Recently, Integration Point hosted a webcast on the Union Customs Code (UCC) and the upcoming changes in the European Union.   The presenter, Mr. Walter Van der Meiren, Brokerage Division Manager, Europe Region, for UPS, shared a great deal of information about the UCC, the changes forthcoming and how companies can prepare for these changes.  There were several questions submitted that we did not have time to cover, and Mr. Van der Meiren has agreed to answer those here.  Today’s questions deal with the timing of the change and how a company can prepare.

If you missed the live webcast, you can view it on-demand here.

Q. What can we do in order to prepare for these changes?

A. Keep yourself informed. There still will be many changes in the next months, but you can start by looking at the impact of the new rules on your current business processes. For example, identify new opportunities such as benefits from AEO status, centralised clearance, self-assessment, comprehensive guarantee for several procedures, guarantee waiver or reduced guarantee, combination of inward process, processing under customs control (PCC) and destruction, longer storage period for temporary storage (is there still a need for a Customs Warehouse?), movement of temporary storage goods without use of a transit procedure, use of equivalent Union goods, and the new rules  concerning the assessment of customs debt.

You can also identify any new risks stemming from the new rules such as the assessment of customs debt (e.g. for re-imports after outward processing), the abolition of Customs Warehouse Type D, the abolition of free zone type II, and the introduction of the last sale rule for customs valuation.

Finally, you can request adaption or replacement of existing authorisations for customs procedures and facilitations (e.g. authorisation for the place(s) of temporary storage, comprehensive guarantee for all authorisations).

 

Q. Which articles will be applicable on May 2016 and which will be applicable later?

A. When we go through the UCC, there are certain titles that will be almost applicable immediately, like for instance title 1, definitions, customs representation and AEO.

For other titles like title 2, they will be partially applicable, like valuation will be apply immediately will for the Power of Union Status a system will need to be prepared.

We will have to wait for the transitional delegated acts and for the UCC work program in order to see which articles will be applicable when.  However, as a general rule, all articles that require a new system to be implemented or a system to be changed will not be applicable as of May 2016.

Q. Will the implementation timelines change?

A. That is the one million euro question.

There are different deadlines. The first one is the implementation of delegated and implementing acts.

For the moment the Commission is on schedule. Timelines are tight, but the way it looks now, the timelines will be respected. As we have seen, there a quite a few articles where the Commission, the Member States and Trade do not agree on. Also, there are also quite some important simplifications that are being reviewed in workshops. So the question is whether sticking to the timelines is an absolute requirement or whether it would not be better to take a bit more time and come up with workable solutions that are beneficial both for member states as for the industry.

The second deadline is December 31st 2020, when all systems that support the UCC will need to be operational. The UCC work program contains a lot of systems that will need to be implemented between 2017 and 2020 – and both trade as the 28 Member States will all have to deploy these systems, which require funding and resources, so future will tell if that date is really set in stone.

Q. Can you explain how the UCC Work Program looks like and when we can expect system changes?

A. The UCC work program is based on the Multi Annual Strategic Plan an contains 16 projects with target dates between 2017 and 2020.   And then there are projects included in the UCC WP but with indication that target dates are to be defined like Safety and security and Risk Management.

The most relevant are:

     UCC  Customs Decisions 02/10/2017
     Direct Trader Access 02/10/2017
    UCC  Proof of Union Status (PoUS) 02/10/2017
    UCC  AEO updates 01/03/2018
UCC Full BTI  phase 2 01/10/2018
  UCC  NCTS Common and Community Transit System 01/10/2018
  UCC  Automated Export System (AES) 01/03/2019
  UCC  Special Procedures 01/10/2019
  UCC  Notification of arrival, presentation notification and temporary storage 02/03/2020
  UCC  Centralised Clearance for Import (CCI) 02/10/2020
  UCC  Guarantee Management 02/10/2020

 

Stay tuned to Global Trade News for more Question & Answer from the UCC webcast with Mr. Van der Meiren.