Customs & International Trade issues and trends
Control and Risk Management
The profile of customs duty within businesses has been raised significantly as a result of a number of initiatives that have a common theme, namely control and risk management. The majority of businesses use third party freight forwarders to complete customs declarations for them and there is frequently a lack of control over this process in terms of the business providing written guidance to the freight forwarder on how to complete the declarations and/or reviewing declarations to ensure there are no errors. The new Senior Accounting Officer regulations in the UK, the requirement for business to reapply for simplifications such as CFSP by this year and AEO accreditation all require businesses to demonstrate they have robust controls in place for customs duties to ensure that their imports are processed correctly. This involves having comprehensive written customs/import procedures including internal manuals, standing instructions for freight forwarders and providing staff responsible for this area with the tools to perform their duties effectively. This includes training and access to specialist information.
We can assist businesses in this area by helping them implement a suitable framework and provide written procedures and training for staff.
It is fair to say that the number of AEO applications within the EU has not met with the European Commission’s expectations. Initial views from business were that there were insufficient tangible benefits to justify the investment in the application process in terms of resource and cost. Over the past 6 months however there has been a notable change with many businesses recognising the benefit of beginning work on the application process, either as a result of coming under commercial pressure from within their supply chains or in bid situations, or because they appreciate that the application and audit process is a lengthy one. The European Commission is examining ways of incentivising businesses to apply by removing the requirement for costly financial guarantees in certain situations. Similarly progress is being made globally with mutual recognition initiatives which means the various supply chain security regimes including AEO will be mutually recognised. This should mean goods can move more freely worldwide as the accreditation demonstrates an appropriate level of security.
We can provide a wide variety of support in relation to AEO readiness ranging from initial stakeholder workshops, gap analysis and remediation work to full end to end support in preparing and submitting the application and dealing with audit queries.