a future-proof trade compliance program · 2019-03-07 · a future-proof trade compliance program....

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phenix advisory – your trade compliance partner across the globe

A future-proof trade compliance program



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).


2006 2007 2019201820172016201520142013201220112010200920082005

NCTS

NCTS

Securit

y

ECS

Phase

1

ICS

Safety/S

ecurity

ECS

Phase

2

NCTS

TIR

EORI

AEO

Phase

1

AEO

Full

AIS

Centr.

Clearing

AES

Centr.

Clearing

Common

Infra

StructureECIP

SEA

P

SAS

P

Old Customs LawModernized Community Customs Code

Partly Recognized

UCC Union Customs Code

Fully EU Wide Recognized

Implementation Provisions

Union Customs Code

Single

WIndow

EMCS

AEO

Simpl/Pr

ocess

REX

WCO

SAFE

Framewor

k

2006 2007 2019201820172016201520142013201220112010200920082005

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.

EU translation of 2020 Customs



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



• 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?

Compliance Data



WCO DM basics

WCO DM

EU CDM

IOR / EOR DM

Product Database

Origin

Database

HS

Database

Relation Database

Buyer

Database

Supplier

Database

LSP

Database

Customs Database

Customs

License Table

VAT

Relation Table

EORI

Relation TableMore detailed

IOR / EOR Database

Shipment data

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.



WCO DM

EU CDMCOMMISSION REGULATION (EC) No

2286/2003

Data Group

Customs

Transport

Client Specific

Customs

Entry

Products

Legal Obligations and

Formalities

Involved Parties

Additional Information

Transport

Reference

Cargo Data

Vessel and Voyage Data


Client Specific Manufacturer

WCO DM basics

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.



Customs

Entry

Declared Goods

Import, Export or Tansit (Nature of

Transaction)

Declarant

Products

Warehouse

Items (Manufacturer Parts)

HTS

Legal Obligations and Formalities

Duties & Taxes

Charges

Payment Method

Surety Bond

Involved Parties

Information emitted to National

Authorities

Consingee

Consignor

Legal Representative / Broker


Entry

Declared Goods

Type (Nature of Transaction)

Number

Subtype

Summary Declaration Date

ECCN / Business Number (NA)

Customs Barcode

Reference No for Common

Access (AP)

Import, Export or Tansit (Nature

of Transaction)

Place of Entry

Date of Entry

Port of Loading

Country of Discharge

Country of Destination

Port of Destination

Customs Office of Entry/Exit

Declarant

Submitter Name

Customs 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)

WCO DM Customs

The WCO DM Customs contains all

information specifically for Customs matters.Each group has sub- groups and so have each sub-group.



Transport

Reference

Cargo Data

Container External

Packing

Container Packing and weights


Vessel Data

Container Voyage Data

Inland Mode of Transportation



Vessel Data

Carrier Name

Carrier Nationality

Carrier ID Number

VIN (Vehicle ID Number) (NA)

Name of Master

Transshipments

Container Voyage Data

Incoterm

Departure Date / Date of Export

Country of Discharge

Country of Discharge Code

Port of Discharge

Port of Lading Code

Port of Destination

Place of Unlading Code (Ship to ID)

Location of Goods

Countries of Route Codes (EU)

Inland Mode of Transportation

Name of Carrier Crossing the Border

Customs Office of Entry/Exit

Mode of Transport at Border

Inland Mode of Transport ID

Intended Customs Office to Transit

WCO DM Transport

The WCO DM Transport contains all information specifically for routing and security matters.Each group has sub- groups and so have each sub-group.



Client Specific

Manufacturer

Manufacturer Product Specifications

Supplier

Product Details

Assembly Calculation

Manufacturer Product Details

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

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)

WCO DM Client Specific

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.



Data Origin

Source information

Data Group Data Area

IPR / OPR

Inbound

Warehouse

Manufacturing

OutboundOrigin Determination

Valuation Determination

Product Classification

WCO DM Specific Data

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.



USA

Single Window - One Stop Shop required Information

Canada

Mexico

European Union

India

China

Japan

Imp

ort

Exp

ort

Tra

nsit

VA

T/S

ale

s

Tax

Sta

tistic

s

Ag

ricu

lture

Tax

Co

mp

an

y

Tax

Excis

e

Customs

- Partners

- Product

- Financial

- Agriculture

- Environmental

- Logistic

- Security

EOR / IOR Systems

Feeder systems Parts Production

Table ID Field name Structure DefinitionSystem Name Global NA Region SA Region AP Region EMEA Region

WCO DM Model Customer Entries

Each country has specific needs for

information, but all is covered by the WCO

DM.

Based on this part of the model it will be

identified how the mandatory data will be

transferred towards the authorities

Communication towards

the authorities and

receiving information

back from the authorities

will require multiple

communication

protocols.



WCO DM Model

Trade ContentCustoms

Declarations

The total WCO DM, merged into a data control model.



ASNClient

ScreeningENS / AIS

Entry Summary Declaration

ClassificationCustoms Valuation

Non. Preferential

Origin Determination

PreferentialOrigin

Determination

FTA’s DatabaseCustoms

PreferentialYes / No

200GSP

300EUR 1

400ATR

Customs Regime code

Determination

Bnd Whs71xx.xxx

NCTS

Temp Import

5xxx.xxx

IPR51xx.xxx

OPR61xx.xxx

End Use4xxx.140

Home Use4xxx.xx

Duty CalculationImport

Supplementary Declaration

DocumentsClient

Language

HSCodes

ECCNCodes

ENS EntryCustoms

ImportSupplementary

EntryCustoms

Product DatabaseClient

Trade InformationClient

Clearing InstructionsClient

Customs Broker

Managed Service

Customs Broker

Managed Service

Customs Broker

Customs Broker

Customs Broker

Customs Broker

Customs Broker

Customs Broker

PrAu

PoAu

Pre Audits – completed before shipment departs

Post Audits – completed after shipment arrives

PrAu

PrAu

PrAu

PrAu PrAu PrAu

PrAu

PrAu

PrAuPrAuPoAu PoAu

PrAu PrAuPoAu

PrAu

PrAu

Data pre-assessments Pre-audits on data is mandatory. It will enable data adjustment before actual shipments will flow.

24hrs before stowing - Sea

4 hrs before take-off – Air

Etc…



Physical Security

Data Security

Data Security


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.



Thank you.

Peter J.M. BultersPartner & COOdir +31 223 69 31 03mob +31 6 155 49 [email protected]

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