A future-proof trade compliance program

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Cameron Atkins
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2 WCO Safe Framework of Standards Today s environment will require some level of partnership with the authorities to maintain a regular import flow and simplified authorizations. The alternative would be to declare each single shipment with time delays because of stricter control & audits on documents and products before they are released. WCO has released and upgraded their Safe Framework of standards, which has been subsequently translated by the EU into the UCC and AEO requirements. Phenix Advisory will walk you through these steps and explain how to take advantage of the globalization and standardization of these requirements. Main result is that the authorities are now expecting a more pro-active role from their business partners starting with the collection of correct and complete data aligned with the new WCO DM (EU CDM in Europe). 2 all rights reserved no reproduction allowed without prior written consent

3 EU translation of ECIP Common Infra Structure NCTS NCTS TIR NCTS Securit y EMCS SEA P ECS ECS AES Phase Phase Centr. REX 1 2 Clearing EORI Single WIndow WCO SAFE Framewor k ICS Safety/S ecurity AIS Centr. Clearing AEO Phase 1 AEO Simpl/Pr ocess AEO Full SAS P Old Law Modernized Community Code Partly Recognized Implementation Provisions Union Code UCC Union Code Fully EU Wide Recognized The European scheme as presented above is fully in alignment with the WCO Safe Framework, and can be used as a global foundation for basic development. 3 all rights reserved no reproduction allowed without prior written consent

4 Topics 1. WCO DM / EU CDM 2. Involved Partners 3. Product Specifications 4. Routing and security Measures 5. Pre-Assessment 6. Security Measures 7. Pre-notifications 4 all rights reserved no reproduction allowed without prior written consent

5 Compliance Data What data is legally required? What data is customer specific required? What is the source of the data? What are the data characteristics? What data needs to be submitted for which entry in a specific country? What platform is used for submission of entries? What is the message technology? Which partners are involved in the data collection and submission? How do we retrieve information for involved partners? What is the archiving location of the data? What is the record retention period for data? 5 all rights reserved no reproduction allowed without prior written consent

6 WCO DM basics HS Database LSP Database Supplier Database EORI Relation Table VAT Relation Table More detailed IOR / EOR Database Origin Database Buyer Database License Table Product Database Relation Database Database Shipment data IOR / EOR DM EU CDM WCO DM The WCO DM is the foundation for regional or national data programs. The EU has implemented the EU CDM. Business should match their data with the legal required information and add the information which is required to complete other determination models. 6 all rights reserved no reproduction allowed without prior written consent

7 WCO DM basics Entry Products Legal Obligations and Formalities Involved Parties Additional Information EU CDM COMMISSION REGULATION (EC) No 2286/2003 Transport Reference Cargo Data Vessel and Voyage Data Additional Information Data Group Transport Client Specific Client Specific Manufacturer WCO DM A future proof Data Modell should contains legal mandatory data and Client specific data. The last data base should be build based on internal needs, product specific requirements or process required information. 7 all rights reserved no reproduction allowed without prior written consent

8 WCO DM Entry Products Legal Obligations and Formalities Involved Parties Additional Information Declared Goods Import, Export or Tansit (Nature of Transaction) Declarant Warehouse Items (Manufacturer Parts) HTS Duties & Taxes Charges Payment Method Surety Bond Information emitted to National Authorities Consingee Consignor Legal Representative / Broker Entry Declared Goods Import, Export or Tansit (Nature of Transaction) Declarant Type (Nature of Transaction) Number Subtype Summary Declaration Date ECCN / Business Number (NA) Barcode Reference No for Common Access (AP) Place of Entry Date of Entry Port of Loading Country of Discharge Country of Destination Port of Destination Office of Entry/Exit Submitter Name Notification Declarant License (Submitter ID) Signature Broker (Y/N) Transmitter ID for US filing (NA) Export License No (NA) US Filer ID No (NA) USPPI No (NA) The WCO DM contains all information specifically for matters. Each group has sub- groups and so have each sub-group. 8 all rights reserved no reproduction allowed without prior written consent

9 WCO DM Transport Transport Reference Carrier Name Carrier Nationality Cargo Data Container External Packing Container Packing and weights Vessel Data Carrier ID Number VIN (Vehicle ID Number) (NA) Name of Master Transshipments Incoterm Vessel and Voyage Data Vessel Data Container Voyage Data Inland Mode of Transportation Vessel and Voyage Data Container Voyage Data Departure Date / Date of Export Country of Discharge Country of Discharge Code Port of Discharge Port of Lading Code Port of Destination Additional Information Place of Unlading Code (Ship to ID) Location of Goods Countries of Route Codes (EU) The WCO DM Transport contains all information specifically for routing and security matters. Each group has sub- groups and so have each subgroup. Inland Mode of Transportation Name of Carrier Crossing the Border Office of Entry/Exit Mode of Transport at Border Inland Mode of Transport ID Intended Office to Transit 9 all rights reserved no reproduction allowed without prior written consent

