European Union Customs Code report

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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
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UCC
Update
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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
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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
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State of play – UCC DA / IA
Bla, bla, bla ……
……political……
bla, bla, bla!
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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 !!!
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PoUS - System
Single Window
Union-goods
Non-Union-goods
T2L / T2LF
Summary
Declaration
Customs
FAL Form …
Authorised Issuer
Who ?
Customs Cargo Manifest
Port Authority
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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
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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)
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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
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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?
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Proof of Union Status - IT
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Proof of Union Status - IT
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Proof of Union Status - IT
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ICS
2019
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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
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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
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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 ?
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Questions ?
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Thank you !
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