Duty-paid components: inward processing equivalence
Yes, if the duty-paid components are equivalent free circulation goods and HMRC approves equivalence under your full inward processing authorisation. Matching specifications and permission for common stocking need separate attention. Cambridge China Bridge can help gather factory specifications for your comparison.
Check approval before substituting stock
Equivalence lets you use equivalent free circulation components instead of those entered to inward processing. It requires a full authorisation; authorisation by customs declaration does not qualify. Request equivalence in your application, or apply to amend an existing authorisation. Start by checking the approval letter with your customs agent. Our customs procedure codes guide explains the declaration field, rather than permission to substitute stock.
Prove that the components match
The components must share the same first 8 digits of the commodity code, commercial quality and technical characteristics. A matching code alone is insufficient. Prepare a comparison of material grade, dimensions, tolerances, performance and condition, supported by drawings, samples and supplier records. Use finding your commodity code for classification and the computer components guide for practical checks on part revisions and condition.
Agree common stocking separately
Do not assume equivalence approval also permits mixed storage. HMRC allows a separate request for common stocking; without that approval, inward processing goods must occupy a separate physical space. Records must distinguish the quantities under inward processing and in free circulation, drawing down inward processing stock first. Ask your warehouse to demonstrate how receipts, production issues and remaining balances will be recorded before combining bins.
Screen the restrictions
Equivalence is unavailable where goods are subject to anti-dumping duty or would attract excise duty on release to free circulation. It must also be refused where processing is a usual form of handling. It cannot be used simply to offset free circulation exports against imports intended for the UK market. Give your agent the exact components and proposed operation; ask for a written eligibility check before changing production instructions.
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Prepare a substitution file
Keep the approved scope, comparison documents, warehouse instructions and production records together. Agree who checks a changed material grade, drawing revision or supplier before it reaches shared stock. Ask Cambridge China Bridge's staff in China to collect the factory's current specifications and supporting records, then have your customs agent review the proposed substitution. Keep purchasing approval and the customs approval clearly identified in the file.
Frequently asked questions
Can I use duty-paid parts under inward processing?
Yes, where they are equivalent free circulation goods and equivalence is approved under your full inward processing authorisation. Payment of duty alone does not establish a match.
Is the same commodity code enough for equivalence?
No. The first 8 digits must match, but commercial quality and technical characteristics must also be the same. Compare specifications and condition.
Can I mix inward processing and duty-paid stock?
Only with common stocking approval. Otherwise, keep them in separate physical spaces. Records must show both quantities and draw down inward processing stock first.
Can I add equivalence to an existing authorisation?
Apply for an amendment to your authorisation. Ask your agent to check that the approval covers the proposed components before you substitute stock.