Even if the document makes it to the destination, further delays can still occur. The customs inspector examines all the requirements such as the legibility and the authenticity of the signature and the stamp. He or she may reject the goods if the document contains spelling mistakes or the watermark has been damaged. If the COO is not provided on time, so-called compensatory anti-dumping payments are incurred in addition to the regular customs duties. It may be possible to reclaim these costs at a later date, but the refund can normally take up to 12 months. Once the goods finally arrive at the customer’s site, the company risks a complaint because it has failed to comply with the delivery date.
The enormous time and financial expenditure related to COO logistics could be reduced by introducing digital customs clearance. A pilot project being organised by the German-Russian Chamber of Foreign Trade is called the Green Customs Channel. With the aim of having a cross-border electronic flow of documents, the current export declaration procedure used by European customs authorities is transferred to the Russian import customs procedure. However, there is a challenge here: the Eurasian Economic Union (EAEU) regulates the current legal basis for customs clearance in Russia, Belarus, Kazakhstan, Kyrgyzstan and Armenia. According to Decision No. 49, it accepts electronically issued certificates of origin, but only with certain restrictions. The Chamber of Commerce must give the responsible customs inspector access to the database. This enables him or her to ensure that the certificate was actually issued and whether it contains all the necessary information.
Some complications still occur with this method in practical situations. If the goods come from a different country than the exporting nation, this needs to be clearly visible on the COO and proven by an invoice or declaration from the country of origin. If this information exceeds the space that provided for writing in the document, complications may arise. It is then necessary to confirm that the remaining attachments are part of the same certificate. The Russian customs authorities do not automatically link any additional pages to the first electronic document.
Belgium provides a best practice example. The Chamber of Commerce there already provides a software tool with direct access via an online login. All the necessary documents such as invoices, packaging lists or original COOs can be easily uploaded to the portal. The company only has to have them digitally signed and can then use the documents for exports to Russia.
The basic idea behind the Green Customs Channel is to use a digital signature when sending COOs to the responsible customs authorities. This works in the following way in practice, based on the example of a Russian export: if a Russian company would like to export goods to the European Union, it first sends the export customs declaration to the Russian customs service. The customs service authorises the declaration and sends it back to the company. The declaration with the digital signature is then sent to a customs representative, e.g. a specialist logistics services provider. Its agency services are mandatory as the German and Russian customs authorities are not permitted to communicate with each other directly. After this, the declaration is forwarded to the third trustworthy party, the information integrator. This party checks the integrity and issues the acknowledgement of its assessment. The officially recognised customs representative in Europe transfers this export declaration together with the digital signature and acknowledgement to the European customs authorities. In the meantime, the truck travels from Russia to the border and the destination point, the customs clearance office. The moment the truck crosses the border from Belarus to Poland, the original customs terminal sends the data to the border customs point. The border customs point confirms that the truck has physically left the territory of the EAEU.
Digitalised customs clearance accelerates the whole process. Steps involving a great deal of work and other delays caused by human errors related to COO logistics are then a thing of the past. The flow of documents takes place within the central system and, as a result, it is possible to make savings in terms of the costs for logistics and storage. The complete process is also paperless and more transparent: the customs authorities have immediate access to the information that they need. This enables faster trading practices, which in turn generates higher customs duty payments for the importing country. Both trading partners benefit from the advantages of a digital solution.
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