How to declare free replacements and promotional goods
Free goods still need a supported customs value. A zero-value invoice shows that no payment is due, but does not establish the value for customs. Explain why the goods are free and ask your agent to select the appropriate valuation method and check any relief separately. Cambridge China Bridge can help gather the factory paperwork.
Separate the amount payable from the customs value
HMRC requires a customs value on the import entry even where no duty or VAT is payable. For genuinely free goods, the transaction value method normally cannot be used because there is no price paid or payable. A zero-value invoice alone therefore does not explain how the goods should be valued.
Ask the supplier to distinguish the amount payable from a supported value for customs purposes. Describe the goods, their quantity and why they are supplied without charge. For the ordinary adjustments, including freight and packing, use our customs value guide.
Ask which valuation method supports the declaration
The valuation methods follow a prescribed sequence. If transaction value cannot be used, consider evidence of identical imports, then similar imports. Later methods use UK selling prices or production costings. The selling-price and production-cost methods may be considered in reverse order; the fall-back method comes after the earlier methods cannot be used.
Give your agent comparable import invoices, product specifications and available factory costings. Ask for a written explanation of the chosen method and any adjustments. Under the fall-back method, HMRC says the price you would have paid the supplier can be a basis, but you must explain why earlier methods cannot be used and support the value with evidence.
Check whether replacements travel with the original order
HMRC distinguishes spare replacements included with the original shipment from replacements sent separately. Where extra goods are included to replace items likely to be defective or damaged in transit, the contracted sale price covers the total quantity shipped. A later free replacement shipment normally cannot use transaction value because no payment is due.
For a separate shipment, give the agent the original invoice, import declaration, defect report and supplier's replacement agreement. Ask whether the contractual arrangements support requesting an amendment to the original shipment's customs value. HMRC permits such a request; that does not establish the value of the replacement shipment or guarantee a refund.
Do not confuse promotional giveaways with sample relief
Calling an item a sample does not establish entitlement to commercial samples relief. HMRC expressly excludes giveaways intended to promote trade from that relief. Proper preparation before import matters for eligible commercial samples. Ask your agent to assess the actual goods and intended use before the supplier packs them.
Keep customs relief separate from product compliance. Ask the relevant product regulator to confirm which obligations apply when giving merchandise away, using our promotional merchandise guide to prepare your questions. For the declaration's customs treatment, see customs procedure codes explained.
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Send a complete file before dispatch
Send the agent the invoice, packing list, reason for the free supply, valuation evidence and freight details together. Ask them to confirm the valuation method, declared value and any relief being claimed before dispatch. Check that free items have not disappeared from the paperwork merely because the supplier is not collecting payment.
Keep the supplier's explanation and the valuation workings with the final declaration. Cambridge China Bridge's staff in China can help request factory documents and reconcile descriptions and quantities, giving your customs agent a clearer basis for preparing the entry.
Frequently asked questions
Can I declare free goods at zero value?
No payment does not establish a zero customs value. Free goods normally need another valuation method, supported by evidence. Ask your agent to explain the basis before shipment.
How do I value free warranty replacements?
Distinguish replacements included with the original order from a separate shipment. Separate free replacements normally cannot use transaction value. Provide the original invoice and replacement agreement.
Are promotional giveaways covered by sample relief?
HMRC excludes giveaways intended to promote trade from commercial samples relief. Do not assume that writing “sample” on the invoice makes the goods eligible.
What documents should I give my customs agent?
Provide the invoice, packing list, reason for free supply, comparable import invoices or other valuation evidence, and freight details. For replacements, add the original order and defect correspondence.