary charges and ensure compliance, focus on understanding the specific requirements for import notifications and the associated invoicing process."— Arne Mielken, Managing Director, Customs Manager Ltd.

Abbreviations We Use in this Blog

To help with understanding, we'll define key abbreviations used in this blog:

DEFRA: Department for Environment, Food & Rural Affairs – responsible for environmental protection, food production and standards, agriculture, fisheries, and rural communities in the UK.
CUC: Common User Charge – a fee applied to import notifications for certain goods.
IPAFFS: Import of Products, Animals, Food, and Feed System – the UK's notification system for importing certain goods.
P&PP: Plants and Plant Products – refers to the categories of goods being imported.
CHED PP: Common Health Entry Document for Plants, Plant Products, and other Objects – a document required for certain imports under the IPAFFS system.
DoA: Delegation of Authority – when an agent is authorised to act on behalf of an importer for notification purposes.

Where can I learn more about the Common User Charge (CUC) and watch the webinar that DEFRA recorded recently?

We are pleased to share the DEFRA Common User Charge (CUC) Invoicing some more details, including updated FAQs and a recording of the webinar that can be found here.

The same slides can be downloaded here for ease of reference, too, if helpful.

How Are Low and Medium-Risk Plants and Plant Products Handled in IPAFFS?

Understanding the risk categorization for plants and plant products is crucial to avoid unnecessary charges. DEFRA has established specific rules regarding the import of low-risk, medium-risk, and high-risk goods, which determine whether a notification is required in the IPAFFS system and whether you will incur a Common User Charge.

Low risk P&PP goods and medium risk B P&PP goods must not be notified in IPAFFS. Full guidance is available on gov.uk on both the common user charge page and the BTOM risk categorisations page. T

Key Points to Consider:

Low-Risk Goods: No notification or phytosanitary certificate required. If you mistakenly notify these goods in IPAFFS, you'll incur a £29 CUC per commodity line.
Medium-Risk A Goods: Require both a phytosanitary certificate and pre-notification (CHED PP).
Medium-Risk B Goods: Require a phytosanitary certificate but do not need pre-notification. However, any notification in IPAFFS will incur the CUC.
High-Risk Goods: Require both a phytosanitary certificate and pre-notification in IPAFFS.

There is a temporary easement in place for some fruit and vegetables from the European Union, Liechenstein and Switzerland. These are medium risk but are currently being treated as low risk and therefore do not require notifying on IPAFFS. The BTOM risk categorisations page provides an overview of the risk categorization for the different commodity types.

What Are the Billing Requirements for Agents Raising Import Notifications?

Agents raising import notifications must understand the billing implications to avoid being charged incorrectly. The responsibility for the Common User Charge depends on whether you're operating under your own IPAFFS account or under Delegation of Authority.

Key Billing Scenarios:

Own Account Use: If you raise notifications using your IPAFFS account, you must provide your billing details, and you are responsible for paying the charge.
Delegation of Authority (DoA): If you act under DoA using your client's IPAFFS account, you must provide the client’s billing details. Failure to do so could result in you being charged for all notifications raised under that account, even those by other agents.

To amend incorrect billing details, update the information in IPAFFS for live notifications or on the next notification you create.

When am I required to pay the common user charge?

If you're submitting your own import notifications on IPAFFS, you're responsible for paying the common user charge. Make sure to use your own billing information in the notification.

How Can You Resolve Issues with Incorrect Billing Details or Invoice Queries?

The billing details provided in the IPAFFS notification must be those of the organisation whose IPAFFS account was used to create the notification. Full guidance is available on gov.uk on the common user charge page. Mistakes in billing details or invoice queries can be resolved by following the correct steps and contacting the right support services. Overall, if you’ve entered incorrect billing details, you can easily fix this in IPAFFS. Just update the billing information on a live notification (one that hasn't yet entered the country) or on the next one you create. If you want an existing invoice to reflect the updated billing details, contact SSCL to request this change.

What to do if I am handling POAO or HRFNAO products and submitting notifications for multiple clients?

For agents handling POAO or HRFNAO products and submitting notifications for multiple clients, you must cover the common user charge for all these clients and use your own billing details. If you use a client’s billing information, they might be charged for notifications belonging to other clients as well.

How to proceed if I am If you’re an agent submitting P&PP products under Delegation of Authority (DoA) ?

If you’re an agent submitting P&PP products under Delegation of Authority (DoA) using your client’s IPAFFS account, you need to use the client’s billing details, as they are responsible for the charge. If you mistakenly use your own billing information, you could end up being charged for all notifications on that client’s account, even those submitted by other agents.

