System A3 Number 5
Problem Definition
Customs requires certain import entry
information for cargo risk assessment
purposes
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Currently import entries may be lodged up to
20 days after goods arrive in New Zealand
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Import entries confirm liability for duties and
charges which become payable following
submission of entry
The current 20 working day timeframe creates
border security risk for Customs as the provision
of risk assessment information is delayed
Import Entries & Risk Assessment
NOT GOVERNMENT POLICY
72.05% of import
entries for air
cargo lodged
before or on
arrival¹
Objective
Import entries contain information integral to
Customs’ cargo risk assessment process . Our
objective is to ensure that required data is
supplied within a timeframe that allows for its
most effective use.
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Border
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83.25% of import
entries for sea
cargo lodged
before or on
arrival.
88.9% of import
entries for sea
cargo lodged
within 24hrs of
arrival².
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Option Two:
Import Entry submitted
24-72 hours after arrival.
Goods cleared.
Status Quo: Import Entry
submitted (up to 20 working
days after goods arrival)
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Time
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Goods
released
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Proposed that duties and charges
remain payable 20 working days after
arrival. Ability to adjust value where
necessary (see ‘declaring and adjusting
value’ A3)
Option One:
Import Entry submitted before or
on arrival
Customs’ Risk Assessment Approach
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Import Entry - Status Quo
Risk assessment information contained within
import entries not uniformly received ahead of
goods arrival
Risk exists regarding movement of un-cleared
goods from ports
Duties and charges fall due on submission of
an import entry – this may be driving late
lodgement due to cash flow concerns
Proposed Options for Change
Status Quo: Customs permit for
removal of goods (to CCAs) lodged
OR delivery order lodged if import
entry submitted and goods cleared.
Goods removed from
port
•
Feedback from submitters
Changes must be balanced against
operational impacts on importers (especially
with respect to cash flow)
Further consultation with industry required
Timing Principle Advanced knowledge of domestic and overseas
goods, people, and craft entering and exiting New Zealand enables
risk to be assessed and legitimate trade and travel to be facilitated
efficiently
Technology and Data Principle Risk assessment processes must be
driven by advanced data analysis and the application of technological
solutions
Compliance Approach Customs makes compliance easy to do and
hard to avoid. Customs provides high assurance with a light touch
Implementation considerations
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TSW/JBMS feasibility work required
Option may be phased in over time
Analysis must be undertaken with respect to
the management of non-compliance (admin
penalties)
Further industry consultation required
1. Results of internal data analysis of 68, 922 air import entries lodged between 1/04/2014 and 30/04/2015.
2. Results of internal data analysis of 56,268 sea cargo import entries lodged between 1/04/2015 and 30/04/2015.
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NOT GOVERNMENT
POLICY
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Proposed Change – Option One
Require import entries (containing necessary risk assessment
information) to be submitted before or on arrival of goods
Requires provisional revenue confirmation to be submitted ahead
of arrival
Allow adjustments to value to be made where necessary (see
‘declaring and adjusting value’ A3)
Proposed that duties and charges are to remain payable within 20
working days of goods arrival
Pros
Risk assessment information contained on an entry will be received
for analysis before goods physically arrive in New Zealand allowing
Customs to assess risk
Lower compliance costs relating to CCAs
Small impact on FCL imports according to data analysis
Cons
Potential compliance difficulties for LCL and Airfreight due to
complex information chain and timing issues
Proposed Change - Option two
Require import entries (containing required risk assessment information to
be submitted within 24-72 hours of arrival
Require provisional revenue confirmation to be submitted within 24-72
hours of arrival
Allow adjustments to value to be made where necessary (see ‘declaring and
adjusting value’ A3)
Proposed that duties and charges to remain payable within 20 working days
days of goods arrival
Pros
Risk assessment information on an import entry received earlier than present
Smaller impact on LCL and Airfreight according to data analysis . Compliance
Cons
Risk assessment information will not be received for analysis before goods hit
the border introducing a risk element