FotoImpex/Adox and UK since Brexit

David Allen · Mar 21, 2021

Dear All,

a recent thread on the UK Analogue Website has highlighted one of the impacts for photographers living in the UK as a direct result of Brexit.

You can read the thread here: http://www.film-and-darkroom-user.org.uk/forum/showthread.php?p=139278#post139278

You will note that there is a slight implication (by a single poster) that EU suppliers could be profiteering from Brexit but I believe that the suppliers are just being honest and doing their very best in a new economic landscape.

Has anyone else had a 'surprise' recently regarding UK/EU purchases?

Bests,

David.

Craig75 · Mar 21, 2021

Im confused. Why cant small eu businesses just stick a customs label on it and i pay import duties + handling at my end via the courier like we do with every other country?

perkeleellinen · Mar 22, 2021

I have had two eBay purchases declined (one from Germany, one Netherlands) because the customs paperwork is not worth the hassle. On both auctions the sellers said they would ship to 'Europe' but actually they mean EU/EFTA

Anon Ymous · Mar 22, 2021

Craig75 said:
Im confused. Why cant small eu businesses just stick a customs label on it and i pay import duties + handling at my end via the courier like we do with every other country?

The bizarre part is that the UK requires the sender to collect taxes on their behalf as has been mentioned here before and in the thread mentioned by the OP. It's not just a bit more paperwork, like a CN22 form. People were reluctant to export outside the EU, it just got even worse, more of a mess I guess.

@perkeleellinen I wish eBay had an EU filter option to narrow down the search results. I used to buy from the UK, cameras, lenses, whatever, but not any more.

R.Gould · Mar 22, 2021

The whole thing is a mess, and often good that come with big bills to be paid to the coutiwer are being refused and sent back where they came from, A very good friend of mine bought a coat from Paris, cost £100 including the British rate of vat, which was collected by the retailer, when the coat finally arrived 2 months later he was presented with a bill from the courier for £95, which had to be paid to the courier before delivery, meaning that the £100 coat was costing him £195, he refused and the coat was returned, and because returns would be costing the firm so much it is being stored in the uk and will be destroyed, which is cheaper than returning to Paris, anything below £135 the retailer, not just in the EU, but anywere in the world, the retailer must now,since Brexit, must register with the UK for VAT, whic is expensive, and collect the VAT and send it to the UK tax man, UK is the only country in the world doing this, so many retailers, not only Photographic have now closed the door to online ordrs to anybody in the UK, untill this mess is sorted out, and it seems to me it is going to get worse with this ''Vaccine'' war with the UK

ADOX Fotoimpex · Mar 22, 2021

Since we were mentioned I just wanted to add for clarification that we DO SHIP TO THE UK at the moment and CONTINUE TO DO SO.
All we need to avoid is this 135UKP rule so your order has to be >170 EUR. Before apuggers start driving to Calais or even swimming the channel, why don´t you team up and make collective orders?
Since we do not charge you VAT additional costs in total are not prohibitive if you exceed the threshold of 170 EUR all is fine!

David Allen · Mar 22, 2021

Thanks for the explanation Adox / Fotoimpex. I have posted it on the UK website.

I have also suggested to the UK analogue photography site that they should join together to make orders.

The one thing that people are asking on that site is what is now classified as 'Dangerous goods'.

Perhaps Mirko or one of the team could provide a few examples so that the UK-based photographers have a better idea of what continues to be available for shipping and what can no longer be shipped to the UK.

Bests,

David

Temporary website address: http://dsallen.carpentier-galerie.de

foc · Mar 22, 2021

R.Gould said:
the retailer must now,since Brexit, must register with the UK for VAT, whic is expensive, and collect the VAT and send it to the UK tax man, UK is the only country in the world doing this,

Thankfully I am retired but my son has a small website and before 1st Jan 2021 he supplied goods from the Republic of Ireland to Great Britain (our neighbour) and world wide.

Since Brexit, he decided to stop supplying GB because he would be required to register for VAT with HMRC, charge UK vat and submit it to HMRC even though he in a different jurisdiction. He weighed up the costs, time and money, and decided it wasn't worth the effort.

