Revision of the Union Customs Code

The Federation of Small Businesses (FSB) is a non-profit making, grassroots and non-party political business organisation that represents members in every community across the UK. Set up in 1974, we are the authoritative voice on policy issues affecting the UKs 5.5 million small businesses, micro businesses and the self-employed.

The Confederation of Enterprises is an advocate of employers’ companies operating in Finland. We communicate industry’s common messages and solutions to society’s decision-makers and public debate. We are a comprehensive representative of the entire Finnish business community: we have more than 15000 member companies, with around 900000 employees. The Confederation of Businesses (EK) supports the proposal.

Filed in Finnish · English published by the European Commission

EY appreciates the opportunity to submit comments on behalf of the EY network on the European Commissions call for feedback on the proposals put forward by the Commission on 17 May 2023 to reform the EU Customs Union.

Dear Title, I would ask for a revision of the wording of Article 47. In our Member State, customs obliges economic operators to use seals in normal transit, while in other Member States the authorities are more lenient.

Filed in Hungarian · English published by the European Commission

Dear Title, I would ask for a revision of Article 71(2) as there are many reasons for invalidating the various declarations, there may be circumstances that the economic operator/declarant cannot and unfortunately be bound by the relevant Regulation.

Filed in Hungarian · English published by the European Commission

Dear Title, I would ask for a revision of Article 86(5). The 3 days indicated and 6 days for authorised consignees are inapplicable in practice. This will force various service providers to apply for customs warehouse authorisations. If simplification is to be achieved, this is not the best way forward.

Filed in Hungarian · English published by the European Commission

The Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to provide our views on the Proposal for a Regulation of the European Parliament and of the Council establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013.

Inditex welcomes the opportunity to contribute our views on the European Commission's proposal to revise the Union Customs Code. Our contribution aims to improve the protection of the EU Single Market and facilitate trade. Please see our feedback in the attached document.

The Office for Development through Automation and Simplification of External Trade is an Association Loi 1901 set up in July 1972 by private sector managers with the support of the Directorate-General for Customs and Indirect Taxes. With around 300 members, we represent more than 500 companies, groups, organisations or natural persons active in the field of international trade.

Filed in French · English published by the European Commission

Please find attached the PostEurop Position on the EU Customs Reform of 7 November 2023, contributing to the legislative deliberations on: The Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013 [COM (2023) 258 final]; and The Proposal for a COUNCIL REGULATION amending…

The Dutch business community embraces the simplifications introduced by the European Commission in the proposal for the New UCC. Based on a data-led approach the reform can reduce cumbersome customs procedures, reducing 27 systems to just one harmonized model.

The European Smoking Tobacco Association (ESTA) appreciates the opportunity to provide views on the European Commission's proposal for an EU Customs Reform. Whilst ESTA welcomes the general direction that the proposed reform is aiming at, we have attached comments and suggestions that we hope the European Commission will take into consideration.

Dear Sir, on behalf of the Digital Polish Union, a professional employers’ organisation which brings together the largest high-tech companies operating in Poland, including producers, importers and distributors of electrical and electronic equipment, we submit our comments to the Consultation on the Communication of the European Commission on Customs Reform.

Filed in Polish · English published by the European Commission

EUROALLIAGES welcomes the opportunity to provide comments to the European Commission proposed Regulation establishing the Union Customs Code and the European Union Customs Authority and repealing Regulation (EU) No 952/2013 (hereinafter the Revised UCC Proposal).

The German Chamber of Commerce and Industry (DIHK) would like to thank you for the opportunity to comment on this proposal for a Regulation. The opinion is based on the comments received by the DIHK, companies and the DIHK’s economic policy positions prior to the submission of the opinion. You can find the detailed feedback in the attached file.

Filed in German · English published by the European Commission

SOMO appreciates the opportunity for providing feedback on the Commissions proposal for a new Union Customs Code. EU supply chains need to become much more transparent to effectively address the abuses they are fraught with. EU customs law reforms can substantially contribute to supply chain transparency.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) welcomes the opportunity to comment on the revision of the Customs Union Code. EFPIA represents the biopharmaceutical industry in Europe. Please find an explanation of our position attached. EFPIA supports the objectives of the revision and wishes to highlight a few elements that require further explanation.

