To export or not to export

To export or not to export, that is the question. If you are confused about whether or not sailing overseas from Australia constitutes “exporting” your vessel, you’re in good company. Some have argued that if you plan to return in the same vessel to Australia, exporting is unnecessary. Past performance is not an indicator of the future, though.

A quick web search uncovers this ABF web page which clearly states:

When a small craft departs Australia for a place overseas, the vessel is exported and an export    declaration is required. You should lodge the export declaration, and present the export declaration number (EDN) to the ABF, before requesting ABF clearance.

I subsequently emailed the ABF and received a reply with an attached document named “EXPORT ADVICE - FACTSHEET - SMALLCRAFT.pdf” with the title “Exporting Small Craft”. It contains the following.

All small craft departing Australia for a place overseas are considered exported and require an export declaration to be lodged.

The document also states:

When an Australian-owned and registered vessel returns to Australia and has ceased its international voyage the vessel may be imported on a formal import declaration quoting GST exemption code 417 (GSTE417) for returned Australian goods.

and the following:

There is no mandatory requirement for a customs broker to undertake the clearance formalities however it is generally recommended.

The guidance is clear. An Australian-owned and registered vessel is exported temporarily when going overseas and re-imported upon returning. By citing the correct code(s), no duty is payable upon re-importation.

Customs brokers, whose services cost several hundred dollars, have accounts with the Integrated Cargo System (ICS), and file relevant documents electronically. Alternatively, signing up for the ICS also costs several hundred dollars. Fortunately, there is a free alternative, which is known as the manual declaration process.

If you’re sailing overseas for the first time in an Australian-owned vessel, the vessel must first be registered with the Australian Shipping Register Office (SRO). Allow at least one month, or even longer if you purchased your vessel second-hand. It's an expensive process, but there seems to be no way around it.

You must also register as a customs client, by completing ABF Form B319. Register using the individual or company name on your SRO certificate. Be sure to select both importer and exporter roles. You may also be asked to separately register the supplier of your vessel, by selecting the other role (and specifying 'supplier'). Note that the supplier is the entity that sold you the vessel, as described on the bill of sale. Client registration requires a 100-point check, which can be done presenting in person at a customs house or via email. 

Both the SRO registration and ABF client registration are one-time only.

The export declaration form, ABF Form B95, results in an export declaration number (EDN) being issued. It is a relatively simple one-page form but there are two items that warrant particular attention:
  • The export goods type (field 13).
  • The commodity classification code (AHECC) (field 28).
Specify OP (Own Power) for export goods type and 9902.10.20 (Non-cargo under own power) for the AHECC code. The latter is used to classify goods that are exported from Australia on a temporary basis and intended to be re-imported.

Apart from the above, you just need to be able to describe your vessel, its value and your destination. A bill of sale for your vessel is required to substantiate both your ownership of the vessel and its value. There are standard 5-letter port codes, known as UN location codes (UN/LOCODE), e.g., NCNOU for Noumea, New Caledonia.

Assuming you’re a registered customs client, you can lodge your export declaration well ahead of your intended date of departure (a.k.a. “date of export”). You must depart within ten days of the intended date of departure, though.

The normal flow is to request your departure clearance once you receive your EDN. In my case, I had previously contacted ABF Brisbane Maritime Operations ( and they emailed me that they had already received my EDN. I was instructed to arrange a departure time from Southport and we were cleared to depart within 24 hours. I have no complaints about the process or any of my interactions with the ABF. 

Fast forward to the return trip. Returning yachties are required to notify of their intended port and date of arrival at least 72 hours ahead of time. In our case, we notified them seven days ahead of time, that being our estimated passage time between Noumea and Sydney. I contacted them again once we were within internet range to finalize the date and time.

We were instructed to proceed to Neutral Bay (33°50.5’S 151°13.067’E), where we were met by customs officers (ABF) and biosecurity officers from the Department of Agriculture, Fisheries and Forestry (DAFF). The customs inspection and immigration check was free but the biosecurity check cost $430 (including a fee to remove some food). We were cleared and the officers sent us on our way.

None of the officers mentioned anything about re-importation during our arrival formalities and I didn't ask. At this stage, you'd be excused for thinking that re-importation is not required. However, unless you re-import, your vessel technically remains under the control of customs, even if you were cleared by ABF and DAFF officers upon arrival. I was subsequently advised that I should have lodged an import declaration prior to arrival.