Hopefully, this may change from the HMRC side but I wouldn't hold my breath.
Also some of his products came from or through GB and because they are now outside the EU, there were weeks of delays receiving deliveries because the paperwork was incorrectly filled in and Irish Customs wouldn't allow it in. So what used to take 3 days is now taking 10-16 days.

pentaxuser · Mar 22, 2021

Since we do not charge you VAT additional costs in total are not prohibitive if you exceed the threshold of 170 EUR all is fine!

he supplied goods from the Republic of Ireland to Great Britain (our neighbour) and world wide.

Since Brexit, he decided to stop supplying GB because he would be required to register for VAT with HMRC, charge UK vat and submit it to HMRC even though he in a different jurisdiction.

The first line is from Mirko's post and the rest of from foc's post. There would appear to be a contradiction given that both the Republic of Ireland and Germany are both EU members

Can someone reconcile this difference?

Thanks

pentaxuser

R.Gould · Mar 22, 2021

the UK vat is chargeable on all exports to the value of £135, above £135 no need to bother to register with HMRC as you will not have to charge VAT,, the vat will be collected upon arrival in the UK, plus any other customs charges, duty Ect plus an extra for the courier to pay for the paper work that they have to do for collecting the tax and passing it on to the HMRC, which can sometimes amount to nearly the cost of the goods in the first place, in the pre brexit VAT was collected by the seller, at the rate of the country, IE 19% in Germany which ws paid to the German tax people,, to any other country outside the EU vat is rated at 0 so no vat is p0aid, to countrys inside yhe EU vat is cololected at the rate of the exporting country, paid to the counrtry's tax people, GB is the only country that demands the exporting company becomes a tax collector for them, hence the problems with online shopping from every where also, things take a very long time to get here, as a for instance, my Classic mercedes need a part ghat has to come from Germany, oit is readily avainable, should get to anywhere in th eEU within 2 or 3 days, it is ordered and on it's way, bu tI have been wating for a £50 specia;l relay since the 17th of Febuary, and no sign of it, I ordered 2, from the 2 Mercedes parts garages in Jersey, I was told today that it is on it's way, but could take 6 month's to get here due to complications due to Brexit, Brexit seems to me to be an unholy mess, and I am in Jersey, we were not in the EU, but had a special arrangement with them, which was lost when GB left as for the Future, heaven help us, time to re join them leaving was the worst mistake ever made

Richard

foc · Mar 22, 2021

pentaxuser said:
Since we do not charge you VAT additional costs in total are not prohibitive if you exceed the threshold of 170 EUR all is fine!

he supplied goods from the Republic of Ireland to Great Britain (our neighbour) and world wide.

Since Brexit, he decided to stop supplying GB because he would be required to register for VAT with HMRC, charge UK vat and submit it to HMRC even though he in a different jurisdiction.

The first line is from Mirko's post and the rest of from foc's post. There would appear to be a contradiction given that both the Republic of Ireland and Germany are both EU members

Can someone reconcile this difference?

Thanks

pentaxuser

Since my son's website supplies low-cost items, they would be under the £135 or €170 threshold and so according to HMRC he, the seller, would be obliged to include in his sale UK Vat @20% and remit it to HMRC.
For sales under £135/€170 the seller must charge UK Vat @20%.
For sales over £135/€170 the seller doesn't have to charge UK Vat @ 20% but the buyer will pay the Vat upon entry into GB and maybe custom duties.

Here is, what I think, an easy version of the Vat details and Brexit.
https://www.shopify.ie/blog/brexit-impact-ecommerce

mshchem · Mar 22, 2021

For decades in the US, for out of state, mail orders, or internet purchases, were exempt from state sales taxes. There's no Federal VAT. Now out of state sellers are required to collect state sales taxes. There's 50 states, each with it's own tax scheme.

ADOX Fotoimpex · Mar 22, 2021

David Allen said:
Thanks for the explanation Adox / Fotoimpex. I have posted it on the UK website.