The European Community Shipowners Associations (ECSA) represents 20 national shipowners associations based in the EU and Norway. European shipowners control 39.5% of the global commercial fleet, contribute annually 149 billion euros to the EU GDP and provide 2 million people with careers both on board and ashore.

AEGIS Europe appreciates the opportunity to provide comments to the European Commission proposed Regulation establishing the Union Customs Code and the European Union Customs Authority and repealing Regulation (EU) No 952/2013 (hereinafter the Revised UCC Proposal).

The International Trademark Association (INTA) would like to thank the European Commission for the opportunity to provide comments on the reform of the Union Customs legislation. INTA previously provided feedback in this file on the public consultation. In the attached document you can find more specific comments on the Commission's proposal, with a focus on the defense of intellectual property rights and consumers.

AVE and its Members appreciate the opportunity to provide further feedback on the Revision of the Union Customs Code, complementing our previous remarks in this regard. We would like to take this opportunity to highlight some of the key parameters which essentially need to be addressed with any reform resp. revision of the Union Customs Code and thank you for considering the following.

An Post Position Include the word all in Article. 2 sub-section (e) of COM (2023) 258 as follows: (e) supporting [all] legitimate business activity, by maintaining a proper balance between customs controls and facilitation of legitimate trade and simplifying customs processes and procedures.

H&M Group welcomes the opportunity to provide feedback on the European Commission's proposal for a revised Union Customs Code (UCC). This proposal strengthens the legal framework for customs and makes it suitable to address recent challenges.

IKEA strongly support the EU Commissions proposal for the revision of the Union Customs Code (UCC) aiming to simplify, digitalize, and modernize the customs procedures and welcomes the opportunity to provide feedback. The EUs customs union plays an important role in establishing a predictable and responsive customs environment especially for companies like IKEA with vast EU and international operations.

As a major player in cross-border trade, La Poste Groupe is particularly sensitive to customs issues, which may have a major impact on its international business model. The proposed UCC reform project is extremely ambitious and fully supported by La Poste Groupe in its objectives to make the single market more efficient.

Filed in French · English published by the European Commission

EuroCommerce believes the timing for launching the Customs Reform Package is an exceptional and pivotal moment for the EU Single Market and businesses operating within it. The tone of the reform package is both ambitious and aspirational and advocates fundamental change. But such change must fundamentally enhance the current situation for all stakeholders.

Unifab (Union des Fabricants) is the French association for the promotion and defense of intellectual property (IP) rights. Founded in 1872 by a group of pharmacists, it is now composed of approximatively 200 member companies and professional federations from all sizes and all sectors of activity thus representing an annual turnover of 1450 billion euros.

We welcome the opportunity to share feedback on the package recently brought forward by the Commission, composed of a proposal for a new Regulation on the Union Customs Code, EU Customs Data Hub and EU Customs Authority, a proposal for amending the Regulation on the system of reliefs from customs duty and the tariff and statistical nomenclature, and a proposal for amending the VAT Directive on its provisions related…

For several years, the Veblen Institute has been making proposals for a reform of European trade policy. Access to the European market should be used more as a lever for the green transition and the achievement of the ambitious objectives of the European Green Deal.

Filed in French · English published by the European Commission

We would like to thank you for the opportunity to comment. In principle, we welcome the fact that the EU modernises its customs system and adapts it to the evolution of e-commerce by aligning it with the system of import VAT.

Filed in German · English published by the European Commission

See the document below for our feedback. Topics discussed are: Importers/exporters and Trust & Check (T&C) Trader status, Involvement of customs representatives, The shift of the place of importation, Non fiscal legislation/obligations, Temporary storage.

A4E welcomes the opportunity to comment on the Commission proposals presented by the European Commission on 17 May 2023, which outline significant reforms to the Union Customs Code and related legislation. These reforms aim to address the shortcomings of the current legislation and improve the efficiency and effectiveness of customs procedures within the European Union (EU).

