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The Road to Mandalay – paved or potholed?

Trade Intelligence Asia PacificMarch/April 2014

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Australia and Japan conclude Free Trade Agreement negotiations

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Key intelligence

Amendments to Singapore’s Strategic Trade Scheme

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ASEAN preferential Certificates of Origin no longer need FOB value

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Taiwan’s BSMI makes various amendments to the Apparel Labelling Standard

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Panel report issued on US measures on Chinese products

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BOC in the Phillipines issues rules to obtain the importers accreditation

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2014 Asia Pacific Customs and Trade Conference in Shanghai on 27 May

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PwC

3Trade Intelligence Asia Pacific March/April 2014

Index

Feature article

The Road to Mandalay – paved or potholed? 4

ASEAN updates 8

Export controls

Hong Kong – Application for International Import Certificate (IIC) and Delivery Verification Certificate (DVC)

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Taiwan – Certain SHTC goods exported to the U.S. or Japan may be free from export license requirements

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Free Trade Agreements (FTA) focus

Australia and Japan conclude FTA negotiations 12

Australia-Korea Free Trade Agreement oncluded 13

BIMSTEC leaders to expedite trade agreement 13

Canada and South Korea finalise FTA negotiations 13

Malaysia and Turkey sign Free Trade Agreement 14

Country reports

Australia 16

China 17

Hong Kong 19

India 20

Japan 24

Malaysia 25

New Zealand 26

Philippines 27

Singapore 28

Taiwan 29

Thailand 30

Vietnam 31

Around the world

WTO Releases the Sixth Trade Policy Review of Malaysia

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Safeguard investigations on bare elastomeric filament yarn and sodium citrate were initiated by India

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Update of China’s rare earths exports case 32

Japan, China and Indonesia requested DSB to establish panel

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Panel report issued on US measures on Chinese products

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WMS in action 34

Trade Intelligence Asia Pacific seeks to capture the essence of selected issues that are of particular interest to clients of PwC. Our regional network of customs and international trade consultants routinely gather, analyse and disseminate information and knowledge to our clients. Based on studies as well as meetings and discussions that take place across the region with various trade and customs officials, we consolidate our findings into Trade Intelligence Asia Pacific.

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There is no doubt that Myanmar represents an exciting opportunity both as a market for goods and services and as a supplier of raw materials and labour for many companies in the region and globally. As multinationals look to escape the slow-growth constraints of the developed world, ‘frontier markets’ such as Myanmar hold great promise. Myanmar has made a number of early moves to open its markets, with new foreign investment laws passed in late 2012, and has attracted reciprocal attention from trade partners. However, this frontier market remains just that – a frontier, with many risks. Many laws and regulations around foreign trade remain untested.

The fundamentals

So where to begin when looking to enter this frontier economy from a customs and trade perspective? To start with, customs duty is levied under the Customs Tariff of Myanmar Act (2012) at rates ranging from 0% to 40%. When compared with other developing countries, non-preferential (MFN) import duty rates in Myanmar are quite low but do vary widely from product to product. In addition to import duty, many imported goods are subject to commercial tax ranging from 5% to 100% depending upon the product. Like most countries, Myanmar uses the harmonised tariff system to classify imported goods. Myanmar is also a member of ASEAN and thus both offers and enjoys preferential import duty rates with nine other ASEAN countries as well as Australia, China, India, Japan, Korea, and New Zealand.

From an export perspective, a notification listing the types of economic activities allowed for foreign investment has been issued.

In early 2013 the Myanmar Investment Commission (MIC) issued guidance regarding the types of economic activities allowed for foreign investment. The country’s Stated-owned Economic Enterprises Law (SEE Law) specifies 12 activities which are closed to private investment and may only be carried out by the government. However, appeals can be made and the MIC considers all investment proposals on a case by case basis.

The Directorate of Trade and Department of Border Trade administer export/ import licenses and permits which are required for any export or import.

Exemptions and Incentives

Several exemptions and incentives now exist following the enactment of the Myanmar Foreign Investment Law (2012) (MFIL), introduced in November 2012, which provide various incentives for foreign investors with the objective of attracting further capital inflows, particularly in infrastructure projects.

Companies who are registered under the MFIL and which have obtained permits from the Myanmar Investment Commission (MIC) may, at the discretion of the MIC, be given relief from customs duty on certain machinery, equipment, instruments, machinery components, spare parts and materials used during the period of construction or expansion, and on raw materials for the first three years of commercial production. If an investor expands their business within certain approved time frames, it may enjoy exemptions and/or relief from customs duty or other internal taxes on these items that are imported in connection with the expansion of a business.

The Road to Mandalay – paved or potholed?


Manufacturing companies established in Myanmar that export a large portion of their production may be eligible for suspension or exemption of import duties and taxes on raw materials used to produce the goods for export.

Myanmar’s Special Economic Zones are gaining widespread attention from foreign investors. These areas are currently being developed in Dawei, Kyakphyu and Thilawa. They are introduced as part of the Government’s economic reform efforts in recent years and administered by the Central Body for Myanmar Special Economic Zones. Once operational, Special Economic Zones should offer favourable regulatory environments which often include customs duty exemptions. For example, incentives offered to investors under the Myanmar SEZ Law include exemptions on customs duty and other taxes for raw materials, machinery and equipment and certain types of goods imported for investors in exempted zones.

The situation at present

The customs environment in Myanmar is still relatively immature. Current regulations do not seem to exist, or at least are not widely known, on common customs topics such as temporary importation, classification of goods, and duty drawback. There are also apparently overlapping responsibilities of various Ministries and Departments on some trade issues that can lead to contradictions in requirements and confusion as to what type of approvals may or may not be required. Examples include import licensing, duty free importation of certain types of equipment, and import/export remittance requirements. Considerable uncertainty also exists around the treatment of technical customs topics by local industry representatives based in Myanmar, in areas such as valuation and classification of goods, determination of origin, bonded storage, or temporary import procedures.

There are also many anecdotal instances of arbitrary treatments by customs officials, penalties assessed for minor discrepancies, and non-standard approaches required to secure clearance of goods. Importers may struggle to find consistent treatment for imported goods and it is said to be common practice for Myanmar Customs to determine the import value of goods rather than relying on the transaction value as is common in most WTO countries.

Action is being taken by the Myanmar government to improve the import/export trading environment. The Customs and Tariff of Myanmar Law, passed in 2012 is only several pages long and consists of high level principles but it is reported that implementing regulations are being drafted. Myanmar is working to introduce an e-clearance system (based upon the system utilised in Japan), a bonded zone scheme is in the works, and training of customs officers on technical customs topics is underway.

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While the above incentives are promising, many in the local customs and trade field agree that the current laws and regulations around global trade are largely outdated, incomplete, or ignored and require revision. Customs officials PwC spoke with in a recent visit to the country spoke of Customs’ ability to determine the value of imported goods without making reference to any of the methods of the WTO Customs Valuation Agreement to which Myanmar is a signatory.

Looking ahead

Multinational companies wishing to import goods into Myanmar are advised to exercise considerable diligence in both understanding the environment for their products and in choosing business partners including logistics companies and customs agents. Clear service expectations and ‘red lines’ should be in place to protect against irregular activities. Importers should understand that shipments are often physically inspected and not pressure service providers into unrealistic customs clearance times that may encourage unethical behaviours.

As we have seen in other countries in the region, the process of drafting and implementing new regulations, putting in place new systems and procedures, and most importantly changing customs institutional culture can require many years. It appears that Myanmar has begun this journey and the environment for importers and exporters is likely to improve going forward.

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Structuring for growth in Asia –Making the best of Trade Facilitation in a changing commercial and regulatory landscape

Asia Pacific Customs and Trade Conference 201427 May 2014 – Shanghai

Despite a reported decline in recent export levels, the growth of manufacturing in China for both the domestic and international market continues and foreign investment levels remain strong. The customs and trade regulatory landscape in China is now generally viewed as being mature and allows companies to leverage a more predictable supply chain for both inbound and outbound flows. However, China is not standing still. The recent introduction of new customs and trade facilitation policies mean that companies should adopt new measures and practices in order to maintain the competitiveness of their supply chain. The growing accessibility of e-clearance and the establishment of the Shanghai Free Trade Zone are just two examples of where companies need to think about how their customs and trade function can support business growth and add value.

With China maturing and becoming more expensive, opportunities to create value elsewhere in Asia, for example by taking advantage of trade facilitation measures, abound. There have been developments to the Thai Authorised Economic Operator programme and the Indonesia bonded manufacturing zone rules that will also have prompted action from companies wishing to optimise their Asian customs and trade position. Coupled with the recent World Trade Organization Agreement on trade facilitation measures, this points to a good time for companies to invest in determining when and how to leverage trade facilitation programmes.

Identifying and capitalising on the available opportunities is not straightforward. The objective of the PwC Customs and Trade Conference 2014 is to equip participants with an understanding of the key trade facilitation measures available in China and elsewhere in the region, the potential benefits to be realised and how to best manage associated risks.

For more information, please visit us at www.pwchk.com/home/eng/taxsymposium2014_ctc_event.html

© 2014 PricewaterhouseCoopers WMS Pte Ltd. All rights reserved. “PricewaterhouseCoopers” and “PwC” refer to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firm’s professional judgment or bind another member firm or PwCIL in any way.

