EU: Export procedures for certain goods effective 1 May 2016

EU: Export procedures for certain goods

Some anomalies in the Union Customs Code (effective 1 May 2016) regarding certain products subject to excise duty or export formalities have been observed. Specifically, the anomalies relate to transactions involving products referred to as “excise / agri goods.”

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Export using transit

When goods are exported to, for instance, Switzerland or Norway under a common transit procedure, the customs office of exit will be the customs office of departure of the transit operation. 

After the barcode on the transit accompanying document (TAD) is scanned at the EU border (for example, the border between Germany and Switzerland), the goods can then proceed to the customs office of destination where the final formalities of the transit procedure and any import procedure are completed. 

According a provision in the implement regulation to the Union Customs Code (UCC), this procedure does not apply to “excise / agri goods.” This means that such excise / agri goods must be transported to the German-Swiss border under the export procedure. 

  • The transporter first must complete the export procedure with German customs.
  • Then, the transporter must complete the formalities required by the Swiss customs authorities in order to bring the goods into Switzerland (import in free circulation or transit). 

For both procedures, the transporter/exporter must use the services of a local logistics provider—and this will not only increase the time necessary for the transport but also will be subject to additional costs. 

This exemption for excise / agri goods also applies to other modes of transportation (including rail and water). 

Export using carnet TIR

When goods are exported to, for instance, Russia under the “carnet TIR” rules and part of the consignment is excise / agri goods, the carnet TIR may only be issued for the non-excise / agri goods. The excise / agri goods will be declared for export and transported under the export procedure to the EU border. The driver must fulfill the following requirements: 

  • Notify the authorities with regard to the goods subject to the carnet TIR regime
  • Complete the export procedure for the excise / agri goods 

The customs authorities then must issue a new document (a new carnet TIR) to allow for the the excise / agri goods to proceed to the final destination. 

These formalities were intended to be avoided under the TIR convention. 

 

Read an April 2016 report prepared by the KPMG member firm in the Netherlands: Export of products subject to excise duty or export formalities / Shortages in cross-border shipments of excise goods

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