HMRC has updated its guidance on the Duty Reimbursement Scheme for businesses that moved “at risk” goods into Northern Ireland and paid, deferred or used state aid to waive EU import duty.
For many small firms this will not be a daily admin issue. But for importers, wholesalers, retailers, agents and ecommerce businesses with Northern Ireland movements in their records, the update is worth checking now because one deadline is close. HMRC says claims for duty paid between 1 January 2021 and 30 June 2023 must be made by 30 June 2026.
The scheme can apply where goods brought into Northern Ireland later meet conditions that mean the EU duty should be repaid or remitted. That can include goods sold for physical retail in Northern Ireland, moved onwards to Great Britain, exported outside the UK and EU, consumed in Northern Ireland, permanently installed there, or destroyed there.
The practical point for SMEs is simple: if the business has older Northern Ireland import movements, now is the time to check whether there is a recoverable duty cost sitting in the files.
Who the scheme may affect
HMRC says a claim can be made by the importer for the original “at risk” movement into Northern Ireland, or by an agent or representative acting for that importer. If a business is not resident or established in the UK, it must use a UK-established agent or representative to submit the claim.
That matters for small firms because Northern Ireland trade can involve several parties: suppliers, freight agents, customs intermediaries, distributors and end customers. Before spending time on a claim, the business should confirm who paid, deferred or waived the duty, who holds the evidence, and who is authorised to act.
The amounts may be modest on a single consignment but meaningful across repeated shipments. A shop, parts supplier, online seller or trade wholesaler may have multiple movements from the period covered by the deadline.
What can be claimed
The guidance says businesses may be able to claim repayment of import duty paid, claim remission of import duty deferred, or reclaim state aid used to waive duty through the Customs Duty Waiver Scheme.
For goods moved from Great Britain to Northern Ireland, HMRC says businesses can claim for the full amount where the conditions are met. For imports into Northern Ireland from outside the UK or EU, a claim may cover the difference if the EU duty was higher than the UK duty at the time of import.
Businesses do not necessarily need every item in a consignment to qualify. HMRC gives the example of a consignment where only some goods meet the conditions, with a claim then made for the relevant portion of duty. That could be useful for small firms whose goods were split between different destinations or uses.
Evidence is the key admin task
The scheme is evidence-led. HMRC says claims will be rejected if the business does not provide enough evidence to show the conditions are met. The examples include sales invoices, receipts, contracts, inventory records, VAT records, customer orders, delivery confirmation, transport documents, packing lists, manifests, bills of lading and export declarations.
For SMEs, this is where the deadline can become operationally awkward. The older period reaches back to 2021, so relevant paperwork may be in archived email accounts, freight portals, accounting systems or customs agent records. Businesses should avoid leaving the evidence search until the final week.
It is also sensible to keep the claim work separate from wider tax and accounting routines. BritishSME has previously covered how small firms should prepare for Making Tax Digital for Income Tax, and the same basic lesson applies here: clean records make compliance tasks less painful when deadlines arrive.
What small firms should do now
First, identify whether the business moved any “at risk” goods into Northern Ireland from 1 January 2021 onwards. Then split the review into older claims, where the 30 June 2026 deadline may apply, and later claims, where HMRC says the deadline is normally within three years of notification of the duty.
Second, check whether goods stayed in Northern Ireland, moved to Great Britain, were exported outside the UK and EU, were sold for retail, were finally consumed, were installed permanently, or were destroyed. Those facts shape the evidence needed.
Third, contact customs agents, freight providers or internal finance staff early if they hold documents. If an agent is submitting the claim, make sure the authorisation position is clear.
This is not a reason for every small business to open a customs project. But for firms with Northern Ireland movements, it is a useful prompt to look for possible recoveries before an old-period deadline passes.