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Some ASEAN preferential Certificates of Origin no longer need FOB value

In accordance with the 45th ASEAN Economic Cooperation initiatives, the ASEAN Economic Ministers and their counterparts in the Republic of Korea have agreed to relax the general requirement to state the Free On Board (FOB) value on Certificate of Origin (CO) Form D, used under the ASEAN Trade In Goods Agreement (ATIGA) and Certificate of Origin Form AK, used under the ASEAN Korea Free Trade Agreement (AKFTA).

The FOB value now only needs to be stated in Box 9 of the CO if the Regional Value Content criterion is applied in determining the origin status of the goods. This means companies may no longer be required to make their manufacturing prices known to buyers, particularly where goods are shipped from a manufacturing country but invoiced through a regional headquarters.

Below is a summary of the countries which have implemented the update.

Country Form D Form AK

Cambodia* Yes, but with effect from March 2016 Yes, but with effect from March 2016

Indonesia Yes Yes

Korea N/A Yes

Laos Yes Yes

Malaysia Yes Yes

Myanmar* Yes, but with effect from March 2016 Yes, but with effect from March 2016

Philippines Yes Yes

Singapore No No

Thailand Yes no

Vietnam Yes Yes

ASEAN updates


Export controlsHong Kong – Application for International Import Certificate (IIC) and Delivery Verification Certificate (DVC)

On 21 March 2014, the Trade and Industry Department of Hong Kong (TID) issued Strategic Trade Controls Circular No. 6/2014 and No. 7/2014 to inform the traders on the latest application procedures for IIC and DVC, and to supersede the previous Strategic Trade Controls Circular No.3/2013 and No.4/2013.

Application for IIC and DVC may be submitted electronically through E-Applicants at the Strategic Trade Control System Website. Paper applications forms can ben also found and downloaded from the website.

The original signed copy of the IIC and DVC application forms must still be provided to TID in all circumstances. For electronic applications, applicants

should ensure that the original signed application forms are delivered to TID as soon as possible. TID will withhold approval and issuance of the IIC and DVC unless and until the original form is received. A processing fee of HK$105 and HK$315 will be charged for the issue of an IIC and DVC respectively.

Applicants must ensure that all information and details provided in the IIC and DVC application are true and correct. Provision of false or misleading information is an offense under the Hong Kong Import and Export Ordinance (HKIEO) and offenders are liable to prosecution and/or administrative actions. In addition, importing and exporting specific strategic commodities not under and in accordance with a license issued by TID will be deemed be an offence under the HKIEO and its subsidiary Regulations and may be liable to a penalty of a fine and imprisonment.

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Singapore Customs has amended the Strategic Trade Scheme (STS) that governs control and licensing of strategic goods and related technology.

The various changes entered into effect from 1 April 2014, with a transition period through 30 September 2014. The amendments are as follows:

Nature of change Currently until 1 April 2014 1 April 2014 onwards Potential impact of the change

Change in permit structure

Tier 1 Permit• Approved on a per transaction basis

Individual Permit • Approved on a per

transaction basis Singapore Customs will have more discretion going forward to grant trade facilitation to bulk permit applicants, depending on their respective transaction models. The previous Tier 2 permit was relatively more restrictive for applicants as it was limited to either a single product or end user.

Tier 2 Permit• Same product to multiple end-users, or

• Multiple products on same end user

Bulk Permit• Approval by

countries of destination

• Approval by specific entities

Tier 3 Permit• Multiple products to multiple

destination countries

Internal compliance programme (ICP) requirements standardised for all bulk permits

• Tier 2: Required to fulfil 4 ICP elements: End user/order screening, product classification, internal audits, recordkeeping

• Tier 3: Required to fulfil 7 ICP elements: 4 ICP elements cited above and appointment of strategic goods control officer, commitment statement from senior management and implementation of training programme

Companies applying for any bulk permits will be required to fulfil all 7 ICP elements.

Regardless of the degree of trade facilitation actually required by bulk permit applicants, they are now to fulfil all ICP elements.

From an operational aspect, applicants of a smaller operational scale with limited resources may find it challenging, especially in terms of organising internal training programmes regularly for all company employees. This is more so if the applicants do not have in-house subject matter specialists to conduct such training.

Additional declaration requirements on TradeNet for strategic goods bulk permit

Under Tier 2 and Tier 3 permit applications, the following fields are optional:

• Consignee Name

• Consignee Address

• Consignee Country Code

• End User Name

• End User Address

• End User Country Code

It is compulsory that these fields are to be filled for submission of a TradeNet bulk permit for strategic goods.

The new TradeNet declaration requirements will be relatively more stringent going forward. Applicants are now required to provide more shipping details about the consignees and end users to data entry personnel when they populate each strategic bulk permit on TradeNet. These personnel are most likely to be from external logistics providers/customs brokers.

STS participants will need to ensure operational procedures are in place to collect and communicate required information in order to avoid shipment delays and increased administrative burden.

For more information, please refer to the following link: www.customs.gov.sg/NR/rdonlyres/6B9EA876-92CF-41D7-8758-25916F32D8C2/0/STSCircularFinal.pdf


Taiwan – Certain SHTC goods exported to the U.S. or Japan may be free from export license requirements

On 21 April 2014, Taiwan’s Bureau of Foreign Trade (BOFT) announced several amendments to the Regulations Governing Export and Import of Strategic High-Tech Commodities (the Regulations). The amendments mainly exempt the license requirement for exporting low value Strategic High-Tech Commodities (SHTC) to the U.S. or Japan.

According to the new Regulations, the export license required for SHTC items may be exempted if the following criteria are met:

• The item(s) is being exported to the U.S. or Japan

• The exporter has conducted proper screening of the end user/buyer against the BOFT’s blacklist

• The FOB value of the same controlled item(s) on the export declaration is below NT$300,000 (approximately US$10,000); or if the exporter has implemented an Internal Control Program (ICP) that has been certified by the BOFT

Although the Regulations state that the NT$300,000 threshold applies to the FOB value of the same controlled item on an export declaration, the BOFT seems to hold different opinions and interpretations. The BOFT has indicated that the threshold should refer to the total FOB value of all controlled items listed on the export declaration. However, no formal ruling is available at the moment.

In addition, the Regulation asks exporters to conduct a screening of the end user/buyer to ensure that they are not blacklisted prior to the exportation. The BOFT expects the exporters to keep records as they may conduct post-entry audits (based on Taiwan customs regulations, all documents and records should be kept for at least five years). The implementation details for using the new exemption scheme requires that a special certificate number “FT999999999997” be listed on the export declaration instead of listing the export license number.

Other amendments include changes to the annual review deadline for ICP exporters.

Exporters who have implemented an ICP and have been certified by the BOFT may apply for special export licenses that are valid for multiple countries, buyers, consignees and end users when exporting SHTC items. The license is valid for three years.

To maintain the exporter’s certified ICP status, ICP exporters need to submit the annual internal ICP audit report to the BOFT. Currently, the deadline for the audit report is by 31 January of each year. However, after the amendment, the deadline has been extended to 31 March.

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Free Trade Agreement (FTA) focus

Agreements signed

Mexico – Panama FTA 3 April 2014

Australia – South Korea FTA 8 April 2014

Malaysia – Turkey FTA 17 April 2014

Agreements concluded

Australia – Japan FTA 7 April 2014

Canada – South Korea FTA 11 March 2014

Australia and Japan conclude Free Trade Agreement negotiations

On 7 April 2014, the Australian Prime Minister Tony Abbott announced the conclusion of negotiations on the Japan Australia Economic Partnership Agreement (JAEPA). Japan is Australia’s second-largest export market and second-largest trading partner.

The JAEPA aims to deliver significant benefits to Australia’s agricultural producers, resource exporters, service providers and consumers. The key outcomes of the JAEPA include:

• Agricultural tariffs of up to 219% will be eliminated or significantly reduced on many Australian agricultural exports. Exporters of beef, sugar, horticulture, wine and seafood will benefit from preferential access to the Japanese market and tariffs will be bound at zero for wool, cotton, lamb and beer.

• Energy and mineral products account for almost 89% of Japan’s merchandise imports from Australia. Under JAEPA, all tariffs on energy and mineral products will be eliminated within 10 years, most on entry into force of the agreement.

• Japan currently applies tariffs of up to 30% on some manufactured products. Under JAEPA, tariffs on A$243 million worth of Australian manufactured exports to Japan will be eliminated immediately on entry into force of the agreement.

• JAEPA guarantees Australian suppliers access to the Japanese government procurement market and contains commitments that will ensure transparency and facilitate participation in procurement processes. Australian and Japanese procuring entities have committed to provide national treatment for the goods, services and suppliers of the other Party for procurements above agreed value thresholds.

• Australian consumers will also be major beneficiaries of the JAEPA with tariffs eliminated on imported cars from Japan as well as household appliances and electronics.

The signing of the FTA by the two countries is expected to take place later this year, with the agreement entering into force by the end of 2015.


Canada and South Korea finalise Free Trade Agreement negotiations

On 11 March 2014, Canada and South Korea concluded negotiations on a bilateral FTA, with South Korea becoming the first Asian market to reach a free trade deal with Canada. The negotiation process has been focused on barriers to the auto and agricultural sectors and took nine years to conclude, with some difficult challenges along the way when Canada took South Korea’s restrictions on beef to a WTO panel in 2009, which resulted in prolonged halts to the talks.

