At risk query and HMRC response

We recently asked HMRC what the process is for dealing with scenarios where goods come into Northern Ireland and at that time are declared ‘not at risk’ and then they subsequently leave Northern Ireland and become  ‘at risk’ including if there is a way to declare/pay the tariffs that are due as result.

According to HMRC, the correct process to follow (for both Trader Support Service (“TSS”) and non-TSS users) is the underpayments process. The trader would have to fill in a ‘voluntary clearance amendment (underpayment)’ form, but would not have to resubmit the original declaration. We have asked HMRC to confirm the compliance implications of making such an amendment.