OCEAN comments on EU's plans to withdraw trade facilitation on "Small Consignements"
OCEAN suggests linking exemption to AEO status
The current EU Customs Code Implementing Provisions give Member States the possibility to allow their national ship suppliers not to make export declarations for small consignments. The EU Commission plans to withdraw this exemption under the Modernized Customs Code by 2013. This article explains the consequences of this for the European ship supplying industry.
"I would like to express its disappointment and hope that the exemption for small consignments will be maintained" Peter de Haas Jr., Chairman of the OCEAN Working Group of customs & taxation stated. "At the same time, we understand the security concerns that the European Commission has raised and we, consequently, wish to propose a compromise solution" he continued.
At this point, it is important to recall the characteristics of our industry to better understand why we have an interest in maintaining this exemption.
We deliver hundreds of goods (machinery items, spare parts, security equipment, household goods needed onboard of vessels) in very small quantities to vessels. Very often, captains need them “last minute” or “urgently” because of a breakdown of the apparatus in question just a few hours before. Often, these goods simply need to be replaced, so only a small quantity of these items is needed. Yet, these items may be critical (e.g. a replacement part of the motor engine etc.) to the proposed functioning of the vessel: No spare part = No departure of the vessel. With turn-around times of the vessel more and more reduced (often to less than a few hours), in some cases it would be difficult to fill in customs declarations and forms, wait for their approval etc. while the vessel wants to leave.
At the same time, European Ship Suppliers recognize the legitimate concern of the European Commission wishing to secure the EU supply chain. Ship suppliers wish to contribute to this and therefore propose to link this simplification / exemption to the Authorized Economic Operator (AEO) concept under the Modernized Customs Code. Only those companies being certified under the AEO status should be able to apply for this exception in the future.
OCEAN recognises that, besides security, there are more issues which need to be addressed like VAT, threasholds, import / export equal or unequal treatment and how to operate this system in a paperless, e-customs environment. OCEAN will comment on these issues in the near future.