The agreement has an extensive coverage of virtually all aspects of trade, including trade in goods and services, investments, government procurement, environment and labour cooperation. In regards to trade in goods, the agreement will reduce both tariffs and non-tariff measures to promote market access, transparency and predictability.

For the more sensitive auto and agricultural sectors, South Korea will reduce the 8% tariff rate on cars and parts upon entry into force of the agreement, while in return Canada will reduce its 6.1% tariff rate on cars and parts to 4% within 24 months. Although certain agricultural food products such as wine and spirits, fish and seafood will benefit from the agreement, 19% of agricultural products (by number of tariff lines) will be either exempted from benefit or receive a grace period for more than 10 years. Such agricultural products include cheese, dry milk and rice which South Korea regards as a sensitive.

The signing of the agreement is expected later this year after legal reviews are completed by both countries.

Australia-Korea Free Trade Agreement concluded

Following the formal signing of the Korea and Australia Free Trade Agreement (KAFTA) on 8 April 2014, the Australian Government has released the full text of Australia’s latest free trade agreement with its North Asia trading partners.

Upon entry into force of the KAFTA, 84% (by value) of Australia’s exports to Korea will enter duty-free, and that after full implementation, the agreement will eliminate tariffs on 99.8% of Australia’s exports.

It’s also anticipated that KAFTA will open up doors across legal, accounting, financial, engineering, telecommunications, education, environmental, as well as film and television services. KAFTA also includes provisions to facilitate more direct investment from Korea and create opportunities for Australian investment in Korea.

The agreement will enter into force when both parties complete their respective domestic legal and parliamentary processes. This is anticipated to occur by the end of 2014.

BIMSTEC leaders to expedite trade agreement

The leaders of the member countries of BIMSTEC (Bay of Bengal Initiative for Multi-Sectoral Technical and Economic Committee) agreed on 4 March 2014 to expedite the conclusion of an agreement on trade in goods to promote the cross border movement of products among its member countries India, Bangladesh, Sri Lanka, Thailand, Myanmar, Bhutan and Nepal.

The decision was made during the third Summit of BIMSTEC and a joint declaration was issued to the Trade Negotiation Committee to conclude a deal by the end of 2014. During the summit, the member states also agreed on Dispute Settlement Procedures and on Cooperation and Mutual Assistance in Customs Matters under the already existing BIMSTEC free trade area Framework Agreement.

The BIMSTEC free trade area Framework Agreement was signed in 2004 which committed members to negotiate a FTA on trade in goods, a commitment that is yet to progress further.

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Malaysia and Turkey sign Free Trade Agreement

Malaysia and Turkey have signed a Free Trade Agreement (MTFTA) on 17 April 2014 in Ankara, Turkey. The Agreement covers the following chapters:

• Market Access • Rules of Origin• Customs Cooperation • Technical Barriers to Trade• Sanitary and Phytosanitary • Trade Remedy• Economic and Technical Cooperation • Legal Institution

Key highlights in relation to trade of goods include:

1. Tariff Reductions

In line with the commitment to reduce or eliminate the tariffs, Malaysia and Turkey will reduce the tariffs based on the following modalities over a period of eight years.

Fast Track (FT) Immediate elimination upon entry into force

Normal Track (NT) Gradually reduced. Eliminated on the third year from the date of entering into force

Sensitive Track (ST) Gradually reduced. Eliminated on the fifth year from the date of entering into force

Highly Sensitive Track (HST)

Gradually reduced on the eight year from the date of entering into force.

Malaysian exporters that will benefit from immediate elimination of duties include companies in the following industries:

• electronics and electrical products • chemicals• textiles • machinery• plastic • rubber products• selected fisheries and tropical fruits • wood and wood products• selected automotive parts • aircrafts, space crafts, ships and boats• mineral and ores • glass, glassware and ceramic products• miscellaneous manufactured articles

Turkey will reduce duties by 30% for Crude Palm Oil, Processed Palm Oil, Crude Palm Kernel Oil and Processed Palm Kernel Oil. For textiles, Malaysian exporters are given immediate elimination of additional customs duties (ACD) that were imposed over and above the MFN duties for almost 1,000 tariff lines. For Malaysia, elimination of duties by Turkey through MTFTA will compensate for the withdrawal of the GSP benefits previously offered by Turkey until

31 December 2013.


Turkey had placed all tobacco products in HS2401, HS2402, HS2403 and passenger cars (HS8703) in the Sensitive Track (ST). Alcoholic beverages (HS2203 to HS2208) are Excluded (EL).

Turkish exporters will benefit from immediate elimination of duties for the following products, among others:

• agriculture and fisheries (except rice, selected poultries and other meats, selected fisheries, selected vegetables and selected fruits)

• Animal or vegetables fats and oils and its products (except selected palm oil and its products)

• Miscellaneous edible preparations• Sugar and sugar confectionaries• Products of meat, fish or crustaceans leather and its products• Railway or tramway locomotives, rolling stock and parts• Apparels, footwear and headgears• Aircrafts, space crafts, ships and boats• Selected machineries and equipment• Selected iron and steel and its products• Selected textiles• Selected electrical and electronic products

2. Origin Criteria

As Turkey is a member of the EU Customs Union, the FTA adopts EU 2010 GSP rules, pending the conclusion of the Malaysia-EU FTA. Non-wholly obtained materials incorporated into products produced must meet “Sufficient working or processing” requirements as laid out in Annex 4-2 of the FTA.

Materials originating in a Party shall be considered as materials originating in the other Party when incorporated into a product provided they have undergone working or processing going beyond the operations defined as “Insufficient/minimal working or processing”.

In general, materials falling under HS Chapters 25 to 97 originating in the

European Union or ASEAN shall be considered as materials originating in Turkey or Malaysia when further processed or incorporated into a product.

3. Certificate of Origin and invoice Declaration

Upon importation, proof of origin is substantiated by way of either a Certificate of Origin or Invoice Declaration (by an approved exporter or any exporter on consignment with total value of US$10, 000 or less). Approved exporters will carry a unique reference number that will appear on the invoice declaration.

A MTFTA Certificate of Origin (CO) is valid for 12 months from the date of issue. Third party invoicing is allowed. In exceptional cases, CO can be retroactively issued.

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Country reports

Australia Anti-dumping update

Anti-dumping and countervailing activity has remained strong during March and April, with the following notifications being issued by the Anti-dumping commission:

Gary Dutton

+61 (7) 3257 8783 [email protected]

Goods Action

Deep drawn stainless steel sinks

Initiation of an investigation into alleged dumping and subsidisation of sinks from China

Rod in coils Initiation of an investigation from Indonesia, Taiwan and Turkey

Aluminium extrusions Initiation of an anti-circumvention inquiry for product from China

Wind towers Findings in relation to a dumping investigation for product from China and Korea

Tomatoes, prepared or preserved

Findings in relation to a dumping investigation for product from Italy

Newsprint Initiation of an investigation into alleged dumping and subsidisation of newsprint from France and Korea

Hot rolled structural steel sections

Preliminary Affirmative Determination and imposition of securities for product from Japan, Korea, Taiwan and Thailand


Damon Paling

+86 (21) 2323 2877 [email protected]

China

Susan Ju

+86 (10) 6533 3319 [email protected]

Colbert Lam

+852 2289 3323 [email protected]

Shanghai Customs announces innovation programs in Shanghai PFTZ

Since the launch of the Shanghai Pilot Free Trade Zone (PFTZ) in September 2013, Shanghai Customs has committed to the exploration of innovation programs to promote and facilitate the business operations of enterprises within PFTZ. At a press conference on 22 April 2014, Shanghai Customs announced the timeline of implementation of 14 innovation programs that are ‘replicable and extendible’ across the country. Given the popular attention on the development of the Shanghai PFTZ and its potential wider implications to China, the 14 Customs programs are summarised below for reference:

I. Programs to be implemented by 1 May 2014

1) ‘Enter First, Declare Later’

• Goods can be released into the zone with manifest first, and declared to Customs within a designated period thereafter;

• 47 enterprises have participated in this program at trial stage.

2) Self-transportation within PFTZ

• Interregional transportation within the four bonded areas of the PFTZ can be arranged by an enterprise itself instead of via designated Customs supervised vehicles;

• Seven enterprises have participated in this program at trial stage.

3) Verification based on Work Orders under Processing Trade

• With the support of a network interface with enterprises’ ERP Systems, Customs verification of bonded manufacturing activities based on registered Unit of Consumption will be replaced by one based on actual Work Orders for enterprises conducting Processing Trade within the zone. This will provide a reference to the supervision of bonded R&D and bonded repair business, and will help mitigate the handbook inconsistency with enterprises’ internal record/actual bonded materials consumption;

• Similar programmes have already been piloted outside the PFTZ for several years.

4) Bonded exhibition and transaction

• Bonded exhibition and transactions within or outside PFTZ are allowed for qualified enterprises with deposits or bank guarantees provided;

• All goods sold during the exhibition are subject to consolidated declaration and duty payment afterwards.

5) Global repair

• Global repair for both domestic and overseas products is allowed for qualified enterprises in the PFTZ;

• Supervision will be performed with reference to that for Processing Trade.

6) Bonded futures transactions

• Bonded futures transactions will be extended from Yangshan Bonded Port Area to the whole PFTZ;

• The type of bonded future commodity will be extended from copper and aluminium to all the listed commodities in the Shanghai Futures Exchange.