10 WCO DM Client Specific Client Specific Manufacturer Manufacturer Product Specifications Supplier Product Details Assembly Calculation Product Model Name Assembly Plant Code Assembly Plant Country Product EXW Value Product EXW Currency Product HS Code Manufacturer Part Number Manufacturer PartDetails Levels Part Price Value Part Price Currency Part Supplier Code Part Supplier Name The WCO DM Client Specific contains all information specifically for matters related to the IOR or EOR. This group is not mandatory and free to define, however many of these fields will be required to enable use the previous two parts. Manufacturer Product Details Solicitation Status (Pending, Sent, Complete) Product Treshold Value Product Treshold Value Currency Non-originating Value Non-originating Value Currency Positive Regional Value (%) Negative Non-originating value (%) BOM part type (Purchased/Manufactured) Product Supplier Code Product Supplier Country Product Preference Indicator Product Type (Diesel/Petrol) Product (Purchased/Manufactured) Product b Supplier Code Product b Supplier Country Product b Preference Indicator Product b Type (Diesel/Petrol) Product b (Purchased/Manufactured) 10 all rights reserved no reproduction allowed without prior written consent

11 WCO DM Specific Data Data Group Data Area Data Origin IPR / OPR Source information Origin Determination Inbound Warehouse Manufacturing Outbound Valuation Determination Product Classification The WCO DM Specific data could be used to enable de determination of the HS or ECCN code of a product, which is required to determine origin of a product. Also in this part of the table the data origin of the information will be identified and who the source of the information will be. 11 all rights reserved no reproduction allowed without prior written consent

12 WCO DM Model Customer Entries Single Window - One Stop Shop required Information Canada China European Union India Japan Mexico USA Each country has specific needs for information, but all is covered by the WCO DM. Import Export Transit VAT/Sales Tax Statistics Agriculture Tax - Partners - Product - Financial - Agriculture - Environmental - Logistic - Security Communication towards the authorities and receiving information back from the authorities will require multiple communication protocols. Based on this part of the model it will be identified how the mandatory data will be transferred towards the authorities Company Tax Excise EOR / IOR Systems Feeder systems Parts Production System Name Global NA Region SA Region AP Region EMEA Region Table ID Field name Structure Definition 12 all rights reserved no reproduction allowed without prior written consent

WCO DM Model Trade Content Declarations The total WCO DM, merged into a data

14 Data pre-assessments 24hrs before stowing - Sea 4 hrs before take-off Air Etc Product Database Client Pre-audits on data is mandatory. It will enable data adjustment before actual shipments will flow. ENS Entry HS Codes ECCN Codes PoAu ASN Client Screening Managed Service ENS / AIS Entry Summary Declaration Broker Classification Managed Service Valuation Broker Non. Preferential Origin Determination Broker PoAu Import Supplementary Entry Broker PoAu Import Supplementary Declaration Broker Duty Calculation Broker Regime code Determination Broker Preferential Yes / No Broker Preferential Origin Determination Documents Client Home Use 4xxx.xx Bnd Whs 71xx.xxx 200 GSP FTA s Database 300 EUR 1 Language End Use 4xxx.140 NCTS 400 ATR OPR 61xx.xxx Temp Import 5xxx.xxx Trade Information Client PoAu Pre Audits completed before shipment departs Post Audits completed after shipment arrives IPR 51xx.xxx Clearing Instructions Client 14 all rights reserved no reproduction allowed without prior written consent

Data Security Physical Security Data Security 15 all rights

16 Conclusion. As authorities implement risk based controls, a few key elements are becoming more and more important: All available partners will have to be identified, The routing of a shipment will be key for security measures, Classification (ECCN and HS) and Origin Determination of products should be aligned between country of dispatch and destination, Pre Assessment on procedures, documents, authorizations and data quality is a must-have, Security measures should be lifted to a next generation which will not only focus on physical flow of goods but also the data security. 16 all rights reserved no reproduction allowed without prior written consent

Thank you. Peter J.M. Bulters Partner & COO dir +31 223 69 31 03 mob +31 6 155 49 123 peter@phenix-advisory.

17 Thank you. Peter J.M. Bulters Partner & COO dir mob peter@phenix-advisory.com Office for Europe Parallelweg LK Callantsoog, NL Office for Asia 106, 10/F 52 Wellington Street Central, Hong Kong 17 all rights reserved no reproduction allowed without prior written consent

Diversifying to International Markets: Customs Workshop. Page 1

Diversifying to International Markets: Customs Workshop Page 1 EU Trade Agreements Legend EU & Customs union European Economic Area Preferential trade agreement in place Preferential agreement awaiting