Plastics Recyclers Europe welcomes the ECs initiative to revise the Union Custom Code (UCC) as an opportunity to create a level playing field between the EU industry and global economic partners. Please find attached a paper detailing our position on this initiative. PRE remains available to further discuss the elements included in this paper with the relevant policy officers at DG TAXUD

We would like to thank the European Commission for this important proposal for a regulation and for the opportunity to comment. European customs authorities play an essential role in protecting affected businesses and consumers from counterfeiting and piracy. Under the border seizure procedure, large quantities of counterfeit goods can be withdrawn every day before entering the European market.

Filed in German · English published by the European Commission

The National Chamber of Commerce (KIG), the largest organisation representing the small and medium-sized enterprise sector in Poland, is closely analysing the European Commission’s proposals for the reform of the European Union (EU) Customs Union.

Filed in Polish · English published by the European Commission

The AIM Anti-Counterfeiting Committee thanks the Commission for the opportunity to comment on this extremely important proposal. In order to protect our consumers, creators, innovators, economies and environment, European intellectual property right holders are actively engaged in the global fight against counterfeiting and piracy, in which customs are an essential partner.

Regarding the "Trust & Check" economic operators, our member companies consider the certification process to be extremely complex. Accordingly, it is essential to simplify the process as much as possible. When developing the "Trust & Check" trader mechanism, the European Commission should pay special attention to the Special Report 13/2023 of the European Court of Auditors: "Authorized Economic Operators - A solid…

Bitkom welcomes the reform of the UCC as it has the potential to deliver a more efficient, secure and business-friendly Customs Union. However, achieving this goal will require a common interpretation of the UCC by Member States and the actual implementation of various proposed improved customs mechanisms.

UFE view on the Revision of the Union Customs Code Ever since our foundation in 1963 The Union of Finance Personnel in Europe (UFE) has been the only organisation representing the trade union interests of employees from all ranks and grades of the tax and customs administration authorities of Europe. UFE brings together more than 400,000 members from 40 member unions in more than 20 countries.

The Alliance du Commerce, a professional organisation, represents department stores, popular shops and clothing and shoe brands, representing more than 170 000 employees and 27000 sales outlets in France. Companies in the sector have expressed serious concerns about the draft regulation and the extremely serious financial consequences it will generate.

Filed in French · English published by the European Commission

DIGITALEUROPE supports the objectives of this ambitious reform and the aim of modernising the Union Customs Code in the wake of structural changes induced by the digitalisation of trade and of business models. We also welcome the proposed improvements for a coherent and uniform interpretation of the Code, as well as reformed mechanisms striving for enhanced trade facilitation for economic operators.

EEA would like to express our appreciation for the proposals presented by the European Commission on 17 May 2023, which outline significant reforms to the Union Customs Code and related legislation. These reforms aim to address the shortcomings of the current legislation and improve the efficiency and effectiveness of customs procedures within the European Union (EU).

While the EU Commissions proposed reforms to the Union Customs Code, such as the introduction of the European Customs Authority, the EU Customs Data Hub and the Trust and Check trader status demonstrate a commitment to improving customs procedures and trade facilitation, there are several aspects that should be further refined.

BusinessEuropes views on Union Customs Code Reform Key Messages: 1. EU Customs are subject to increasing pressures from enormous e-commerce volumes to ever-growing non-financial measures. The UCC reform is therefore more urgent than ever. BusinessEurope fully supports this reform, which is crucially needed.

DHL Group welcomes the opportunity to comment on the Commission proposals to reform the EU Customs Union. The input from companies in the logistics sector such as DHL Group is critical. As we continue to cooperate on the IT developments under the current Union Customs Code (UCC) implementation, which is still ongoing, we need to contribute at the earliest possible stage to this proposed fundamental and wide-ranging…

Good Day, I would like to ask whether the reform of the Union Customs Code will continue to allow goods to be imported into the European Union by a company registered in a third country represented by a direct representative established in a Member State, who will act as an importer in this case?

Filed in Polish · English published by the European Commission

CONFIAD welcomes the efforts of the European Commission to modernize the Union Customs Code with the ultimate goal of making procedures simpler and more efficient. CONFIAD also welcomes the establishment of the EU Customs Authority, which should ensure the uniform application and interpretation of the EUs customs law.

