Embed Size (px)
Citation preview
Proof of Union Status, E-Manifest and Expansion of the e-T2L
José García, Port Authority of Valencia
B2MOS Mid Term Conference
Valencia, 30 October 2014
1
2
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
Table of Contents
3
Introduction
• The Proof of Union Status (PoUS) is a very important document in theMotorways of the Sea environment.
• It is required for the transport of goods that enter or leave the EU.
• Customs are required to check the status of the goods.
• Performed by consulting the PoUS system.
• Using the paper T2L document as confirmation of where the goodsoriginated.
A new PoUS system is proposed, with aim to integrate it into existingshipping businesses IT departments….to replace the current paper T2Lwith an electronic equivalent.
4
Current situation
• At present, the PoUS document is in paper form.
However, the electronic T2L is available in some countries
e.g. Spain and Belgium (Table 1).
Country e-T2L T2L Pre-authenticatedT2L
C-StatusManifest
Commercial invoice
UK ✓ ✓ ✓
Greece ✓ ✓ ✓
Spain ✓ ✓
Belgium ✓ ✓
Germany ✓
Slovenia ✓
Table 1: Member States and the type of documents used for PoUS
• N.B. Only a sample of shipping businesses were interviewed in each country, and thus it is not to say that each of the
countries do not use other types of documents for PoUS as otherwise stated in Table 1.
5
Proposed system
Summary of the proposed system
• A new PoUS system is being proposed, which will be integratedinto existing shipping businesses IT departments.
• It is expected that the new PoUS system will become mandatoryfor Member States.
• The e-Manifest will allow the PoUS to be checked faster, thusallowing the status of the goods to be indicated quicker.
6
Proof of Union Status
Main functionalities
7
Electronic POUS in the European Union
PoUS System - Request to register PoUS
8
PoUS System - Validaton of PoUS
This process is based on the assumption
that a national system will be developed
which will interface to a Central Repository
for the registration of the proof. Only a fully
validated proof will be stored in the Central
Repository.
2nd QUARTER 2014. Vision document
1st QUARTER 2015. Service Specifications
3rd QUARTER 2015. Technical Specifications
4th QUARTER 2017. PoUS Operational
Electronic POUS in the European Union
9
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
Table of Contents
The synergy of the PoUS and e-Manifest
10
• The combination of the PoUS system and e-Manifest will provide anelectronic environment for port customs in MoS.
• As an authorised consignor, the PoUS procedure is greatly simplified (only the e-manifest is needed for proof at re-entry).
• Commercial documents are usually archived for up to 2 years as required by law link to the e-archive initiative as a way to increase efficiency
Main functionalities: Maintenance of the Export Procedure
11
E-Manifest
Main functionalities:
Simplified transit procedure
Assistance to safety and security processes
Support to other customs requirements
Excise goods
Requirements from maritime authorities
…
12
E-Manifest
13
November 2013. Way forward
January 2014. Draft legal provisions
July 2014. e-Manifest legal provisions voted
June 2015? e-Manifest implemented jointly with Directive 2010/65/EU
The e-Manifest is defined as a document allowing for the identification of goods for Customs purposes
Authorised consignors vs non-authorised consignors
Simplifications facilitating the free movement of goods by sea in the Single Market
Validation of the PoUS can be done within the e-Manifest framework
Implementation of a harmonized e-Manifest: Combined with the implementation of Directive 2010/65/EU.
E-Manifest
14
Authorised consignor Non-authorised consignor
Not required to request the endorsement of the PoUS
Required to request the endorsement of the PoUS to customs
Not required to stamp, sign or endorse any document if they use the e-Manifest
Required to prepare the documentation required by customs for its endorsement
Not required to use the PoUS system (when available)
Required to use the PoUS system (when available)
Only required to mark the goods which have Union status in the e-Manifest
Required to mark the goods which have Union status in the e-Manifest and include the PoUSreference
Not required to hold the PoUS at the time of presenting the e-Manifest
Not required to hold the PoUS at the time of presenting the e-Manifest
The best option is that all shipping companies that ship goods with Union status
become authorised consignors and use the e-Manifest.