I have also suggested to the UK analogue photography site that they should join together to make orders.

The one thing that people are asking on that site is what is now classified as 'Dangerous goods'.

Perhaps Mirko or one of the team could provide a few examples so that the UK-based photographers have a better idea of what continues to be available for shipping and what can no longer be shipped to the UK.

Bests,

David

Temporary website address: http://dsallen.carpentier-galerie.de

Our webshop specifies this. It will not let you check out as well and mark those items. In short: Nothing dangerous may be included in a postal parcel. So anything having a classification in Section 9 of an MSDS cannot go. We try since years to only formulate chems which comply and most of our recent developers and other chemicals can still be ordered. Having it world parcel compatible was the biggest challenge in the new ADOX Scala Kit for example. Legacy formulations such as Rodinal unfortunately do not comply.

ADOX Fotoimpex · Mar 22, 2021

R.Gould said:
the UK vat is chargeable on all exports to the value of £135, above £135 no need to bother to register with HMRC as you will not have to charge VAT,, the vat will be collected upon arrival in the UK, plus any other customs charges, duty Ect plus an extra for the courier to pay for the paper work that they have to do for collecting the tax and passing it on to the HMRC, which can sometimes amount to nearly the cost of the goods in the first place, in the pre brexit VAT was collected by the seller, at the rate of the country, IE 19% in Germany which ws paid to the German tax people,, to any other country outside the EU vat is rated at 0 so no vat is p0aid, to countrys inside yhe EU vat is cololected at the rate of the exporting country, paid to the counrtry's tax people, GB is the only country that demands the exporting company becomes a tax collector for them, hence the problems with online shopping from every where also, things take a very long time to get here, as a for instance, my Classic mercedes need a part ghat has to come from Germany, oit is readily avainable, should get to anywhere in th eEU within 2 or 3 days, it is ordered and on it's way, bu tI have been wating for a £50 specia;l relay since the 17th of Febuary, and no sign of it, I ordered 2, from the 2 Mercedes parts garages in Jersey, I was told today that it is on it's way, but could take 6 month's to get here due to complications due to Brexit, Brexit seems to me to be an unholy mess, and I am in Jersey, we were not in the EU, but had a special arrangement with them, which was lost when GB left as for the Future, heaven help us, time to re join them leaving was the worst mistake ever made

Richard

This is comprehensive. Even if I might repeat myself just to make sure for our services:

- You are not charged German VAT. Only british VAT is colected upon arrival
- You should not be charged additional services except VAT and if aplicable customs because we use (for this reason) world postal service
- You may have to drive to the post office to make this declaration and pay on location though

We are looking into courier options but they will involve a paperwork fee on top of taxes collected.

R.Gould · Mar 22, 2021

In Jersey things are different, in that as we were outside the EU for VAT purposes we have never been charged VAT from The UK or anywhere else, I was trying put before the Brexit and since, for instance a good friend of mine in the UK ordered a coat from Paris, paid £100 for it, including UK Vat, when it arrivied, a month later, he was handed a further bill from the carrier for £95, I don't know what for, he refused to pay and got a refund from the seller, but to return the item would have been so complicated that they simply left it in the carriers warehouse, it was cheaper to burn it than return it, In theory we in Jersey, which is not part of UK, could order from you in smaller amounts as you would NOT have to add VAT, just send it direct to Jersey and we pay any tax when the parcel gets here, and if the order was less than 135, including carriage, we would not pay any tax, but the UK situation is crazy, and unless it changes on line shopping for them from outside the UK is going to be difficult, but for Jersey channel islands we are not, or should not be , affected as we are a seperate countrry, for tghe UK the point is that before Brexit goods were sent, I believe, with the country's of origin's VAT but no vat in the country of recipt, where now, since the UK left the EU foods are now sent , at least over £135, with vat 0 rated, and goods sent from the UK to the EU are still 0 rated, it is the paper work complication's that cause the delays, which is getting stupid from either side. goods to us in the Channel Islands were always 0 rated, or should be, from both UK and EU
Richard

pentaxuser · Mar 22, 2021

So in summary the order has to be £135 GBP to ensure the EU seller( in this case Adox) does not have to charge VAT on behalf of HRMC and send that VAT to HRMC. As the U.K. has a tariff free agreement with the EU then other than VAT and making a declaration at the U.K. post office plus of course the normal postal delivery charges which presumably remain the same as they would have been if the U.K. was still in the E.U. there will be no other charges that anyone can think of?