Ecommerce Europe welcomes the opportunity to provide feedback on the European Commissions proposal for a revision of the Union Customs Code (UCC). This proposal is a clear step forward to strengthening the legal framework for customs and to making it suitable to address the challenges that have emerged in recent years.

TLF Overseas is the professional organisation comprising freight forwarders and French registered customs representatives. Our member companies organise 85 % of maritime transport and 90 % of air freight flows in France. Customs representatives carry out around 85 % of customs clearance operations in France and the overseas departments.

Filed in French · English published by the European Commission

Tobacco Europe AISBL represents the common views of major Europeanbased tobacco and nicotine products manufacturers which includes British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI).

The Ecommerce Forum of Africa (EFA), a not-for-profit association representing ecommerce in Africa, is extremely concerned that the Reform of the Customs Code will scrap the de minimis rule. This will adversely affect African SMMEs which sell low value quality goods online to EU customers. Presently, these small entrepreneurs can send parcels of up to the value of 150 Euro without paying customs duties.

The European Consumer Organisation (BEUC) thanks the European Commission for the ability to provide feedback on this important reform. BEUC represents 45 independent consumer organisations from 31 European countries in Brussels and defends the interests of consumers. Our acronym comes from our French name, Bureau Européen des Unions de Consommateurs. BEUC wants consumers to be protected in a global market.

Allegro is one of the leading e-commerce platform in Central and Eastern Europe. We are pleased to share with you our position paper on the EU Customs Reform, which outlines our views and some of the key challenges that we would face as an online marketplace operating across the EU single market in the light of the proposed reform.

In connection with the work of the European Commission on the reforms of the EU Customs Code, we would like to provide an opinion. We also Attach a report from a survey conducted among our members on the impact of the above reforms on the activities of entrepreneurs. The position papers is attached below.

Filed in Polish · English published by the European Commission

Decision of the General Assembly of the Rhine-Neckar CCI of 13.09.23 First priority: Competitiveness of European businesses The draft EU Customs Code mentions the competitiveness of European businesses only to a very limited extent than the latter objective. Instead, priority is given, for example, to generate revenue and implement other EU policy objectives.

Filed in German · English published by the European Commission

Finnwatch would like to thank the Commission for the opportunity to provide feedback on the Commission proposal for a regulation establishing the Union Customs Code and the European Union Customs Authority (and repealing the existing UCC).

The food industry is the third largest industry in Germany, implementing every third euro abroad. With a share of over 70 %, the food industry exports most of its products to the European internal market. It offers unique advantages for the export of food: Duty-free, mostly harmonised rules and standards, and short transport distances.

Filed in German · English published by the European Commission

Ecommerce Europe welcomes the opportunity to provide feedback on the European Commissions proposal for a revision of the Union Customs Code (UCC). This proposal is a clear step forward to strengthening the legal framework for customs and to making it suitable to address the challenges that have emerged in recent years.

Dear, please find in attachment a proposal from Belgian Offshore platform and Elia related to the customs formalities for offshore wind farms in the EEZ. Thank you for the opportunity to provide feedback and your consideration of our proposal. Kind regards, [name removed]

The BDSI welcomes the envisaged changes and measures in the framework of the EU’s customs reform. At the same time, however, the interests of exporting medium-sized enterprises and SMEs in particular must also be put at the centre of the reform. The aim of the EU customs reform is very much motivated by the simplification of administrative processes.

Filed in German · English published by the European Commission

The European Association for Automotive Suppliers (CLEPA) fully supports the European Commission Proposal for Regulation COM(2023)258, concerning the Revision of the Union Customs Code. We recognise the reforms potential to facilitate trade, reduce costs and improve market surveillance through enhanced risk management.

HAROPA PORT brings together the ports of Le Havre, Rouen and Paris to form the ‘Grand fluvio-maritime port de laxe Seine’. Fourth North European Port. It serves a large hinterland, the heart of which lies on the Seine Valley and the Paris region, which form the largest consumption basin in France.