Who to contact with invoice queries?

SSCL are your first point of contact for any invoice related queries, issues or payments. You can contact SSCL by phone (01633 631800) or email (SSCL.invoicing@gov.sscl.com). In every contact with SSCL you must quote the organisation name, customer number and invoice number for the relevant invoice you wish to discuss. Only the organisation named on the invoice can discuss or query an invoice or seek support, but any organisation can pay the invoice if they have the organisation name, customer number and invoice number.

SSCL can also send invoice data in an excel spreadsheet upon request.

Expert Recommendation

Understand Risk Categories: Familiarize yourself with DEFRA's risk categorization for P&PP to avoid unnecessary notifications and charges.
Accurate Billing Information: Ensure the correct billing details are used in every IPAFFS notification to avoid cross-charges.
Contact SSCL for Invoice Issues: Don’t hesitate to reach out to SSCL for assistance with any invoicing problems.

How We Can Help

🌟 Customs Manager Ltd offers comprehensive support for managing import-export operations, including bespoke consultancy and practical assistance with DEFRA’s Common User Charge. We provide public, in-house, and on-demand training tailored for customs professionals, importers, exporters, and their partners. Our membership services include weekly customs trade intelligence and updates, along with UK import and export customs clearance services. Visit www.customsmanager.org for more details.

Sources That We Base Our Information in This Blog On

The content of this blog is derived from the most recent advice provided by DEFRA and HMRC authorities via the JCCC on 22 August 2024. We are sharing this information with our membership networks as authorised by the JCCC Secretariat.

Where To Find More Information On Topic

To dive deeper into import methods and related legal frameworks:

Subscribe to The Customs Watch – our weekly consolidation of updates to law, guidance, and policy.
Visit our Knowledge Hub Content Library at www.customsmanager.info for more detailed information on imports and related topics.

Additional Information on SPS and the UK Veterinary Border from our Knowledge Hub Content Library

If you're new here and find value in our information, get started with a free Standard Membership to our Trade Intelligence service to receive updates directly to your inbox. We keep you informed about customs, export control, and sanctions changes based on your preferences. To get started, leave your e-mail address at www.customsmanager.info.

Training

We offer extensive training on SPS, Veterinary Matters, the Common User Charges and Import Notifications. Visit www.customsmanager.org/events to explore our course plan and book a public course.

About the Author

Arne Mielken is a custom, export control, and sanctions expert with over 20 years of experience. You can find out more about Arne here and connect with him on LinkedIn here.

Disclaimer

The information provided in this blog post is for educational purposes only and should not be construed as legal advice. Consulting with legal professionals or specialists for specific compliance requirements and guidance is recommended. Book a free call with our expert at Customs Manager Ltd.

#training #education #clearance #consultancy #advice #support #customs #import #export #IPAFFS #sanctions #CommonUserCharge #DEFRA #plants #plantproducts #compliance #notifications #exportcontrol #customsagent #traders #invoicing

DEFRA colleagues have also included some clarifications below on key topics raised during the webinar, as documented below – we hope this is useful for you in supporting your members further.

Important clarifications:

Billing details including advice for agents:

The billing details provided in the IPAFFS notification must be those of the organisation whose IPAFFS account was used to create the notification. Full guidance is available on gov.uk on the common user charge page. Traders must note:

If you raise your own import notifications on IPAFFS, you are responsible for paying the common user charge. You must provide your own billing details in the notification.
If you are an agent raising POAO or HRFNAO products and you raise import notifications on IPAFFS for more than one importer/customer, you must pay the common user charge for all these importers and use your own billing details for the notifications. If you use an importer’s/customer’s billing details, they could be invoiced for all the notifications you raise, including those for other importers/customers.
If you are an agent raising P&PP products you will be operating under Delegation of Authority (DoA) for your customer and raising notifications using their IPAFFS account. In this instance you must provide the customer’s billing details as they are responsible for the charge i.e., the billing details for the organisation whose IPAFFS account you are using to create the import notification. If an agent working under DoA provides their own billing details, they could be charged for all notifications raised on the customer’s IPAFFS account. This includes notifications raised by other agents operating under DoA for that customer.
If you have used incorrect billing details on your notifications this can easily be amended in IPAFFS by either updating the billing details on an existing live notification (i.e., one which has not already entered the country) or updating the details on the next notification (if there are no existing notifications). This will update the customer record for future notifications. If you want an existing invoice to be sent to the updated billing details, then you must contact SSCL to request this.

Who to contact with invoice queries