7) Financial lease

• Customs duty and import VAT can be levied only on lease fees paid on an instalment basis;

• Deposits can be provided in the form of a Letter of Guarantee by qualified enterprises.

II. Programs to be promoted and implemented between 1 May 2014 and 30 June 2014

8) ‘Delivery by Batch, Consolidated Declaration’

• The traditional Customs declaration on a shipment basis will be replaced by a consolidated declaration for shipments delivered in batches within a certain period.

9) Simplified supporting documents

• Supporting documents will only be required to be submitted when necessary instead of at the time of inbound/outbound registration, and import/export declaration for goods with customs duty and import VAT exemption.

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10) Unification of the Inbound/Outbound Registration Form

• The Registration Form that is used in different bonded areas and in a different format will be unified.

11) Selective duty levy for domestic sales

• For goods manufactured in the PFTZ but sold to the domestic market, customs duty will be levied either based on the raw materials sourced overseas, or on the finished goods sold domestically.

12) Consolidated customs duty/import VAT payment

• With the provision of a guarantee, goods can be released first without customs duty/import VAT payment.

• Consolidated payment within a designated period will be allowed.

13) Network supervision for bonded logistics

• For enterprises utilising a Warehouse Management System, the traditional management model of “Registration, Stocktaking, and Verification” will be replaced by real-time and dynamic electronic management by Customs called “System Network, Location Management, Real-time Verification”.

14) Intelligent gate verification and release

• The PFTZ gate operation and truck release will be simplified by automatic goods/document/system data matching, verification and release.

III. Summary

The aforementioned innovation programs are still at initial stages with the Customs supervision model to be improved and matured. There is general scepticism in the business community as to when and how such programs will be

actually implemented and their benefits available to business.

Nevertheless, Customs will continue exploring more programs or pilots to support the development of new types of business models including e-commerce, and aiming to promote more mature supervision models all over the country in due course.

A new chapter for Beijing-Tianjin customs clearance integration

Following the agreement of customs authorities in Beijing and Tianjin, a new integrated clearance procedure will be launched by these two nearby cities in order to accelerate customs clearance. The integration is expected to bring greater convenience to companies importing and exporting cargo in either Beijing or Tianjin. The new customs clearance integration is an essential step in the implementation of intensified reforms nation-wide. Additionally, according to the General Administration of Customs, the new clearance trial project will gradually expand to the neighbouring province Hebei, which is a positive development for affected companies.

What is customs clearance integration?

Under previous clearance procedures, Beijing based trade companies importing or exporting goods in Tianjin ports had to go to Beijing for prior tax declaration to have the goods examined and released in Tianjin. Under the new clearance procedure, after going through the customs declaration and risk assessment processes in Beijing, Beijing Customs will send an instruction to the Tianjin port to release the cargo directly. The new clearance procedure enables firms to finalise declaration and examination processes within one single day, significantly simplifying the procedure.

How can companies benefit from the new clearance procedures?

Compared with previous clearance procedures, the new clearance procedure is expected to generate

significant cost and time savings for companies.

In accordance with China’s relevant customs regulations, depending on a company’s compliance with customs laws and regulations, trade volume and management, companies have been divided into five levels: AA, A, B, C and D. After the achievement of customs clearance integration, for those companies which are in higher levels, cargo can be directly released upon receiving instructions from Beijing Customs. Normally, it only takes two to three hours to have cargo transported from the Tianjin port to the site of a company in Beijing.

According to Beijing Customs data, due to the reduction in terms of transportation expense for supervision, companies are expected to lower logistics costs by 1,800 Yuan (approximately US$293) to 2,000 Yuan (approximately US$320) per TEU, or 20-foot equivalent units.

What can Customs gain through the reformation?

The application of the new Customs clearance procedure is also a positive reform for customs. The procedure will reduce the authorities’ workloads in terms of auditing and inspection.

According to statistics released by the Beijing Customs District, in 2013, 730,425 customs declarations were examined by field customs in Beijing Customs District, which occupies 82.4% of total customs declarations. The integration of customs clearance will make the cargo clearance more targeted and relieve the pressure on field operations. Thus, customs officers can be more focused on high-risk customs declarations.


Hong Kong

Derek Lee


Hong Kong and Korea Customs agree on closer co-operation and mutual recognition of AEO programmes

On 13 February 2014, the Commissioner of the Hong Kong Customs and Excise Department (CED) and the Commissioner of the Korea Customs Service (KCS) signed an arrangement to mutually recognise respective Authorized Economic Operator (AEO) programmes at the 31st Customs Cooperation Conference in Hong Kong.

This is the third arrangement of a similar nature that CED has concluded with other Customs administrations, after the Mainland China and India agreement. Under the Mutual Recognition Arrangement (MRA), Hong Kong companies accredited by the CED as AEOs can enjoy clearance facilitation, such as reduced examination or prioritised clearance, for their goods imported from or exported to these signatories. The CED will continue to take active steps to develop MRAs with Customs administrations of Hong Kong’s principal trading partners with the aim to assist local traders in accessing overseas markets and bring more business opportunities to the import/export and logistics industries.

Higher fees for various certificates and permits

Pursuant to the Hong Kong Import and Export (Fees) (Amendment) Regulation 2014 and the Chemical Weapons (Convention) Ordinance (Amendment of Schedule 4) Order 2014 published recently, and subject to the passage of the relevant legislative amendments by the Legislative Council, application of Delivery Verification Certificate, International Import Certificate and Permit under Section 9 of the Hong Kong Chemical Weapons (Convention) Ordinance is subject to the following new fees with effect from 21 March 2014:

Item Existing Fees HK$(until 20 March 2014)

New Fees HK$(from 21 March 2014)

Delivery Verification Certificate 285 315

International Import Certificate 96 105

Permit under Section 9 of the Chemical 235 260 Weapons (Convention) Ordinance

235 260

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Nitin Vijaivergia

+91 (0) 982 023 9915 [email protected]

IndiaCustoms

Notifications and circulars

• The Central Government has instructed the customs authorities that the facility of manual filing and processing of import/export documents should be allowed only in exceptional and genuine cases where the electronic filing and processing of import/export documents is not feasible. This exceptional process can be followed with the permission of the Commissioner of Customs.

(Instruction No. 401/81/2011-Cus.III dated 7 April 2014)

• The Central Government has instructed customs authorities to ensure that the import of Ammonium Nitrate is allowed clearance in compliance with the Ammonium Nitrate Rules, 2012.

(Instruction F. No. 450/37/2014 dated 5 March 2014)

• The Central Government has issued guidelines to the customs authorities at the airport regarding import of gold by eligible passengers. Gold (up to 1 kg) in the form of bars and ornaments is allowed to be imported by eligible passengers upon payment of a 10% customs duty.

(Circular No. 06/2014-Customs dated 6 March 2014)

• The Central Government has clarified that all incoming international passengers will be required to declare the contents of their baggage in the form notified under Customs Baggage Declaration Regulations 2013 with effect from 1 March 2014. Further, the Ministry of Home Affairs (MHA) has decided that the MHA arrival (disembarkation) card will be given to foreign nationals only.

(Circular No. 05/2014-Customs dated 27 February 2014)

• The Central Government has clarified that due to Electronic Data Interchange (EDI) system restrictions, exporters cannot opt for a higher rate of duty drawback in the absence of “non-availment of CENVAT certificate” at the time of export and they have to opt for a lower rate to get “Let Export Order” (LEO). However, this practice does not prevent the exporter from subsequently claiming higher drawback upon following the due procedure. The Central Government has directed customs authorities to allow such higher drawback upon following the prescribed procedure.

(Instruction No. 609/156/2013 dated 13 March 2014)

Case law

Classification

• The Delhi Tribunal, in CC v Star Personal Transport Pvt Ltd (2014-TIOL-533-CESTAT-DEL), held that classification of imported goods as spare parts cannot be disputed and termed as complete vehicles in Semi-Knocked Down (SKD) condition when there is no report to prove that such spare parts make a complete vehicle.

Valuation

• In CC v Shri Hari Corporation (2014-TIOL-554-CESTAT-MUM), the Mumbai Tribunal held that the transaction value of the importer can be rejected when the import price is lower than the price appearing in the manufacturer’s price list and the importer is not able to justify the same.

• The Mumbai Tribunal, in Star Entertainment Pvt Ltd v CC (2014-TIOL-583-CESTAT-MUM), held that the royalty/licence fee paid for exploitation of intrinsic content of imported media will be includible in the assessable value of imported media as it is a condition of sale.


• In Ravi Dyeware Co Ltd v CC (2014 (301) ELT 421), the Mumbai Tribunal held that for re-valuation of imported goods on the basis of the value of similar goods, the lowest of the value declared for similar goods is to be considered.

• The Mumbai Tribunal, in R S Merchant v CC (2014 (302) ELT 101), held that the transaction value of a wholesale importer cannot be rejected as the only basis of comparison with the retail imports as the goods are not of the same commercial value and quality as required in terms of the erstwhile Customs Valuation (Determination of Price of Imported Goods) Rules, 1988.

• In Prasad Enterprises v CC (2014 (302) ELT 261), the Mumbai Tribunal held that the value of imported goods cannot be rejected in the absence of legally permissible grounds prescribed under Customs Valuation (Determination of Price of Imported Goods) Rules, 2007, such as price paid over and above an invoice or any evidence of contemporaneous imports at higher value.

