In short
- Free-of-charge goods entering Great Britain do not automatically have a customs value of 0. If there is genuinely no sale or other consideration, Method 1 is unavailable, subject to HMRC’s pre-sold-goods exception; contractual extra items and later replacements require separate checks against the original transaction.
- HMRC distinguishes extras covered by a shipment’s sale price from replacement goods sent later in fulfilment of that sale.
- For a later contractual replacement, HMRC points to the original unit price and treats any adjustment of the earlier entry separately.
- Keep the valuation evidence, reason for dispatch and transport costs with the new entry rather than copying a zero commercial invoice.
- AirPost is a peer-to-peer fulfilment network: online shops have their orders packed and dropped at a parcel point by verified people near their customers, who earn a fee per parcel from home. No warehouse, no minimum order volume.
Your shop imports a replacement from an overseas supplier, or your EU business supplies replacement stock to a British operation. The customer-service record says free replacement and the supplier invoice requests no payment. That describes the commercial charge for this dispatch. Customs still needs an explanation of the goods and their value. The useful question is how the dispatch connects to the purchase contract. This article deals with goods entering Great Britain and focuses on extra items and replacements, rather than relief for damaged demonstration samples or a general export-invoice checklist.
Does a zero invoice mean there was no sale?
Look beyond the document generated for the parcel. A warranty replacement may fulfil an earlier paid agreement. Extra items may have been promised as part of the original order. A genuinely independent transfer without a sale is another situation. Collect the purchase order, supply terms and correspondence that explain the relationship. A pro-forma document marked value for customs purposes only is useful only if the value and its basis are supportable. It is not a reason to type a token amount into every no-charge dispatch.
HMRC’s free-charge guidance says Method 1 cannot be used where there is no sale or other consideration, while noting that evidence of a pre-sale can make Method 1 possible. For your records, identify the actual transaction before choosing a method. A no-payment line in the replacement workflow does not answer that question. Ask finance whether another invoice or agreement covers the goods. Give the declarant the response with the documents, especially when purchasing and customer service keep their records in different systems.
Create a dispatch note recording the original order, reason for supply, current quantity and contractual link. Mark that link as unresolved until it has been checked. Keep the customer-service explanation separate from the valuation decision: a promise to send a replacement explains the dispatch, while the declarant needs the agreement and supporting evidence to assess its value.
How are extra free items in the paid shipment treated?
HMRC describes cases where the sale price covers the total quantity shipped, including specified spare replacements or contractually supplied extra items. In those cases, you do not invent a separate additional value for the extras. Establish that your contract actually describes this arrangement. A supplier's unexplained surplus is not automatically the same fact pattern. Put the agreed inclusion in the order records and make the physical quantity visible on the goods list. The total price and the number of goods are different fields, and both must remain understandable.
For an internal reconciliation, call the supported sale price P and the complete shipped quantity Q. Check whether P covers Q under the agreement and show every supplied unit on the goods list. Give the declarant the contract so they can confirm how the complete quantity and agreed price are represented in the import entry.
| Dispatch situation | Document to connect | Valuation question |
|---|---|---|
| Contractual extras with the paid shipment | Supply terms and complete goods list | Does the sale price cover the total supplied quantity? |
| Later warranty replacement under the original transaction | Original invoice, warranty and replacement correspondence | Which original unit price supports the new goods? |
| Replacement invoiced at the original unit price | Replacement invoice and any credit arrangement | How are the new entry and earlier credit reviewed separately? |
| Independent supply with no sale or consideration | Reason for transfer and available valuation evidence | Which subsequent method can be supported? |
| Goods already sold onward before import | Evidence of that sale and the full transaction chain | Does HMRC’s pre-sold exception permit Method 1? |
What changes when the replacement arrives in a later parcel?
For later no-charge replacements clearly fulfilling the original transaction, HMRC directs the customs value to the unit price in that transaction. It separately addresses adjustment of the original entry. Connect the new parcel to the original product and invoice line. Do not use the current retail price from your webshop merely because it is the first price you can find. If the supplier has substituted a different version or upgraded model, disclose that change. The declarant needs the actual replacement, not an assumed identical copy.
Prepare two linked records: the goods and value evidence for the new import, and the question about any correction or credit for the earlier goods. A refund from the supplier does not automatically tell your shipping software how to declare the replacement. Nor does a new parcel label amend the earlier customs entry. Ask the representative to record the decision for each movement. This prevents finance from treating a credit note as though it settled all customs consequences of a later dispatch.
If the earlier goods are sent back, keep that return as its own physical movement with the corresponding evidence. Do not label the inbound replacement as returned goods solely because it is part of the same service case. The existing article about EU customer returns to the UK deals with a different relief question. Give the declarant the serial or batch link where available and explain whether the original goods were returned, retained or disposed of. Those facts should come from your records, not from a default template.