Filed in French · English published by the European Commission

On behalf of SPECTARIS, the German Industry Association for Optics, Photonics, Analytics and Medical Engineering, we would like to take part in the discussion on the planned EU customs reform. We would like to send you some comments and requests from our side. Trust & Check Trader and existing authorisations: The discourse speaks of a trust & check trader.

Filed in German · English published by the European Commission

After reading the elements in this ambitious document on the revision of the Customs Code, we can only see that it is unworkable in a Europe that destroys its public service. We (Europe) will only be able to fight and have strong customs with a strong public service. In order to do so, every European citizen must make a contribution commensurate with his or her resources to a collective leffort, which is limited.

Filed in French · English published by the European Commission

To to the kind attention of Commission, INDICAM (Italian Association for the protection of intellectual property) thanks the Commission for the opportunity to comment on this extremely important proposal. Please, find attached the document with our comments on the proposed Reform of the UCC. Thank you for your attention, Juna Shehu - General Director

Born Free welcomes the opportunity to provide feedback on the revised Union Customs Code. Our organisation has a long history working on wildlife trade and trafficking and we believe Member States Customs authorities play a central role in the regulation and control of wild animals and wildlife products that enter, circulate within and are exported from the EU.

The reuse, refurbished and repair sector needs to limit the sell of unfair and foreigners company thanks Marketplaces. Indeed a lot of foreigners (out of EU) company sell products thanks to Marketplace without paiement of VAT, ECOCONTRIBUTION, COPYRIGHT LEVIS. We need to define real rules for Marketplaces to oblige ecommerce vendors to respect the local and fiscal laws.

The APRAM (Association of Praticians of Trade Mark and Models Law) is a French-speaking international association of specialists in industrial and intellectual property. It brings together the three families in the world of IP: In-house lawyers, lawyers, industrial property councils, who give it strength, creativity and openness to an ever-changing world for the greatest benefit of its members.

Filed in French · English published by the European Commission

For Clean Clothes Campaign, transparency in global supply chains, including on customs data, is crucial to investigate human rights abuses in international supply chains, monitor companies' practices and facilitate remedies for victims.

The Association of Employers Business and Science Poland (USP) brings together actors from various sectors of the economy, including mining, fuel, energy, air, postal, financial, food and chemical transport. The main objectives and policy options of the planned reform of the EU customs regulations identify areas that are clearly relevant for the activity and functioning of the EU market for fuels and chemical…

Filed in Polish · English published by the European Commission

UNIFAB is the French association for the promotion and the protection of intellectual property rights (IPRs). Today, the association represents more than 200 French, European and International companies as well as professional federations from various sizes and all sectors of activity; and serves as a unique guardian of IPRs of its members, standing as a platform for discussions on this topic.

As the Commission points out, there is a high risk that current customs rules will pose a challenge in enforcing future EU law. One risk can be averted if Art 12 UCC is amended to ensure that customs data is not by default confidential and can be publicly disclosed.

CINOA welcomes the opportunity to provide comments to this call for evidence on the revision the Union Customs Code. We understand the available custom’s capacities of Member States are limited yet more than 350 pieces of EU legislation covering a wide range of diverse policy areas, such as product safety, environmental protection, climate change, intellectual property rights, dual use goods, protection of human and…

In te Call for evidence for an impact assessment on the Reform of the Union customs legislation, the European Commission points out multiple shortcomings of the existent legal frameworks as well the as their potential regarding human rights and environmental protection.

TIE recognises the problems listed in the call for evidence and wishes to share a number of suggestions to tackle the challenges faced. Simplification: - Strengthen the EU AEO programme: By fostering process-based controls and centralised clearance for trusted traders.

Imperial Brands PLC (IMB) is a FTSE 100 company headquartered in the UK with a significant presence in the EU and is the parent company of a dynamic international business specialising in tobacco and non-tobacco products. We welcome the opportunity to contribute to this call for evidence. Below is a summary of our submission.

With close link to the evaluation of the UCC and pathing the way for the upcoming changes in the EU Customs Union (CU), the European Express Association (EEA) notes with interest the publication of the report of The Wise Persons Group on Challenges Facing the Customs Union (WPG), which has the objective to feed into a wide, inter-institutional debate on the future of the EU CU.