• The Delhi High Court, in Kirat International v Union of India (2014- TIOL-254-HC-DEL), held that the different valuation approach for freight and insurance calculation for identical goods imported from different countries could not be adopted in the absence of any justifiable reasons.

• In IMCD Group B V India v CC (2014 (301) ELT 259), the Mumbai Tribunal held that the transaction value could not be rejected merely on the basis of high selling price of the imported goods in India, where the importer was able to justify its import price on account of expenses incurred in India such as customs duty, local clearance, logistics cost, insurance, etc.

• The Delhi Tribunal, in CC v Data Enterprises (2014 (301) ELT 257), held that the value of imported goods could not be rejected in the absence of legally permissible grounds prescribed under the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007.

• In Rehau Polymers Pvt Ltd v CC (2014 (301) ELT 116), the Mumbai Tribunal held that the importer’s transaction value could not be rejected for price difference with third party imports where the price difference was on account of quality and there was no flow-back of money to the supplier.

Others

• The Delhi High Court, in Groz-Beckert Asia Pvt Ltd v Union of India (2014-TIOL-385-HC-DEL), held that where goods were re-exported after packing, a drawback will be allowable under section 74 of the Customs Act, 1962 (the Act) since such packing does not amount to the manufacture, processing or operation required for a drawback claim under section 75 of the Act (that applies to indigenous manufacture, process or operation).

• In Rollwell Forge Ltd v CC (2014-TIOL-414-CESTAT-AHM), the Ahmedabad Tribunal held that duty drawbacks granted on the re-export of imported goods cannot be demanded when goods were cleared after verification of identity of imported goods.

• The Madras High Court, in CC v Tamil Nadu Newsprint & Papers Ltd (2014-TIOL-346-HC-MAD), held that for determination of any question related to classification of goods or the value of goods for the purpose of assessment, an appeal against the decision of the Tribunal shall lie before the Supreme Court in terms of the Act.

• The Kolkata Tribunal, in CC v Indian Metals & Ferro Alloys Ltd (2014 (301) ELT 340), held that remission of duty will be allowed on shortages of imported goods found on re-warehousing in terms of section 23 of the Custom Act, 1962, where the loss is attributable to natural causes and not due to negligence as goods are lost before clearance for home consumption.

• In CC v India Tourism Development Corp Ltd (2014 (302) ELT 285), the Mumbai Tribunal held that non-renewal of a bond on removal

of goods from a private warehouse for sale in duty free shops within a specified bonded period does not amount to a violation of the law as the conditions of the Customs Bonding Licence are complied with.

• In ZTE Corporation v CC (2014-TIOL-249-HC-DEL), the Delhi High Court held that the foreign supplier’s request for re-export of goods from India could not be denied by the Customs authorities where ownership of goods remained with the exporter and these were virtually abandoned by the importer.

• The Delhi Tribunal, in SK Enterprises v CC (2014-TIOL-364-CESTAT-DEL), held that where the importer informed the Customs authorities of the wrongly shipped goods not conforming to BIS standards before filing of Bill of Entry, re-export of the same could not be denied on the grounds of mis-declaration.

• In Fossil India Pvt Ltd v CC (2014 (301) ELT 268), the Bangalore Tribunal held that refund of Special Additional Duty (SAD) of customs was admissible even though declaration about non-availment of SAD was not made on a sales invoice when the dealer was a non-registered dealer under excise.

• In Firmenich Aromatics (India) Pvt Ltd v CC (2014-TIOL-338-CESTAT-AHM), the Ahmedabad Tribunal held that in the absence of any specific period of limitation, the limitation period for demanding interest in respect of ‘warehoused goods which could not be cleared within the prescribed time’ would be six months in terms of section 28 of the Customs Act, 1962.

• The Mumbai Tribunal, in Seli Societa Esecuzione Lavori Idraulici Spa v CC (2014-TIOL-348-CESTAT-MUM), held that the test of unjust enrichment was not applicable on refund claims of cash security post finalisation of assessment in the case of goods imported under Project Import Scheme as the test applied to duty and interest thereon.

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Foreign Trade Policy

Notifications and circulars

• The Central Government has introduced a self-certification process in relation to compliance under the bar-coding requirement on secondary and tertiary level packaging of pharmaceuticals and drugs effective from 15 May 2014.

(Public Notice No. 56(RE-2013)/2009-14 dated 1 April 2014 and Public Notice No. 58(RE-2013)/2009-14 dated 15 April 2014)

• The Central Government has modified an appropriate body to certify quality of steel in terms of Steel and Steel Products (Quality Control) Second Order, 2012. Earlier, the requirement was to obtain quality certification from the recognised Quality Certifying Board of the Country of Origin, which shall now be quality certification from the International Standard Certifying Body.

(Notification No. 74(RE-2013)/2009-14 dated 13 March 2014)

• The Central Government has amended the Market Linked Focus Products Scrip (MLFPS) to give incentive to the specified products in addition to any benefit to which the said product may be entitled.

(Notification No. 71(RE-2013)/2009-14, Public Notice No. 53(RE-2013)/2009-14 and Public Notice No. 54(RE-2013)/ 2009-14 dated 27 February 2014)

• The Central Government has introduced an online system for Export Obligation Discharge Certificate (EODC)/ Redemption for Advance Authorization (AA) and Duty Free Import Authorisation (DFIA) with effect from 1 June 2014. This will reduce processing time and transaction costs.

(Public Notice No. 55(RE-2013)/2009- 14 dated 14 March 2014)

Case law

• The Karnataka High Court, in Gemalto Terminals India Pvt Ltd v CC (2014 (301) ELT 291), held that bank guarantees issued by importers in relation to Advance Authorisation (AA) schemes can be invoked in case an importer fails to produce the Export Obligation Discharge Certificate (EODC).

• In Patel Engineering Ltd v CC (2014 (301) ELT 370), the Mumbai Tribunal held that goods are liable for confiscation and benefit under the exemption notification, providing exemption under Export Promotion Capital Goods scheme is not eligible in cases of mis-declaration of the year of manufacture of second hand machinery by the importer to overcome the restriction of import of more than 10 year old machinery.

• The Delhi Tribunal, in Jubliant Life Sciences Ltd v CC (2014 (301) ELT 649), held that in cases of de-bonding, during intervention periods between the date of no objection

certificate by the Central Excise Authorities and the date of issue of final de-bonding orders by the development commissioner, Export Oriented Units can export finished goods under AA with no excise duty chargeable as they were not cleared into the Domestic Tariff Area (DTA).

• In CC v City Office Equipment (2014 (302) ELT 212), the Chennai Tribunal held that there are no restrictions on the import of second-hand digital multifunction print and copying machines in the FTP for the period of import before 28 February 2012 as the amendment is prospective in nature.

• The Bangalore Tribunal, in Milsoft Technologies Ltd v CC (2014 (302) ELT 110), held that liability to pay customs duty on imported capital goods along with interest arises in cases of non-extension of letters of permission due to non-fulfilment of export obligations.

• In Bharat Bijlee Ltd v CC (2014-TIOL-374-CESTAT-MUM), the Mumbai Tribunal held that benefit under Project Import Scheme was not available in cases where materials imported by one unit were transferred to another unit.

• The High Court of Delhi, in Kandoi Metal Powders Mfg Co Pvt Ltd v UOI (2014-TIOL-230-HC-DEL-EMIM), held that refund of Terminal Excise duty (TED) was available on supplies to Export Oriented Units (EOU) in terms of erstwhile FTP.


• In Marvellous Marble & Granite v CC (2014-TIOL-332-CESTAT-AHM), the Ahmedabad Tribunal held that a higher penalty and redemption fine was justifiable when lower fines and penalties had not deterred the importer from importing a restricted and sensitive commodity.

• The High Court of Delhi, in Aval Exports v UOI (2014 (301) ELT 14), held that an advance licence was to be issued in accordance with the policy in force on the date of issuance of the license, and not on the basis of policy as on the date of receipt of application.

• In CC v Gujarat Fashions P Ltd (2014- TIOL-328-HC-AHM-CX), the Gujarat High Court held that deemed exports were to be taken into account for the purpose of computation of entitlement of DTA clearances at concessional rates under the EOU scheme.

Free trade agreement changes

• The Central Government has reduced the basic customs duty (BCD) on imports of specified products from Japan under the India-Japan Comprehensive Economic Partnership Agreement (CEPA). This notification is effective from 1 April 2014.

(Customs Notification No. 09/2014 dated 1 April 2014)

• The Central Government has revised the available benefit on specified imports from Least Developed Countries (LDCs). The notification has changed the product coverage and extent of benefits although the eligible countries remain the same.

(Customs Notification No. 08/2014 dated 1 April 2014)

• BCD concessions are increased on imports of specified goods into India under the India-Japan CEPA.

Anti-dumping policy

Notifications

• The Central Government has levied provisional anti-dumping duties on imports of Cast Aluminium Alloy Wheels or Alloy Road Wheels used in motor vehicles, falling under Custom Tariff Heading (CTH) 8708, originating in, or exported from, People’s Republic of China, Korea RP and Thailand for a period of six months from 11 April 2014.