What if the original invoice cannot support this valuation?
Identify the missing evidence instead of putting zero in the field. Perhaps the supplier sent an independent promotional item, the replacement differs from the purchased goods, or the original contract is unavailable. HMRC describes using subsequent valuation methods for genuine free-charge goods. For Method 2, its separate guidance requires comparison with qualifying identical goods and evidence of an accepted transaction-value import. An ordinary online retail listing is not that import evidence. Explain what you have and let the declarant decide which method can actually be supported.
The Method 2 guidance asks for an import entry with supporting documents or data allowing HMRC to trace it, and considers differences in level, quantity and delivery costs. It also says that when several qualifying values are available, the lowest is used. Build a comparison file around those conditions. Do not pick a convenient previous price while ignoring that it covers another product, another commercial level or materially different transport. If the comparison cannot be established, keep the reason for moving to the next method visible.
State the missing link
Explain why the dispatch is not supported as part of the original paid transaction, or which fact remains unconfirmed.
Collect usable evidence
Gather supplier prices, relevant earlier import records and exact specifications rather than unrelated product screenshots.
Review the method
Have the declarant document the supported valuation method and any adjustments required by the actual circumstances.
Include transport evidence
Provide the real freight, insurance and handling records for the new movement, with their relationship to the goods price.
Retain the entry file
Store the final value, supporting material and any separate earlier-entry question together under the service case.
HMRC’s preparation guidance also requires a declared customs value even where no duty or VAT is payable. Keep relief and valuation as separate questions in your handover. The commercial invoice checklist covers the broader document fields. Here the additional task is to explain the no-charge transaction with evidence that a reviewer can follow.
Can recurring replacement imports use an agreed valuation approach?
HMRC points regular free-charge supply arrangements towards an agreed approach and advance valuation rulings. Its current guidance describes a ruling for specified goods and a scenario, binding for three years subject to withdrawal or cancellation. It must be requested before import or the declaration; it is not retrospective. For a recurring arrangement, assemble the contract, goods specification and proposed method before the next shipment. A ruling on valuation does not replace a classification review or silently settle every tax issue.
The ruling guidance gives a decision period of no later than 90 days after acceptance, with acceptance dependent on the necessary information being supplied. Keep that distinction in your planning. Sending the first form is not the same as having a complete accepted application. Record the scenario covered by the decision and review changes to the supply agreement. If the supplier later starts sending different goods or changes the contractual basis, return those facts to the reviewer instead of treating the old ruling as a blanket approval for all free parcels.
How do I budget preparation separately from the replacement value?
For a suitable small parcel prepared at an EU dispatch location through AirPost, constants retrieved on 14 October 2026 give €0.85 platform fee and €2.25 recommended sender fee. Their subtotal is €3.10 before the label and packaging. If the replacement requires its own comparable dispatch, that preparation subtotal belongs to that additional order. A no-charge product does not make its handling free. These amounts are a euro dispatch-accounting reference, not a sterling customs value or a quoted EU-to-UK transport price.
The actual sender agreement sets the preparation fee. Give the declarant the transport and service breakdown rather than assuming that every preparation or platform charge is the same valuation component. Through AirPost local fulfilment, a sender packs and hands over the order; the seller remains responsible for correct customs content, value and origin according to the copy. Release the replacement instructions after the transaction review, with the approved goods description and value basis attached.
Frequently asked questions
What customs value do free-of-charge goods need?
Use a supported valuation method for the actual transaction. First establish whether the goods are genuinely outside a sale or whether a paid contract covers the extra items or replacement.
Can I put zero on a free replacement invoice?
No payment for this dispatch does not establish zero customs value. Connect it to the original transaction and obtain the appropriate valuation review.
Are free extras valued separately from a paid shipment?
Where the contractual arrangement falls within HMRC’s described cases, the sale price covers the total supplied quantity. Document that inclusion and show the real physical quantity.
Does a supplier credit change the earlier customs entry?
Have that question reviewed separately. Keep the new replacement entry and the original-entry adjustment linked, without assuming one document automatically corrects the other.
Can I request a valuation ruling after the replacement arrives?
HMRC says advance valuation rulings are not retrospective. For a recurring arrangement, prepare the application and evidence before the relevant imports or declarations.
Sources
- HMRC: free-charge goods and contractual replacements; checked 14 October 2026
- HMRC: Method 2, identical goods and accepted import evidence
- HMRC: preparing the customs value, including where no duty or VAT is due
- HMRC: advance valuation rulings, acceptance, validity and timing
- AirPost: prices; preparation calculation from constants on 14 October 2026
Attach the reviewed replacement value and product instructions before releasing the order. Use AirPost to arrange its packing and handover on an available service.
Arrange fulfilment with AirPost