Importing involves more effort than exporting because it involves two agencies, ABF and DAFF. The relevant form is ABF Form B650 Import Declaration (N10), which has three sections.

Section A describes the owner details, the overall value, port codes for the destination and biosecurity location (e.g., AUSYD), which the owner declares to be correct.

Section B describes your mode of transport (i.e., SEA), the name of the vessel, its official number, and port location codes for loading (e.g., NCNOU), arrival (e.g., AUSYD) and discharge (e.g., AUSYD).

Section C describes the details of what you’re importing and what tariffs apply. If you get this wrong, you will incur delays and/or pay duty to re-import your vessel. I’ve described suitable values for a vessel greater than 10m in length that is reimported after being exported on a temporary basis.

Tariff classification number8901.90.90Self transported goods (under own power).
Statistical code36Vessels that are 10m or more in length.
Valuation basis typeTVTransaction value (i.e., what was paid for the vessel).
Treatment code171Goods reimported after being exported on a temporary basis.
GST exemption code417Free of GST.
Establishment code009Marina.
Origin countryAUCountry of export.
Treatment instruments: Instrument typeBLBy-Law.
Treatment instruments: Instrument number0176871Refers to Customs By-law No. 0176871, which states that goods exported from Australia and returned in an unaltered condition are duty free.
Tariff classification instruments:
Instrument type
HS222022 Harmonized System. The Australian Harmonised Export Commodity Classification (AHECC) system derives from this World Customs Organisation (WCO) Harmonized System.
Tariff classification instruments:
Instrument number
9902.10.20Non cargo under own power (i.e., the AHECC code you used when exporting).

For “Goods description” describe the make, model and year of your vessel and for “Valuation elements” list the value of your vessel and AUD for the currency, as evidenced by a bill or sale and/or receipts. The quantity should be 1 and the unit and permit number can be blank.

Email the import declaration (see email addresses below) along with any supporting documents, e.g., for the 100-point check. A full import declaration (FID) number is issued by return email within one to three days. 

The next step is to lodge with the Cargo Online Lodgement System (COLS) to arrange clearance by DAFF. Note that a biosecurity inspection of your vessel upon arrival does not automatically clear your vessel in COLS. Enter _IMP_C for the Branch ID, which signifies that you're not using a customs broker. 

Once DAFF clears the "cargo", the workflow then returns to the ADF. However, it seems that ABF is not automatically notified of DAFF clearances (or perhaps I was just impatient) as I had to email to nudge the process. After a couple of back-and-forth emails, supplying my EDN as proof or prior "export" and explaining that I was not using a customs broker, I received an automatic email with an Authority To Deal (ATD).  At this point my "goods" (i.e., Arriba) were officially clear and released from customs control. The entire process was free.

Here are some useful email addresses:

Email addressPurpose lodging manual declarations in QLD (importing or exporting). lodging manual declarations in NSW (importing or exporting). arranging departure clearance from Southport, QLD (once you have an EDN). arranging departure clearance from Sydney, NSW (once you have an EDN).
For reporting your planned return to Australia to organize arrival clearance (at least 72 hours ahead of time). inquiring about the status of your "cargo" (once DAFF has released your vessel). registering an Australian-owned vessel with the Shipping Register Office (SRO).

The following are copies of documents that were effective at time of writing. Always contact the ABF for the most current guidelines.
In my case, I submitted my manual import declaration well after arriving in Australia, which complicated the process. Ideally, submit it as soon as you know your approximate return date, i.e., before you depart from overseas. Similarly, lodge with COLS as soon as you know your FID. You can then present the FID to biosecurity officials upon arrival.

I've described the process that I underwent. Your mileage may vary. I would love to hear from sailors who have successfully managed to sail overseas from Australia in recent years and done so without exporting or importing. What worked last decade doesn't count!

For others who want to sail overseas without paying for a customs broker, I hope you find this article helpful. Honestly, I wouldn't blame anyone for wanting to use a broker, though.

Disclaimer: I am not a customs broker and have researched the information in this article from ABF documents publicly available online. I am not liable for any costs and/or other consequences resulting directly or indirectly from relying on (wholly or partially) this information.