(Customs (ADD) Notification No. 15/2014 dated 11 April 2014)

• The Central Government has levied provisional anti-dumping duty on imports of Sodium Nitrate, falling under chapter 28 or 31, originating in, or exported from, the European Union, the People’s Republic of China, Ukraine and Korea RP, for a period of six months from 19 March 2014.

(Customs (ADD) Notification No. 14/2014 dated 19 March 2014)

• The Central Government has levied anti-dumping duty on imports of red phosphorous, excluding red phosphorous used in electronic applications, falling under chapter 28, originating in, or exported from, the People’s Republic of China for a period of five years from 19 March 2014.


• The Central Government has extended the levy of anti-dumping duty on Plain Medium Density Fibre Board of thickness 6 mm and above, falling under Custom Tariff Heading (CTH) 4411, originating in, or exported from the People’s Republic of China, Malaysia, Thailand and Sri Lanka, until 26 February 2015.


• The Central Government has levied anti-dumping duty on imports of Meta Phenylene Diamine, falling under chapter 29, originating in, or exported from, the People’s Republic of China, for a period of five years from 22 March 2013.


• The Central Government has extended a levy of anti-dumping duty on imports of Acetone, falling under CTH 2914 11 00, originating in, or exported from, the EU, South Africa, Singapore and the U.S. for a further period of five years from 11 March 2014.


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Japan

Amendment of Customs Tariff Act and other acts relevant to Customs on 1 April 2014 Increased Threshold for the Application of the Simplified Customs Duty Rate

As a result of the amendment, the threshold customs value for which an importer may choose to apply either the regular customs duty rate or the Simplified Customs Duty Rate has changed from JPY100,000 or less to JPY200,000 or less.

A high-level overview of the goods qualifying for the Simplified Customs Duty Rate in Japan can be found in the table below.

Naoyuki Kano


Categories Simplified Customs Duty Rate

1 Alcohol(1) Wine(2) Spirits such as shochu(3) Sake, Cider, etc.

JPY70/LitreJPY20/LitreJPY30/Litre

2 Tomato ketchup, ice cream, dropped furskins, etc.

20%

3 Coffee, tanned or dressed furskins excluding dropped furskins, etc.

15%

4 Clothing and accessories (other than knitted or crocheted), etc.

10%

5 Furniture, toys, games, etc. 3%

6 Rubber, paper , etc. FREE

7 Other products 5%

Specific Goods Graduated From the GSP Rate ListCertain agricultural/industrial goods classified in Chapter 35 originating from Thailand, in Chapters 07, 09, 12, 16, 20, 27, 28, 29, 36, 38, 39, 44, 46, 51, 56, 57, 58, 62, 63, 65, 66, 67, 69, 74, 76, 79, 81, 82, 83, 90, 94, 95, 96 originating from China, and in Chapter 21 originating from Brazil have graduated from the GSP rate list, and are now applicable to standard duty rates in Japan.

Independent State of Samoa Graduated from LDC PreferencesThe Independent State of Samoa has graduated from the United Nations Least Developed Country (LDC) List. Accordingly, any preference rates for LDCs will no longer apply to goods imported from the Independent State of Samoa into Japan. However, the Independent State of Samoa continues to qualify under the GSP scheme.

Import Consumption Tax AmendmentThe import consumption tax payable to Japan Customs at the time of importation has been increased from 5% to 8%.


Malaysia

Shi Yang Huang


Cessation of “PC1” Merit-based Import Duty and/or Sales Tax Exemption on Machinery & Equipment

The Malaysian Investment Development Authority (MIDA) has announced that it will no longer process the above merit-based applications from manufacturers in relation to machinery and equipment (including spare parts and consumables).

Going forward, manufacturers located in the Principal Customs Areas (PCA) are to claim import duty and sales tax exemption on qualifying machinery and equipment through the recent amended Customs Duties (Exemption) Order 2013 and the Sales Tax (Exemption) Order 2013 respectively. The revised exemption orders took effect 2 May 2014.

Applicants will need to first obtain an endorsement letter from MIDA confirming their manufacturing status for onward submission to the relevant State Customs Department (Industrial Section) before importation, along with details of the qualifying machinery and equipment.

Compared to the existing PC1 process and policy, key changes include:

1. “Spare parts” and “consumables” will no longer qualify for import duty exemption. Sales Tax exemption, however, may still be claimed.

2. Existing exemption letters will continue to be valid until expiry. Manufacturers who hold exemption letters that expire soon or had recently expired are encouraged to contact the MIDA Tariff Division immediately.

3. Qualifying machinery and equipment must be new, unused and to be used directly in the manufacturing of authorised finished products in the approved premise.

It is not clear at this stage whether machinery and equipment imported under lease or to be transferred to Malaysia as a result of plant relocation will qualify.

4. It is unclear whether a penalty and fine will be imposed if miss-claiming or over-claiming are discovered subsequently.

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New ZealandApplication of the Residual (“Fall-back”) Valuation method

A recent Customs Appeal Authority decision confirmed that the Residual Valuation (RV) method of valuation should follow the flexibility envisioned by Article VII of the General Agreement on Tariffs and Trade (the WTO Valuation Agreement), and that with respect to leased goods, it may be unrealistic to take the agreed insurance value as being representative of a fair market value.

The appellant imported leased aircraft into New Zealand. As the aircraft was leased rather than purchased, there was no invoiced value upon which a transaction value could be ascertained. As such, it was agreed between the parties that the RV method was the correct approach to determining the import value of the aircraft for customs purposes.

Customs argued that it was fair and reasonable to adopt the agreed insurance value as a basis for calculating the customs value for the aircraft under the RV method. The Appellant successfully argued that under their particular lease arrangement, the “agreed value” is not an appropriate basis for valuation as it was intended to equate to a future replacement value.

The valuation methodologies outlined in the Customs and Excise Act 1996 closely follow those outlined in the WTO Valuation Agreement. Drawing on the commentary in the Customs Valuation Commentary on the GATT Customs Valuation Code1, Barber J noted with approval that the RV method is intended to be “extremely broad and vague, so as to give a maximum of flexibility.”

Barber J found that Customs’ assessment based on the “agreed value” for insurance purposes was insufficiently flexible and led to a valuation which did not reflect the

market value and did not satisfy the RV method; the Appellant’s reliance on AVITAS valuations of their aircraft was held to be the correct method as it is based on actual sales of equivalent aircraft between arm’s length parties in the ordinary course of trade in the open market.

This case confirms that where the RV method is to be applied, the approach must be sufficiently flexible to enable the value to better reflect the market value, and that specialist industry valuations may be the most appropriate basis to determine the RV for goods imported into New Zealand.

It also makes it clear that the “agreed value” for insurance purposes may not always be an appropriate basis for determining the customs value of goods under the RV method, and this depends on how the “agreed value” is determined.

Amendments to the Customs and Excise Act 1996

Amendments to the Customs and Excise Act to support the implementation of Trade Single Window passed its third and final reading on 20 March 2014.

A key focus of the amendment concerns the implementation of the Joint Border Management System (JBMS). The operation of a Trade Single Window will give importers and exporters a single channel of compliance for New Zealand border requirements, simplifying the flow of trade and lowering compliance costs.

Offences and penalties relating to the arrival and departure of goods and craft will also be expanded.

The changes are expected to come into force on 1 July 2016, or by an earlier date as appointed by an Order in Council.

Eugen Trombitas


1 Sherman & Glashoff, 2nd ed 1988 Chapter 7, para [800] – [801]


Philippines

Alex Saborio


BOC issues rules to obtain the importers accreditation

In an effort to ensure legitimate business and proper tax mapping as well as to minimize duplication of function and productivity of both concerned government agencies, last Feb 6, 2014, DOF issued Department Order No. 12-2014 requiring both agencies, Bureau of Internal Revenue (BIR) and Bureau of Customs (BOC) to provide a set of their rules and regulations for the new accreditation process. Hence BIR RMO No. 10-2014 was issued providing the set of policies, guidelines and procedures in the accreditation of Importers which requires importers to secure BIR Importer Clearance Certificate (ICC) as a prerequisite to obtaining accreditation. Consequently, the BOC has provided the second leg of the process.

Under BOC Customs Memorandum Order 4-2014, which states the policies, guidelines and procedures for accreditation of Importers and Customs Brokers with the Bureau of Customs? BOC requires importers and Customs Brokers to submit the required documents to Account Management Office (formerly I-CARE) in which one of the required documents is Bureau of Internal Revenue Import Clearance Certificate (BIR-ICC). The Account Management

more revenue is collected and will also promote faster and more efficient processing of the permits and licenses.

On the other hand it is important to mention that the BIR will only accept applications that are processed by accredited importers and broker/representatives who are duly BIR taxpayers.

In case the applicant is an individual tax payer, the BIR will request a copy of the Income Tax Return (ITR) and if applicable, the Audited Financial Statements (AFS).

All eATRIG applications filed through the NSW System will be processed and authorised at the Excise LT Regulatory Division (ELTRD) of the BIR National Office.

Even when the eATRIG needs to be processed online through the NSW System, a hard notarised copy of the application is required to be presented before the BIR, before the electronic transmission of the approved eATRIG to the Bureau of Customs (BOC).

Finally, the BIR will reject all eATRIG applications that have remained pending for at least one month without presenting the necessary documentation.