Authorised vs Non-Authorised Consignor
15
Latest update
Proof of Union Status (PoUS System) – 02.10.2017
4 month delay at current situation – from the view of the COM it is not a problem
It will be the Replacement of T2L / T2LF but only for AEOs?
A link between the declaration of “Temporary storage” and the PoUS was not planned but after IPCSA comment to the Commission meeting on the 11th July, an automatic check will be implemented
Registration of the applicant – Everyone now needs an EORI ? (still to be confirmed)
16
1. Proof of Union Status
2. E-Manifest, E-T2L and PoUS
3. Questions for the Discussion Panel
Table of Contents
17
Who is taking responsibility for defining the harmonised format of the e-Manifest and the overlap with the National Single Windows created under Directive 2010/65/EU?
What are the criteria in each Member State to become an authorised consignor?
Who needs to become an authorised consignor, the shipping company or the national offices/agents of the shipping company in each Member State?
What auditing requirements will be established for authorised consignors?
What validations will be introduced in the MRN of the PoUS to be included in the e-Manifest for non-authorised consignors?
Will the e-Manifest be able to be used as a Summary Declaration for Temporary Storage?
Will the e-Manifest be able to be used for the calculation of port taxes or dues(when required)?
Could the PoUS system remove the requirement to present the ENS of Union goods when the ship calls outside the EU? And remove the requirements to present the EXS of Union goods that are transhipped in a third country port?
In such cases, will it be more efficient for authorised consignors to register the PoUSin the PoUS system even if no endorsement is required?
Open questions
18
Q for IPCSA:
The POUS procedure is directly related to how the manifests are managed, what is the position of IPCSA on the idea of DG-TAXUD to adopt a unique format of Summary Declaration of Temporary Storage for the whole EU? How would this affect IPCSA members?
Q for MCP:
What is MCP’s view on the previous issue?
Q for Italian Customs:
The e-POUS may only be a reality at the end of 2017. Given the considerable benefit that the e-T2L generates and its short payback period, could the e-T2L be implemented in Italy before?
What is the view of Italian Customs concerning the adoption of a unique format of SDTS?
Q for Spanish Customs:
Could some of the functionalities of the e-T2L may be of use for the future e-POUS? Which are the best practices generated in Spain that could be of use for the POUS implementation?
Questions for the discussion panel
Electronic T2L
LESS COSTS
LESS TIME
T2L Problems
When forwarding Union goods
When receiving Union goods
Paper presentation of the T2L in customsPhysical post of the document to the European port of
destinationUnfairness and increased time and costs compared to
exports. Worst customs controls
Paper presentation of the T2L in customsManual accounting and checking of the goods with the
SDTS by customsUnfairness and increased time and costs compared to
imports. Worst customs controls.
e-T2L : The solution
Automation of the justifiation of Communitystatus of the goods (T2L) through electronicT2L issuance and reception.
Objective: Avoid trips to the customs office toget the visa of the T2L document and to checkand account the T2L in front of the goods itemsin the SDTS.
Improve the control of these goods.
e-T2L : ¿How?
It was produced the electronic declaration and the T2Lelectronic form for forwarding Union goods
It was produced the electronic declaration and the registrationform for non-electronic T2L documents to be presented in Spain.It was produced the electronic declaration and clearing form ofthe T2L (JEC), which automatically links and settles item quantities ofthe proof of Union status with the goods items declared in the SDTSwas produced. Definition of filters and CLEARANCE for the electronic T2L andthe electronic proof of Union Status (JEC) declarations. Settlement of the goods declared in the SDTS with the goodsdeclared in the T2L documents.Electronic T2L national solution recognized by the other MemberStates.
