Juno Sourcing Limited v The Commissioners for HMRC
Decision date: 1 December 2025
Neutral citation: [2025] UKFTT 1447 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This appeal concerned a post-clearance customs demand (C18) of £1,373,884.73 against Juno Sourcing Ltd for 52 PPE consignments imported in 2020 and a refusal of remission. The Tribunal held that disaster‑relief relief under the Commission Decision (Article 1c) required the goods actually to have ended up with an Approved Organisation and that Juno had not proved that on the balance of probabilities; it also found the remission claim confined to Category 3 consignments and rejected Articles 118 and 120 UCC grounds. Both appeals were dismissed and the C18 and remission refusal were upheld.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The Tribunal’s binding reasoning is that (1) a condition of disaster‑relief measures framed as imports “by or on behalf of” an Approved Organisation requires that the goods in fact reach such an organisation (mere intention or expectation at import is insufficient); (2) Article 118 UCC remission for defective goods requires the goods to be defective or non‑compliant at the time of release; and (3) Article 120 UCC equitable remission requires a causal link between the special circumstances relied on and the customs debt and is unavailable where deception or obvious negligence is attributable to the debtor.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal made observational comments that NIRU application/certificate practices and post‑import verification are consistent with requiring actual end‑use by an Approved Organisation, that a late new ground seeking to treat EU‑approved bodies as qualifying was rightly refused for lateness and lack of prospect, and that HMRC procedural shortcomings after liability arose will not generally ground Article 120 relief absent causal responsibility for the debt.