Office (AMO) will also be responsible for providing Client Profile Registration System (CPRS), a requirement for online registration and profiling system of the BOC. Unlike BIR accreditation which is renewable every 3 years, BOC CMO 4-2014 does not state the expiration of the validity of its accreditation. The accreditation shall continue to be valid until such accreditation shall be subject for the grounds of suspension, revocation or cancellation.

Where an importer or customs broker’s accreditation is suspended, revoked, cancelled and reactivated, the accreditation must be filed with the Legal Service, Revenue Collection Monitoring Group (RCMG) of the BOC. Any decision made will be subject to the approval of the Deputy Commissioner of RCMG, who will notify AMO for immediate implementation.

BIR implements a permit on excisable goods

On 5 March 2014, the Bureau of Internal Revenue (BIR) issued the Revenue Memorandum 14-2014 which establishes the guidelines and procedures for the processing and issuance of an Electronic Authority to Release Imported Goods (eATRIG).

The eATRIG is a permit issued by the BIR to process the importation of goods that are subject to Excise Tax, such as raw materials, machinery, equipment and automobiles. This new publication states that all eATRIG applications need to be electronically filed through the National Single Window (NSW). According to the authorities this process will ensure

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Singapore

Gregory Nichols


Release of guidance relating to preferential trade agreement between Singapore and Taiwan

On 3 April 2014, Singapore Customs released two circulars outlining steps to utilise the recent preferential trade agreement between Singapore and Taiwan. The Circulars include the criteria to qualify for preferential tariff treatment under the Rules of Origin (RoO) and the operational procedures to claim preferential tariff treatment for imports and exports between Singapore and Taiwan under the Agreement between Singapore and the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu on Economic Partnership (ASTEP).

The ASTEP entered into force on 19 April 2014.

Rules of Origin:

Goods may qualify for preferential tariff treatment if they meet the following the criteria:

1. Goods are wholly obtained or produced in either Singapore or Taiwan

2. Goods satisfy the Product Specific Rules specified in the agreement. These are typically a change in tariff classification between the end product and the non-originating raw materials that are used in production; or the product has specific qualifying value content requirement

With the implementation of ASTEP, Taiwan and Singapore are treated as a single production area. Therefore any product or material that originates from Taiwan or Singapore will be deemed to be qualifying under the Agreement.

General Operational Procedures:

Importers will be able to claim preferential customs duty rates with a Declaration of Origin completed and signed by the exporter or producer. Where the value of the consignment is less than US$1,000, a Declaration of Origin will not be required.

Taiwan - Singapore Mutual Recognition Arrangement operational effective 1 April 2014

On 24 March 2014, Singapore Customs issued a circular on the implementation of a Mutual Recognition Arrangement (MRA) on Authorised Economic Operators (AEOs) between the Customs Administration of Taiwan (Taiwan Customs) and Singapore Customs. The new MRA will be operational with effect from 1 April 2014. Singapore currently has similar existing bilateral MRAs with Canada, South Korea, Japan and China.

Under the new MRA, Singapore Customs and Taiwan Customs will mutually recognise Singapore‘s Secure Trade Partnership Plus (STP-Plus) Program and Taiwan’s Security and Safety AEO (AEOS) companies.

According to Singapore Customs, STP-Plus certified traders in Singapore and AEOS companies in Taiwan should be recognised as low risk. In addition, secure companies in these two countries should be able to benefit from trade facilitative customs procedures for exports and imports between Taiwan and Singapore for a quicker customs declaration and clearance process. Such companies should be able to better manage the movement of goods particularly for time sensitive shipments and also reduce operating costs which they could otherwise incur due to delay at the ports.


Taiwan

BSMI makes various amendments to the Apparel Labelling Standard

The Bureau of Standards, Metrology, and Inspection (BSMI) recently announced the amendments to the Apparel Labelling Standard (the “Standard”). The important changes of the amendment include expanding the range of apparel material and accessories subject to the Standard, and adjusting care labelling symbols.

The important changes of the amendment and added criteria include:

• Expand the range of apparel material subject to the Standard to include goods made of or containing down, and specify that apparel containing down may not put wordings such as “pure” or “100%” down on the label.

• Adjust labelling for washing and care instruction symbols based on the new care labelling standard “ISO 3758:2012 Textiles – Care labelling code using symbols.” As a result, the illustration of the labelling symbols will be altered or added.

• Amend the room for error when labelling content percentages.

• Add masks, eyeshades, sleevelets to the list of accessories subject to the Standard.

• List out exceptions to labelling for parts of apparels such as sleeves, collars, labels, and decorations that are under a certain surface area percentage.

• The amendments are expected to become effective in March 2015, but the changes to the labelling symbols will not be implemented until March 2016.

Jay Lin

+886 (2) 2729 6666 Ext. 23800 [email protected]

For further details of the amendments, please visit the following link to download the complete announcement (only Chinese version available):

www.bsmi.gov.tw/wSite/ct?xItem=51651&ctNode=480&mp=3

New labelling requirement for allergy-prone foods

On 7 March 2014, the Food & Drug Administration (FDA) announced that food products containing allergenic ingredients are subject to special labelling requirements. This new requirement, which will become effective on 1 July 2014, stipulates that foods containing the below ingredients must be labelled with allergy warnings on the package:

• Crab

• Egg

• Mango

• Milk

• Peanut

• Shrimp

Allergy warnings must be written in traditional Chinese and manifested in a visually-prominent manner. Wording such as “This product contains peanuts” or “This product is not suitable for peanut allergy sufferers” is acceptable.

Imported foods are subject to mandatory inspection conducted by the FDA, and may only be released if they meet safety and quality standards, which include labelling requirements. If food labels fail to meet criteria, such as neglecting allergy warnings, the FDA/Customs may hold back the goods and request the importer to make immediate remedy.

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ThailandImport licenses required for wooden packaging materials

The Council of State released an opinion in April 2014 related to the questions of whether ‘wooden packaging’ materials could be considered as ‘plants’ as defined in the Thai Plant Quarantine Act, B.E. 2507 (The Act) and if so, whether a certified stamp issued under the International Standards for Phytosanitary Measures no. 15 (ISPM) under the International Plant Protection Convention (IPPC) could waive the requirement to obtain a ‘Health Certificate’ prior to importation. The issues were raised by the Thai Department of Agriculture

According to the Council of State, wooden packaging materials do not fall under the Act’s definition of ‘plants’ but the Council of State viewed that wooden packaging materials should be considered as ‘carriers’ as defined in the Act. According to the Act, the import of carriers are also subject to the requirement of obtaining a Health Certificate and therefore the import of wooden packaging would still require a Health Certificate prior to importation into Thailand.

Paul Sumner


Moreover, according to the Council of State, waiving the requirement of obtaining a ‘Health Certificate’ for wooden packaging certified under the IPPC would be contradictory with the spirit of The Act, especially as wooden packaging materials are considered ‘carriers’ which are governed by The Act. As such, the Council of State ruled that regardless of the certified IPPC stamp, a Health Certificate would still be required for the wooden packaging upon importation.

Therefore, companies that are importing goods which are not subject to import licenses but are packed in wooden packaging materials, may need to apply for a ‘Health Certificate’ with the Department of Agriculture prior to importing the goods into Thailand. It is important to note that Customs may consider the ‘Health Certificate’ as an import license. As such, non-compliance in this respect may be subject to severe Customs fines and penalties.


Vietnam

Amendments to customs valuation regulations in Vietnam

On 26 February 2014, the Ministry of Finance (MoF) issued Circular 29/2014/TT-BTC (Circular 29) amending and supplementing some provisions of Circular 205/2010/TT-BTC (Circular 205) regarding determination of customs value for exported/imported goods.

Circular 29 provides clearer definition for royalty fees/licence fees. In addition, the annex of Circular 29 provides examples of royalty cases for companies and Customs to refer to in daily work. The key updates include:

Trademark royalty/license fees are deemed to be related to imported goods when:

• The imported goods must be sold in Vietnam in their original condition or have gone through only simple processing after importation, and

• The imported goods being sold in Vietnam bear the relevant trademark at importation.

The royalty/license fees for using patents, technical know-how or intellectual properties are deemed to be related to imported goods when:

• The patent, technical know-how or other intellectual properties have been used for the production of imported goods, or

Nguyen Hong Son

+84 (8) 3823 0796 Ext.1509 [email protected]

• Imported goods bear the patent, industrial design or other intellectual property rights at importation; or

• Imported goods are manufactured using the patent, technical know-how or other intellectual property rights.

Circular 29 also provides the definition that for a royalty fee to be considered as paid as a condition of sale, this must be stated in the relevant sales contract, licence contract or other intellectual property transfer agreement.

Circular 29 will take effect from 12 April 2014. Although the clarifications may be welcome for a transparency or predictability perspective, they may not necessarily always be consistent with WTO Valuation Agreement principles. Importers and exporters should therefore take care to fully understand any differences, and how they may impact the supportability of their import or export valuations.

New customs clearance system in Vietnam

VNACCS/VCIS (Vietnam Automated Cargo Clearance System) is a new electronic customs clearance system integrated with one single window policy. It is sponsored by the Japanese government and was officially applied from 1 April 2014. The system is centralised based on encoding operations and information criteria. Main modules of the new system include e-Declaration, e-Manifest, e-Invoice, e-Payment, e-C/O, selectivity, management of risk documents, management of import/export enterprise, customs clearance, control and supervision.