e-T2L: CASES
Case 1. Forwarding of the e-T2L and Reception in Spain
Operador
Forwarding Spanish Customs
Anexes box 44
1. T2L Electronic declaration
2. Electronic countersign and creation ofthe T2L
OperadorArrival Spanish Customs
3. T2L settlement electronic message
4. Electronic countersign and clearance of the proof of Union Status (JEC)
Release
e-T2L: CASES
Case 2. Forwarding e-T2L in Spain and Reception in another MS
Operador
Forwarding Spanish Customs
Anexes box 44
1. T2L Electronic declaration
2. Electronic countersign and creation ofthe T2L
Arrival in another Member State Customs Office
3. Verification T2L
T2L Document
T2L electrónico
Verification in the customs website without the need of a digital signature
A Customs office in another Member State can verify the authenticity of the T2L certificate
Electronic T2L
Electronic T2L
Verification including the Security Verification Number
T2L electrónico
Verification in customs website and use of QR
e-T2L: CASES
Case 3. Forwarding T2L in another ME and Reception in Spain
* Additionally to other ME, it could be generated in paper or by an authorised operator
Forwading Customs in another ME
OPERADORAduanaLlegada
1. Indirectly register the T2L
Annex T2L
2. Acknowledgment
3. T2L settlement message
4. Countersign and generation of a customs release notification JEC
Clearance
e-T2L : ¿When?
Agreement of the Council of Ministries of 16-09-2011 forreducing administrative burdent to companies. Development of the solution by the Customs & ExciseDepartment, the IT Tax Department and ValenciaCustoms Office and Port Authority. Pilot with some operators (ARKAS,GRIMALDI...) inmay 2012 Generalisation of the solution to all operators in july2012Evolution
Electronic T2L
Estatistics forwarded e-
T2L (29-09-2014)
e-T2L expedidos
1.608
10.368
12.008
14.962
17.728
16.624
17.571
19.822
20.680
19.948
0
5.000
10.000
15.000
20.000
25.000
2T 2012 3T 2012 4T 2012 1T 2013 2T 2013 3T 2013 4T 2013 1T 2014 2T 2014 3T 2014
T2L electrónico
Statistics e-T2L
indirectly register /JEC (29-09-2014)
Datado electrónico T2L / JEC
3.211
2.086
2.606
2.487
187
3.711
3.475
3.684
3.936
3.646
0
500
1.000
1.500
2.000
2.500
3.000
3.500
4.000
4.500
2T 2012 3T 2012 4T 2012 1T 2013 2T 2013 3T 2013 4T 2013 1T 2014 2T 2014 3T 2014
T2L electrónicoGoods
shipped wit an
e-T2L versus a
paper T2L(29-09-2014)
Embarque mercancía UE
0
10.000
20.000
30.000
40.000
50.000
60.000
70.000
2.012 2.013 2.014
T2L papel
e-T2L73,4 %
27,7 %
72,3 %64,9 %
35,1 %
26,6 %
Datados DSDT
0
5.000
10.000
15.000
20.000
25.000
30.000
35.000
40.000
2.012 2.013 2.014
JCEJEC
T2L electrónicoSettlements of
SDTS with
electronic
proof of Union
Status vs
manual proof
of Union
Status(29-09-2014)
84,7 % 55,1 %
44,9 %
36,4 %
63,6 %
15,3 %
e-T2L Ventajas
Presentación on-line con CSV
Seguridad en destino Rapidez de gestión a la llegada
THANK YOU FOR YOUR ATENTION
B2MOS Mid Term Conference
Activity 1: Interoperability in MOS
Proof of Union Status, E-Manifest and Expansion of the Electronic T2L
Valencia, 30 October 2014
Francesco CusmaiDirezione Centrale Tecnologie per l’Innovazione
Ufficio Integrazione Applicativa
PoUS – State of the art (1)
• UCC article 6– all exchanges of information between customs authorities and
between economic operators and customs authorities shall bemade using electronic data-processing techniques
• UCC article IA-V-1-00– an electronic information and communication system shall be
used for the processing and exchange of information relating tothe customs status of goods
38
Implementation of a new business process relatedto the issuing and presentation of the T2L documentreplacing its paper form by electronic means
PoUS – State of the art (2)
• Business Case for Proof of Union Status– Published by the European Commission on 15/04/2014
39
• PoUS (Proof of Union Status) system– creation of an IT system including the setting up of a Central Repository for
the storage and exchange of PoUS document data between CustomsAuthorities across all Member States
– centrally developed and centrally operated application
• Pros– Shorter implementation time
– Reduction of costs
– Harmonization of the Customs UnionIT environment
• Cons– Poor integration with MS national
applications
PoUS – State of the art (3)
Italian Customs Agency will support this solution inthe context of future PoUS technical requirements
40
• Open solutionWeb services– automatically accessing to central PoUS data
– enhancing risk analysis and customs’ controls
– linking different customs processes at national level
– speeding-up PoUS-related formalities
• How to mitigate the weaknesses of a centrally developed andcentrally operated application?