I request a revision of Articles 192, 226(3)(a) and 227(2)(a) UCC) and Articles 299 and 302 of Regulation 2015/2447 V. In our Member State, the customs authority obliges economic operators to use seals, while in my view these articles would refer to the facilitation of economic operators if they use a sufficiently precise description of the goods in their submissions.

Filed in Hungarian · English published by the European Commission

I request a revision of Article 174 UCC. There may be quite many reasons for invalidating the various declarations, there may be circumstances that cannot be done by the economic operator/declarant and unfortunately the hands of the customs authority are bound by the relevant regulation and the corresponding Article 148 of Regulation 2015/2446.

Filed in Hungarian · English published by the European Commission

The EIG France PCS brings together the two French leaders in digitalisation and logistics and port facilitation, with over 35 years of expertise. 95 % of French national freight transits in the information systems deployed by the members of France PCS. France PCS works closely with IPCSA, the International Association of Port Community Systems.

Filed in French · English published by the European Commission

Ecommerce Europe welcomes the EU’s ambition to make customs smarter, more data centric, fit for the twin digital and green transitions. We strongly believe we have a shared interest with the EU to make customs processes and controls more efficient and harmonised as this reduces the costs and time to process imports, facilitates international cross-border trade and minimises delivery delays and unexpected costs for…

CIRFS believes that non-compliant imports are today more than ever an imminent threat to EU-industry. Unfair competition arises for our industry not only from non-compliant man-made fibres that are directly delivered into the EU but also from all non-compliant products along the downstream value chains, such as automotives or textile, that are manufactured from/with third country fibres and brought into the EU…

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the reform of the Union customs legislation as an opportunity to bridge several EU policies while ensuring a playing level field for all products being placed on the Single Market.

The Latvian Ministry of Finance and Customs Administration would like to thank the European Commission for participating in the public consultation and providing feedback on the reform of Union customs legislation. Our comments can be found in the attached document.

Filed in Latvian · English published by the European Commission

AEGIS Europe welcomes the opportunity to give feedback on the Revision of the Union Customs Code. An industry alliance representing over 20 key industries, including bikes, ships, railroad engines, steel and aluminum that promotes manufacturing investment, innovation, jobs and growth for a strong Europe.

We thank the European Commission for this initiative. Our feedback reflects the views and experiences of our member companies and refers only to the remit of protecting intellectual property rights, in particular in the context of the border seizure procedure.

Filed in German · English published by the European Commission

EUROALLIAGES welcomes the opportunity to give feedback on the Revision of the Union Customs Code. EUROALLIAGES is the association representing European ferro-alloys and silicon producers. Its objective is to promote a safe, environmentally friendly and competitive production of ferro-alloys and silicon in Europe.

BAT welcomes the opportunity to contribute to the call for evidence request and would like to present several near-term solutions that follow the guiding principles of a collaborative mindset across jurisdictions and organisational siloes, common standards, interoperability between systems, a data-driven culture, and flexibility to learn and adapt.

In its Call for evidence for an impact assessment on the Reform of the Union customs legislation , the European Commission points out multiple shortcomings of the existent legal frameworks as well the as their potential regarding human rights and environmental protection. The role of customs authorities is crucial in identifying non-compliant products at the border to protect citizen’s interest.

The German Trade Association — HDE e.V. thanks the European Commission for the opportunity to comment on the planned revision of the EU Customs Code. Please find enclosed our detailed feedback on what we consider important.

Filed in German · English published by the European Commission

Please see attached the World Shipping Council's full Response. In summary: Taking the Customs Union to the next level as pledged by President Von der Leyen, should equip the EU to better withstand present and future challenges, while protecting its citizens and harnessing the economic opportunities of the 21st century. However, the unfinished buisness of impementing the UCC must be prioritised.

Allegro wants to thank the European Commission for the opportunity to contribute to helping take the EU Customs Union to the next level. As an EU based e-commerce platform, want to support the European Commission in its attempt to review the EU customs rules with a special focus on e-commerce.