Since mid-2013, the Vietnam General Department of Customs (GDC) has provided training and also performed a trial run for enterprises from November 2013 to February 2014.

Subsequently, on 14 February 2014, the Ministry of Finance (MoF) issued circular 22/2014/TT-BTC. Effective from 1 April 2014, the circular details regulations on electronic customs procedures to implement the VNACCS. With the high degree of automation provided by VNACCS, customs clearance is expected to be simplified in terms of the number of procedures and amount of paper work required. The system will allow companies to spend less time on filling forms, duty calculation and checking HS codes, to give a few examples. Furthermore, other government agencies could be authorised to access the system to verify information on goods without receiving customs’ confirmation on declaration as before.

However, VNACCS may not be used for registering products, consumption norms, performing material liquidation for toll manufacturing procedures and import for export production procedures. Enterprises must perform these procedures on the current e-customs system.

Most enterprises are concerned about non-compliance issues when the system is officially launched from 1 April 2014 and GDC are striving to provide support in the form of training and coaching following the implementation of the new circular 22.

According to the Vietnam Customs website (www.baohaiquan.vn), as at 21 March 2014 there were 18,196 enterprises registered to use VNACSS, with 10,154 enterprises having undergone the trial stage.

32 PwC

Around the worldWTO Releases the Sixth Trade Policy Review of Malaysia2

On 3 and 5 March 2014, the sixth Trade Policy Review of Malaysia was undertaken.

According to the report, Malaysia has achieved rapid economic growth during the period under review. Malaysia continues to make efforts on negotiation of new regional trade agreements (RTAs) and signed four bilateral agreements and three other ASEAN RTAs with third countries.

The average applied MFN tariff of Malaysia reduced from 7.4% in 2009 to 5.6% in 2013. Trade facilitation has been further strengthened by shifting customs clearance from clearance-based controls to post-clearance audit controls.

A large number of tariff lines remain subject to import licensing. Meanwhile export restrictions are also applied to certain goods (e.g. timber, crude palm oil).

Safeguard investigations on bare elastomeric filament yarn and sodium citrate were initiated by India3

India notified the World Trade Organization’s (WTO’s) Committee respectively on 5 March and 7 March 2014 that it has launched safeguard investigations on bare elastomeric filament yarn and sodium citrate.

Update of China’s rare earths exports case4

On 13 March 2012, the United States, the European Union and Japan each raised the dispute to WTO with respect to China’s export measures on rare earth. A panel was established in July 2012.

On 26 March 2014, the panel reports were issued and concluded that China’s export measures imposed on rare earth are inconsistent with its WTO obligations.

The United States and China appealed the rare earth panel report respectively on 8 and 17 April 2014.5 6

2 www.wto.org/english/tratop_e/tpr_e/tp392_e.htm3 www.wto.org/english/news_e/news14_e/safe_ind_05mar14_e.htm www.wto.org/english/news_e/news14_e/safe_ind_07mar14_e.htm4 www.wto.org/english/news_e/news14_e/431_432_433r_e.htm5 www.wto.org/english/news_e/news14_e/ds431apl_08apr14_e.htm6 www.wto.org/english/news_e/news14_e/ds449apl_17apr14_e.htm


Japan, China and Indonesia requested DSB to establish panel 7

On 26 March 2014, three panels were established by Dispute Settlement Body (DBS) at the request of Japan, China and Indonesia.

The disputes involved including: Ukraine’s safeguard measures on certain passenger cars; US anti-dumping proceedings and Australia’s plain packaging requirements for tobacco products.

Panel report issued on US measures on Chinese products 8

On 27 March 2014, the panel report was issued with respect to the dispute between China and the United States on Countervailing and Anti-Dumping Measures on Certain Products from China.

The Panel report concluded that the measures at issue imposed by the United States were inconsistent the SCM Agreement (Agreement on Subsidies and countervailing measures) but declined some of China’s request.

On 8 April 2014, China notified the WTO of its decision to appeal the Panel Report.9

7 www.wto.org/english/news_e/news14_e/dsb_26mar14_e.htm8 www.wto.org/english/news_e/news14_e/449r_e.htm9 www.wto.org/english/news_e/news14_e/ds449apl_08apr14_e.htm

34 PwC

WMS in actionJapan: Global assessment of import restrictions

A Japanese company recently engaged WMS Japan to review the possible restrictions on importation of its products in a large number of markets, as well as compliance with such standards to assess their alignment with local regulations. The company, which exports products such as medical equipment and tooling machines from Japan to countries all over the world faced a challenge in understanding and managing compliance on a global scale.

By utilising the extensive global network PwC has to offer, WMS Japan conducted research on applicable import regulations in over 50 territories including territories in Asia, the Middle East, Africa, North & South America and Europe. Information was gathered on any restrictions applicable to the equipment, as well as relevant in-country laws and regulations that may impact import procedures and compliance. This ensured that the client was able to make informed decisions on prioritising export markets and how to manage customs compliance in those territories moving forward.

Vietnam: Assistance with customs post clearance audit

Recently one of WMS’ clients, an alcohol importer and trader in Vietnam, was selected to undergo a customs investigation by Vietnam’s Ministry of Finance. The investigation by the Ministry of Finance was largely focussed on valuation issues in relation to the company’s import of products into Vietnam. The company sought PwC’s assistance in preparing for and managing the investigation. PwC worked with the client to perform a mock investigation at the client’s premises, which involved interviewing key personnel and reviewing documentation on site. Following the mock investigation, we advised the client of potential risk areas, as well as assessing the impact of these risks and tax exposure.

The initial investigation by the Ministry of Finance is expected to start in May, PwC will provide ongoing support to the client by preparing documents to support its position as well as a strategy for dealing with Customs authorities going forward.

Ho Chi Minh City

Tokyo

Regional Partners Frank Debets +65 6236 7302 [email protected]

Susan Ju +86 (10) 6533 3319 [email protected]

Colbert Lam +852 2289 3323 [email protected]

Derek Lee +852 2289 3329 [email protected]

Damon Paling +86 (21) 6123 2877 [email protected]

Paul Sumner +66 (2) 344 1305 [email protected]

Australia Gary Dutton +61 (7) 3257 8783 [email protected]

Cambodia Paul Sumner +66 (2) 344 1305 [email protected]

China

Beijing Susan Ju +86 (10) 6533 3319 [email protected]

Guangzhou Harry Zhang +86 (20) 3819 2369 [email protected]

Hong Kong Derek Lee +852 2289 3329 [email protected]

Shanghai Damon Paling +86 (21) 2323 2877 [email protected]

Shenzhen Colbert Lam +852 2289 3323 [email protected]

India Nitin Vijaivergia +91 (0) 982 023 9915 [email protected]

Indonesia Enna Budiman +62 (21) 5289 0734 [email protected]

Japan Naoyuki Kano +81 (3) 5251 2839 [email protected]

Korea Hyung-Kwan (Harris) Yu +86 (21) 2323 1195 [email protected]

Rosa An +82 (2) 709 8916 [email protected]

Laos Paul Sumner +66 (2) 344 1305 [email protected]

Malaysia Shi Yang Huang +60 (3) 2173 1657 [email protected]

Myanmar Gregory Nichols +65 6236 7333 [email protected]

New Zealand Eugen Trombitas +64 (9) 355 8686 [email protected]

Pakistan Syed Shabbar Zaidi +92 (21) 2413 849 [email protected]

Philippines Alex Saborio +63 (2) 459 2005 [email protected]

Singapore Gregory Nichols +65 6236 7333 [email protected]

Taiwan Jay Lin +886 (2) 2729 6666 Ext. 23800 [email protected]

Thailand Paul Sumner +66 (2) 344 1305 [email protected]

Vietnam Nguyen Hong Son +84 (8) 3823 0796 Ext.1509 [email protected]

Wider Europe Leader Ruud Tusveld +31 (10) 4075 500 Ext. 669 [email protected]

Americas Leader Domenick Gambardella +1 (646) 471 3791 [email protected]

Contact detailsWorldtrade Management Services (WMS) is the global customs and international trade consulting practice of PwC. WMS has been in Asia since 1992 and is a regionally integrated team of fulltime specialists operating in every location. Our team is a blend of Asian nationals and expatriates with a variety of backgrounds, including ex-senior government officials, customs officers, international trade lawyers, accountants, and specialists from the private sector who have experience in logistics, customs and international trade.

PwC–Globally PwC firms provide industry-focused assurance, tax andadvisory services to enhance value for their clients. More than 180,000 people in 158 countries in firms across the PwC network share their thinking, experience and solutions to develop fresh perspectives and practical advice.

The information contained in this article is of a general nature only. It is not meant to be comprehensive and does not constitute the rendering of legal, tax or other professional advice or service by PricewaterhouseCoopers WMS Pte Ltd (“PwC”). PwC has no obligation to update the information as law and practices change. The application and impact of laws can vary widely based on the specific facts involved. Before taking any action, please ensure that you obtain advice specific to your circumstances from your usual PwC client service team or your other advisers.

The materials contained in this article were assembled in March andApril 2014 and were based on the law enforceable and information available at that time. © 2014 PricewaterhouseCoopers WMS Pte Ltd. All rights reserved. “PricewaterhouseCoopers” and “PwC” refer to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firm’s professional judgment or bind another member firm or PwCIL in any way.

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