Attention traders: UCC check-point, benefit, burden, and deadlines
Sep 19, 2017 Comments (0)
Long-term supplier’s declarations (LTSDs)
Since the UCC launch, LTSDs could only be issued for past shipments and future shipments separately, often leading to companies issuing two LTSDs instead of one. The EU now changed the rules and eliminated this requirement, which relieved the burden on businesses.
Companies are not too happy about the changes to the licensing costs, which must now be included in the customs value. This can have a massive impact on product values, especially when licensing or software fees account for a high share.
There is also a new restriction on the reporting of purchase prices, where previous purchase prices cannot be applied anymore. Previously, “pre-purchaser prices” were used to significantly lower the customs value, which in turn reduced the import duties based on that value.
But there are also changes for the better: The sanctions-like nature of customs debt has been abolished, enabling many customs operators to avoid the subsequent recovery of import duties.
The Registered Exporter (REX) status was mainly intended for exporters from developing countries under the Generalized Scheme of Preferences (GSP). But with the Comprehensive Economic and Trade Agreement (CETA) with Canada, it now also brings more benefits to EU companies. EU-based companies can now register origin for shipments valued at over €6,000 and REX is the basis for submitting declarations.
The reassessment of open-ended authorisations by customs authorities is of particular importance. Customs authorities are required to check whether authorisations meet the new UCC’s criteria and do not expect assessment results before the end of 2018 based on the high volumes to check. Authorisation holders will receive results in writing from their assigned customs office and holders of temporary authorisations need to reapply before they expire.
IT system implementation
All legal changes under the UCC need to be implemented in IT systems to meet the UCC’s objectives of simpler import and export procedures, lower monitoring and administration costs, and faster processing. To manage the complex web of concurrent IT projects, the EU has developed a Multi-Annual Strategic Plan (MASP), which is reviewed and updated each year, and the “UCC Work Program”, which provides an IT development toolbox to facilitate system implementations. The current programme encompasses 17 individual projects, with an implementation roadmap extending to 2020.
The Automated Export System (AES) project is particularly important for businesses. It aims to deliver the IT adjustments to accommodate changes in the simplified procedures, the customs clearance of exports, and the apportionment of outbound consignments. It is scheduled to go live in October 2019.
This also affects the harmonisation of interfaces to the Excise Movement and Control System (EMCS) and the New Computerized Transit System (NCTS), for which AES will enable automation of all export processes and formalities.
In addition, the first part of the project dealing with special procedures was rolled-out in the first half of 2017 and the project to centralise the customs clearance of imports is scheduled to go live in October 2020.
There are many changes under the UCC that traders can benefit from, and others that add administrative burdens to businesses. Traders and especially authorisation holders are well advised to engage early on any changes with impact on their business.
Key for successful management of all customs procedures – under the UCC as much as under future models the UK will align to after Brexit – is an integrated IT landscape to drive transparent, compliant, and competitive customs operations.
Iqubal Singh Pannu
Iqubal Singh Pannu is Senior Solutions Consultant at AEB in the UK and has been with the company since 2006. With considerable consultancy and project management experience, spanning several areas of the supply chain, Iqubal is advising companies on solutions for optimising supply chain performance and generating value through automated global trade and logistics processes.