PoUS simplifications
• Italian Customs Agency fully agrees with articleIA-V-1-11
41
PoUS of goods shall be provided by an authorised issuer pursuant to Article DA-V-1-09(513-12-DA) by specifying the appropriate status code on the electronic manifest.
Non-Authorized issuer: ?
• Italian Customs Agency supports the proposal of indicatingthe Union status of goods in the e-manifest provided that– PoUS will be submitted to the PoUS system and endorsed by Customs
at the port of departure
– Non-authorised trader will be subject to a risk analysis and, if needed,to customs controls
The shipping company should always include the MRN of the PoUS in thee-manifest in order to let customs carry out necessary controls as quicklyas possible. However, in case of need, the MRN could be optional.
Authorized issuer
Legal provisions of the PoUS
• DA/IA: second preliminary draft provisions(25/08/2014)
42
PoUS provisions (Chapter 1 – Title V) might need to be redraftedas a result of the on-going work on the e-manifest
Business Case (published in April 2014) to be amended accordingly
PoUS & e-Manifest
43
• Italian Customs Agency fully agrees with the implementationof a harmonized and electronic manifest as soon as possible
• Problems:– Not possible at moment due to the lack of an agreement between
Member States
– The project fiche “Blue Belt initiative and e-Manifest” has beendeleted from the last version (Rev. 2014 v1.0) of MASP (Multi-AnnualStrategic Plan) published on 02/07/2014
However, even if a harmonized manifest is not possible in a short time,at least an electronic version should be operational in all Member States
e-Manifest in Italy (1)
44
Italian Customs Agency has its own version of electronic manifest,which is used as Notification of Arrival, Manifest of Inbound Goods andTemporary Storage. It is also fully integrated with the previous ENS(ENtry Summary declaration) and the subsequent customs declaration
e-Manifest in Italy (2)
45
• Our electronic manifest already accepts the declaration ofgoods with “Community” status– In this case, the manifest only serves as notification of arrival and
manifest of inbound goods (no temporary storage is created)
– At present there is no possibility to declare a reference to the T2Lpaper document
• We are already amending our manifest in order to becompliant with the future PoUS system– A new specific field has been added with the aim of giving economic
operators the possibility to declare the MRN (Master ReferenceNumber) of the PoUS
– This amendment will be operational by 2016
e-Manifest in Italy (3)
• We are amending our electronic manifest to be compliantalso with the Directive 2010/65/EU
– IMO FAL forms data will be included in the e-Manifest for the fulfilment of reportingformalities
– This amendment will be operational by 01/06/2015
Recommendations
47
• All shipping companies carrying goods of Union status shouldbecome authorized consignors as this will lead to a reducedeffort compared to non-authorized traders. In these cases, noCustoms control should be necessary
• Successful key elements in the Spanish electronic systemrelated to the T2L– Italian Customs Agency fully agrees with them because their aim is to
• harmonize the customs union IT environment
• simplify and speed-up PoUS-related formalities
• enhance risk analysis and customs’ controls
• link different customs processes at national level
• reducing costs
• improving the throughput of all parties involved
Tests or pilots for B2MOS partners
48
• Italian Customs Agency is willing to participate andcollaborate with B2MOS partners, stakeholders and any otherinterested Member State, to a pilot project concerning theimplementation of a harmonized electronic manifest
Thank you for your kindattention!
[email protected] Centrale Tecnologie per l’Innovazione
Ufficio Integrazione Applicativa
www.agenziadoganemonopoli.gov.it
