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This site was last updated
on
21-Sep-2009
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HM Revenue & Customs
Multi-Annual Strategic Plan
HMRC are working to a long term plan, with stages
along the way, the first of which is the introduction of
1. Authorised Economic Operator: The
thinking is that the supply chain can be secured by approving companies
along the chain to be AEO's.
We have been discussing this with Gary Charles a local Customs,
VAT and International Trade Consultant (see
Partners page) as regards to the practical
nature of applying for AEO status.
Gary's reading of the situation is that the EU is definitely
going down the road of common risk management and systems and the more data they can assemble the more targeted
(especially on non-AEOs) documentary and physical interventions
there will be. However the approval route is onerous with a
requirement for security of premises, fully documented procedures and
full staff screening. These requirements alone may disqualify some
organisations from applying and in the early days we would suggest that
if you have time-critical shipments by air then you should consider
seeking AEO status. Having said that one if our users has been quoted
for upgrading the
security requirements for his premises at over £30,000 and thus he has
disqualified himself. However if companies have already invested to
achieve "Known Consignor" status this accreditation can be
banked for AEO application purposes.
It should be noted however that a quick survey of our users suggests
that the number of companies likely to apply will be minimal and
therefore the supply chain cannot be considered likely to be protected
and the release of customs officers to examine non-approved traffic
seems unlikely to take place, but if this is not the case then there
could be significant delays for cargo. However the other add-on benefits
in terms of reduced Customs controls, advance routing and access to
facilitation that AEO gives it may
represent a significant advantage over non-approved competitors
in the supply chain.
Crucially this isn't a bandwagon that shippers can jump on
quickly as all member states of the EU are invited to comment on
each application and the time it takes to approve is
quoted at between 70 - 120 days if all goes smoothly!
As of November 2008, HMRC have issued some 30 certificates and
have 160 in the process, of which 22% are from large businesses. The
latest figures from HMRC state that 140 applications have been received,
with 4 rejected and 37 certificates issued. HMRC announced, in mid-May
2009, that the
EU/US Roadmap draft document is now available to view. The AEO Impact
Assessment has also been signed by the Minister and is available.
2. Economic Operator Registration and Identification (EORI) Scheme:
The purpose of the
EORI scheme is to have one unique identification number for each
Economic Operator that should be recognised by all EU customs
authorities. Such an identification number will serve as a
common reference for the identification of economic operators,
or persons, in their relations with the customs authorities of
the Community, and for the exchange of information between these
authorities and where appropriate, between customs authorities
and other government departments and agencies.
The implementation date of the scheme is 1st July 2009.
If you are approved, or wish to be
approved, as an Authorised Economic Operator (AEO), and/or are required
to provide pre arrival/pre departure information, or involved in the
import, export or movement of goods under a transit procedure you will
need an EORI number, which will be in the format GB plus a 15 digit
alpha-numeric code. HMRC have now confirmed (November 2008) that
the EORI number will be based upon the Trader's Unique Registered Number
and will notify traders to that effect.
In a circulation dated 24th March, HMRC have
again flagged up the start of the EORI scheme nad announced that from
1st April exporters will only be able to apply for an EORI and will no
longer therefore be able to apply for a TURN number
In early July the EU provided access to on-line EORI numbers
3.
Pre-shipment / pre-arrival Notification: This is the
next stage of co-operation between over 130 Customs Authorities who will
demand that they be notified of shipments so that this information can
be shared with the recipient country. At this stage it is thought that
the information will be required from the carrier, but he will be
relying on information transmitted to him by the shipper / importer.
In early February 2009 HMRC published a consultative document on
changing the time rules for pre-entry (up to 21 days before arrival of
goods) and pre-lodgement to NCH (limited to 48 hours prior to arrival of
vessel/goods.
In
the mean time you can view
Gary
Charles' Fact Sheet and we will update the site with more
information in the near future. For
Gary's details please go to our Partners
Page.
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