The person making the order to Adox is the one who is required to pay the U.K. VAT at the post office which he presumably nominates to ADOX and there he makes the declaration.

What declaration is he actually making? I ask this because presumably Adox includes a list of the goods and their value so the post office knows what to charge the person ordering the goods so other than paying the VAT on the order what is the person who ordered the goods declaring? Maybe that he is confirming that what is on the list is indeed what he ordered so were the U.K. Post Office to open and check the parcel and find there were other goods in the parcel then an investigation ensues to determine if the buyer and seller are involved in a conspiracy to defraud the HRMC of revenue?

Assuming that person has now paid the VAT and made whatever is required and has got the goods then he has the added effort of billing each of his syndicate for each member's goods and share of the postal charges plus that person's bill for the additional postal charges within the U.K. and has to repackage each person's goods

I have laboriously attempted to specify each step so we can all see exactly what is involved and the cost in time and effort. I fear that unless Mirko is selling something relatively unique to Adox which enough people want to buy and cannot get via a U.K. retailer who stocks Adox products then the time and effort involved will mean that in most cases it will not be worth that time and effort.

Unless the U.K. and EU find a way that allows E.U. to U.K. sales in both directions to be as frictionless as was intended by the Brexit agreement( assuming of course that both sides really want this and this looks to be in doubt as things stand now) then all that happens is that Adox and other E.U. small sellers lose business that pre January 2022 was open to them.

Effectively most seller and buyers in the face of what is required just give up on transactions that pre-Brexit were as easy as ordering from a U.K. retailer

pentaxuser

Arcadia4 · Mar 22, 2021

Its worth noting whilst alot of this is due to Brexit, in particular the need to register with hmrc for goods under £135 which applies globally, plus the faff of customs paperwork and handling charges, Some of this is in advance of changes occurring in the eu in july
- Low value consignment relief where goods under £15 or €22 were exempt from Vat was abolished with Brexit in jan, but also comes into force in the EU from July
- The rules over VAT on goods under €150 also change with VAT now applicable based on the buyers country not the seller. However in the eu the seller can also register for vat in a single country.
- marketplaces such as ebay are expected to be responsible for collecting VAT. This has already come into effect with brexit.

Its actually the latter with brexit where the biggest change has occurred. HMRC advise is that vat is not applicable on private sales. However buy goods from ebay from private sellers in the eu (not uk) and you now get charged 20% vat as well, same as for shops on the basis that eBay is the shop.

Arcadia4 · Mar 22, 2021

@pentaxuser

1) Goods under £135. Seller has to be registered with HMRC.
Seller collects VAT and remits HMRC. Buyer has nothing to pay.
Seller has to complete customs declaration.

2) Goods over £135. Seller also has to complete customs declaration. On arrival uk, the courier or royal mail then add;
handling fee and VAT. You pay the courier or RM. Note RM charge a flat £8 handling fee whereas some couriers charge a percentage which can be alot more.

Also the £135 is ex delivery. vat is charged on the total.

Thus main difference in (2) is adox avoids registering with hmrc and having to deal with vat payments.

Ive ignored duty, but note with the exception of excise duty on alcohol this only kicks in over £135.
Excise duty is applied to the total value from 0 up of the consignment including delivery.

beemermark · Mar 22, 2021

mshchem said:
For decades in the US, for out of state, mail orders, or internet purchases, were exempt from state sales taxes. There's no Federal VAT. Now out of state sellers are required to collect state sales taxes. There's 50 states, each with it's own tax scheme.

