II While MPs pontificate about sovereignty and subsidiarity, the EC
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is steadily moving towards its main goal of free trade in a single market. Apart from anti-drugs and smuggling spot checks the customs barriers will finally come down on 1 January. In place of import entries to customs, traders will be responsible for paying VAT through periodic returns and, where appropriate, will have to supply statistical data under the EC's new Intrastat" scheme.
The road to the Single European Market has not been a smooth one, and it is possible that some documentary requirements will linger on into the new year. There are also changes to some of the regulations governing goods travelling overland through the EC to non-EC countries.
The biggest area of uncertainty lies with the EC's plans to abolish the current Common Agricultural Policy (CAP). The Monetary Compensatory Amounts — payments to farmers to bring prices for agricultural goods in line with those ordained by the CAP subsidies — are administered through import and export customs entries. This means that failing to abolish the CAP would leave European customs authorities and agricultural hauliers with a serious problem as there would no longer be a customs presence at major ports to operate the system. Legislation was expected this year, but HM Customs does not expect to receive details until later this month.
EXTRA DUTIES
Similarly, there has been no confirmation that the extra duties still imposed on some (mainly agricultural) Spanish and Portuguese commodities will be removed in time for 1 January. The Single Administrative Document (SAD) and the internal Community Transit (CT) procedure using the T2 ES and T2 PT documents will probably remain in force for some commodities from these two countries. Neither becomes a full EC member until 1995.
Operators carrying goods into the EC from the Channel Islands should note that the full SAD and CT procedure will still be in force. This could also apply to other small territories such as the Canary Islands if they lie outside the EC's fiscal territory, but the T2 will not be needed for goods moving between the Channel Islands and the UK. A similar simplification agreement is being considered for goods moving between the islands and France. But for the foreseeable future goods moving between the Channel Islands and other EC states, whether direct or via the UK, will require a 12.
The CT procedure will also be needed for EC goods crossing a European Free Trade Association (EFTA) country in between two EC states. The six EFTA members are Austria, Finland, Iceland, Norway, Sweden and Switzerland. So, for example, a T2 form would be needed for a run from Italy to the UK via Austria or Switzerland. In theory it would be possible for hauliers to take out the necessary documentation anywhere en route but customs authorities are urging operators to use offices afvay from the EC/EFTA borders to keep congestion to a minimum.
Further clarification is still being sought by the British authorities on the documentary requirements for traffic moving from within the EC to an EFTA country. HM Customs argues that a T2 is unnecessary for a movement of this kind, but operators should assume that this document will be needed, along with the EUR1 movement certificate, until further notice.
LOCAL CUSTOMS
Like trans-EFTA operators, exporters of goods from the UK to non-EC countries overland — from Britain to Poland via Germany, for example — are being urged by HM Customs to initiate export Single Administrative Documents at their local customs office rather than at the EC's external frontier. This will reduce congestion at busy ferry ports such as Dover and will simplify statistical collection. The EC is finalising proposals which would establish the concept of Offices of Export where export documents would be presented and authenticated, and Offices of Exit where the goods leave EC territory.
One copy of the SAD will be carried with the goods for presentation to customs at the Office of Exit. It is not yet clear if the Office of Exit will also have to give a certificate of shipment to the driver or agent as evidence of export for VAT purposes.
In theory there would be nothing to stop goods being loaded on a truck in the UK and taken across the Community to the EC's external frontier. But the driver would have to fill out an SAD himself or find an agent to do so for him. While HM Customs recognises that there could be circumstances in which customs formalities would have to be carried out on the external border (for example when goods originally destined for another EC state are diverted to a third country while en route) the UK authorities hope that this will be the exception rather than the rule.
Airfreight truckers and hauliers carrying consolidated cargo where EC and third-country goods could be mixed on the same vehicle should note that the proposed Community Transit Simplified Procedures applies only to cargo carried on ships and aircraft — not to road movements.
Customs control will also apply to goods moving within the EC which are not in free circulation on which VAT and duty has not been secured, At present such movements are governed by national transit procedures using the C548, C44, C44A and C44B procedures, but these are to be brought into line with the EC-wide CT procedures. Movements will be controlled by SADs, with copies 1, 4 and 5 presented to customs at the place of despatch, and copies 4 and 5 carried with the goods and presented to customs at their destination within the UK to complete the movement. As with existing national transit procedures, it is possible that undertakings rather than guarantees of security will be accepted. No major changes are planned to the ACP90 procedures for air freight or to the simplified procedures for low-value express parcels moving by road.
CT PROCEDURE
Goods imported into the EC duty-free under the Inward Processing Relief (IPR) scheme, on the understanding that they are to be used in the manufacture of EC goods and re-exported outside the Community, will continue to be subject to the full CT procedure and will require the Ti form, at least for the time being. In time it might be replaced with a three-part SAD when goods are moved between EC traders. Also traders' records could be used for control purposes.
Excise goods and goods subject to Ministry of Agriculture, Fisheries and Foods (MAFF) inspection will be treated slightly differently from other goods. Alcohol and tobacco, will be handled by a UK network of up to 4,000 registered dealers and shippers (REDS). Goods will move in an EC-wide network of REDS tax warehouses, in most cases under duty deferment. REDS and shippers will be able to move goods on their own account or on behalf of other traders; in the case of the traders they will need to guarantee duty at their local excise office and provide the REDS warehouse keeper in the exporting country with a registration number before the goods are released.
As with the new VAT arrangements, excise duty will be paid periodically rather than at the point of import. A four-part document will accompany the goods, and vehicles or packages must be suitably sealed.
MAFF goods will be required to pass through one of 54 locations which will be retained as official border inspection posts after 1 January. As these include most of the major sea and airports, operators should be able to continue existing operations.
The MAFF envisages that most items will be subject only to documentary checks. All physical examinations apart from those for preventative purposes would be carried out at traders'
premises.
0 by Chris Lewis