IPCSA Union Customs Code - Update London, 12.02.2015 Software. Consulting. Solutions. Agenda • General Information about UCC » Delegated + Implementing Act – state of play » Transitional Delegated Act • IT Systems » Proof of Union Status » Import Control System - ICS © dbh Logistics IT AG 2 UCC Update © dbh Logistics IT AG 3 State of play - UCC » Last discussions were very detailed about → AEO = – AEO and Customs representation – Again the interpretation of „Who is economic operator?“ – I handed my arguments for the extension of the concept of economic operators related to IT provider again to the ECCG (responsible person = Tonka Kostadinova; guidelines) → Guarantee management = – Flat rate of 7000 € per Summary declaration (no data available for calculation of amount of customs duty) → Proof of Union Status → ENS + ICS © dbh Logistics IT AG 4 State of play - UCC » January 2015 - Discussion-Meeting about the DA / IA incl. the Annexes changes still possible (but very tight frame) » „Transitional DA“ - first draft was published to Trade on 14/01/2015 » May 2015 - first draft of full version » September 2015 - agreement planned » December 2015 - adoption of the T-DA © dbh Logistics IT AG 5 State of play – UCC DA / IA Bla, bla, bla …… ……political…… bla, bla, bla! © dbh Logistics IT AG 6 State of play - UCC • Transitional Delegated Act » For what? → Provide transitional arrangements for the requirements of the use of electronic systems → No IT available on 1st May 2016 until 31st December 2020 » Transitional DA = part of the legislation of the UCC → Actually, should an agreement be made to 1st May Why? → In the current draft there is a timeline (as shown) where the final agreement is planned for December 2015 !!! © dbh Logistics IT AG 7 PoUS - System Single Window Union-goods Non-Union-goods T2L / T2LF Summary Declaration Customs FAL Form … Authorised Issuer Who ? Customs Cargo Manifest Port Authority © dbh Logistics IT AG 8 Today´s Procedure • • Today » Paper based (only in some MS national electronic solutions available) » T2L / T2LF » Manifest with Code “N” or “C” (Art. 317a CCIP) Procedure » Declaration of an T2L / T2LF (mostly on paper) » Endorsement at the customs office of departure » Re-entry in the EU → Declaration of the goods as non-EU; 12 mile zone ! → Presentation of T2L / T2LF or Manifest at customs office of destination (when leaving the port) → In the case of acceptance = manual change of the status © dbh Logistics IT AG 9 Process with PoUS System • Proof of Union Status (PoUS System) » Who needs to submit a “declaration”? (at the competent customs office of presentation) → Non-authorised issuer – Registration = MRN – Waiting for endorsement → Authorised issuer – Registration = MRN ? – Automatical endorsement ? → Customs Cargo Manifest – N / C Code in the Manifest per item – Authorised issuer = no registration in the system at all; sole use of the Manifest – Non-AI = registration of the Manifest, but only one MRN per Manifest (not per item) © dbh Logistics IT AG 10 Proof of Union Status - Process • Proof of Union Status (PoUS System) – “Re-entry” » Verification of the status at the customs office of destination → With MRN – data in the PoUS → With Customs Cargo Manifest – One MRN (Manifest-Data is in the PoUS System) – Without MRN = submission of the authorisation number of the AI and of Manifest-Data to Customs – Or entry into the records!?; decission of the involved MS appropriate system! » Feature → it is necessary to provide an interface connection for automatic verification and recognition of the status © dbh Logistics IT AG 11 Proof of Union Status - IT • Proof of Union Status (PoUS System) » Main goal = replacement of T2L / T2LF » Project 02.10.2017 = delayed → IT activities not started yet → New legal text is in review cycle (CPG) → After the agreement on the in the future applicable legal text the vision document needs to be revised (with the help of Trade!) → Where we are now? © dbh Logistics IT AG 12 Proof of Union Status - IT © dbh Logistics IT AG 13 Proof of Union Status - IT © dbh Logistics IT AG 14 Proof of Union Status - IT © dbh Logistics IT AG 15 ICS 2019 © dbh Logistics IT AG 16 ICS – Import Control System • Import Control System » 28 MS national solution; access to the system at the national level; support + maintenance » Harmonised interface » Common repository + data exchange (COM MS) » Optional central solution from the COM » Data set = Annex B - DA column F1a; F1b; F1c; F1d © dbh Logistics IT AG 17 ICS – Procedure • Import Control System » Multiple filing → Data from carriers → Data from forwarders / consignees / other person who is able to declare (Art. 127 (6) UCC + DA-IV-1-08a) → Information about buyer and seller is required → On the “lowest” manifest level (house; sub-house?) » Risk analysis → “timer” starts with the first part of the ENS declaration = 24 h before loading → “second part” has in this case no impact on the “Do not load” message © dbh Logistics IT AG 18 ICS – Problems? • Import Control System » Merging the different sub-messages » Various changes are possible (on every part) » Implications in the absence of partial data → Who contacts who? → How is the impact on the logistical flow and handling? » Authentification Unified User Management & Digital Signature ? © dbh Logistics IT AG 19 Questions ? © dbh Logistics IT AG 20 Thank you ! © dbh Logistics IT AG 21