Not just sellers, but "market facilitators" i.e. auction sites like eBay. A facilitator being any entity that arranges a transaction between two non-business individuals. Sooner or later they will get around to sites like Craiglist. Let me count thew ways I can tax you says your representative.

davela · Mar 22, 2021

beemermark said:
Not just sellers, but "market facilitators" i.e. auction sites like eBay. A facilitator being any entity that arranges a transaction between two non-business individuals. Sooner or later they will get around to sites like Craiglist. Let me count thew ways I can tax you says your representative.

They now collect these sales taxes on eBay, Amazon, and form all other large internet resellers in the USA now. The idea behind it was that even though most of these sellers do not have a physical presence in most states they sell to, it was supposed to "level the playing field" with brick and mortar stores in the name of fairness. It was also sold as being able to provide new funds for cities and states to mitigate the dire financial shortfalls of many of them. I don't know about playing field leveling, but large numbers of cities and states are still broke despite the greatly increased new revenue!

mshchem · Mar 22, 2021

beemermark said:
Not just sellers, but "market facilitators" i.e. auction sites like eBay. A facilitator being any entity that arranges a transaction between two non-business individuals. Sooner or later they will get around to sites like Craiglist. Let me count thew ways I can tax you says your representative.

Yes, good point, if I buy something from a seller in Japan, Ebay collects our state sales tax. On used items one wonders how many times a sales tax has been collected?
A 50 year old Leica has, nominally, more in sales tax collected by Ebay than what the camera sold for new.

MattKing · Mar 22, 2021

mshchem said:
A 50 year old Leica has, nominally, more in sales tax collected by Ebay than what the camera sold for new.

It isn't the item that is taxed, it is the sales transaction.
And if the taxation system is in the nature of a Value Added system, the end user pays tax but there is no net tax is effectively paid by anyone else in the chain.
If properly designed, and efficiently administered, sales taxes are a very fair way of raising revenue.

mshchem · Mar 22, 2021

The EU is threatening to withhold vaccine. The Telegraph option section today is calling for targeted tariffs, German cars, French wine, this could get ugly fast. Might be time to stock up no matter where you call home. The end user always ends up paying the bill.

mshchem · Mar 22, 2021

MattKing said:
It isn't the item that is taxed, it is the sales transaction.
And if the taxation system is in the nature of a Value Added system, the end user pays tax but there is no net tax is effectively paid by anyone else in the chain.
If properly designed, and efficiently administered, sales taxes are a very fair way of raising revenue.

And best of all like alcohol and tobacco taxes they are regressive. The poor have no where to run. Between, booze, smokes, lottery and government sanctioned marijuana, there's hardly enough left to binge on fast food.

pentaxuser · Mar 22, 2021

Thanks Arcadia 4 for your reply. One of the problems on this thread is that it was really a purely UK/EU thread and while other N American members are free add comments, anything else serves to confuse the nub of the issue which is what changes when we wish to order goods directly from Adox or for that matter Bergger and Foma or any other supplier of photographic materials from the EU

However I think I have grasped the EU to U.K. situation but looking at my analysis of what is now needed in terms of a syndicate purchase from Adox can you see any reason to believe I have got the consequences wrong? Given how things stand is there any good reason to believe that buying from Adox or other E.U, suppliers will be either cheaper or easier than in my analysis?

All I can see that is a slight improvement on my depressing analysis is that it would appear that from what you have said, is that the U.K. buyer has no declaration to sign. He simply pays the VAT on the total including delivery plus if it is RM a flat handling charge

As far as I can see it is a picture of unremitting gloom in terms what has changed in our ability to buy from E.U. retailers

pentaxuser

FotoImpex/Adox and UK since Brexit

David Allen

Craig75

perkeleellinen

Anon Ymous

R.Gould

ADOX Fotoimpex

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David Allen

foc

pentaxuser

R.Gould

foc

mshchem

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R.Gould

pentaxuser

Arcadia4

Arcadia4

beemermark

davela

mshchem

MattKing

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mshchem

mshchem

pentaxuser

FotoImpex/Adox and UK since Brexit

Partner

Partner

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