The reform of the Union Customs legislation presents a timely and excellent opportunity to modernise EU Customs, to stay fit for purpose in a rapidly changing international trade environment. It is especially important that this revision helps with harmonising the application of UCC across Member States as well as restoring the balance between customs obligations and simplifications for business.

Efficient international logistics requires high-performance customs clearance which adapts to rapidly evolving consumption patterns. Pending the desirable establishment of a European Customs Agency, customs formalities must be standardised within Europe, in particular to facilitate cross-border e-commerce. We therefore welcome the European Commission’s intention to reform EU customs legislation in principle.

Filed in German · English published by the European Commission

The VELUX Group welcomes the opportunity to comment on the European Commission’s Call for Evidence for an Impact Assessment on the Reform of the Union customs legislation. In our attached feedback we would like to focus on the need to stipulate clear requirements concerning the signing of invoice declarations, both in the context of reducing varying interpretations by the customs authorities and the digital…

CALL FOR EVIDENCE: REFORM OF THE UNION CUSTOMS LEGISLATION Tobacco Europe AISBL represents the common views of British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI). We appreciate the initiative of the European Commission with respect to the reform of the union customs legislation.

Intellectual property right holders rely on customs officers to target, control and detain shipments of illegal - including counterfeit, sub-standard and non-compliant - goods at the EU’s borders. The AIM Anti-Counterfeiting Committee thanks the EU’s Customs Authorities for their excellent cooperation in fighting this global illegal trade over many years and is grateful to the Commission for consulting European…

EuroCommerce is a unique blend of 5 million companies, from micro-SMEs to renowned global companies in the retail and wholesale sector. Many depend on the smooth import and export of goods or their transit through their supply chains. Members recognise the advances made by the EU Institutions and Member States since the introduction of the Customs Code in 1993.

Born Free welcomes the opportunity to provide feedback. Our organisation has a long history working on wildlife trade and trafficking and we believe Member States’ customs authorities play a central role in the regulation and control of wild animals and wildlife products that enter, circulate within and are exported from the EU.

Please find herewith the feedback of the European Consumer Organisation (BEUC) to this public consultation. BEUC is the umbrella group in Brussels for 46 independent consumer organisations. Our members are from all 27 EU Member States as well as Iceland, North Macedonia, Norway, Switzerland and the United Kingdom. A significant part of household appliances, clothes, toys and food comes from outside of the EU.

Please refer to the attached response to the consultation. I sincerely welcome Line Brendstrup, Secretary [email removed] og www.tekniq.dk Telephone: [phone removed] n.e.c. Direct: [phone removed] Paul Bergsøes Vej 6 af 2600 Glostrup af Billing craftsman 17 af 5230 Odense M Tekniq Employers — Industry, Installation represents 4.100 companies active in electricity, vs and metal with a total of 55.000 employees and a…

Filed in Danish · English published by the European Commission

We, Polish Confederation Lewiatan and our members very much welcome the EU’s ambition to make customs smarter, more data centric, fit for the twin digital and green transitions. We strongly believe we have a shared interest with the EU to make customs processes and controls more efficient and harmonized as this reduces the costs and time to process imports, facilitates international crossborder trade and minimizes…

Thank you for this consultation. Although in the margins of the latter, European beekeepers would like to bring certain points to your attention, in particular in terms of customs code and statistics. Please find attached our contribution. We remain at your disposal.

Filed in French · English published by the European Commission

Medicines for Europe represents the generic, biosimilar and value-added medicines manufacturers in Europe. We welcome the opportunity to contribute to the call for evidence on the future reform of the Union customs legislation. Generic, biosimilar and value-added medicines play a crucial role for patient access to equitable treatments and healthcare sustainability in Europe and globally.

The Community of European Railway and Infrastructure Companies (CER) would like to thank the Commission for this opportunity to provide our views on the Call for Evidence for an Impact Assessment for the Reform of the Union customs legislation.

The European Branded Clothing Alliance (EBCA) welcomes the opportunity to contribute to the European Commission’s Call for Evidence and public consultation on the Revision of the Union Customs Code. EBCA represents some of the biggest global retail clothing brands with a commercial presence in many markets and which process many transactions and shipment volumes across customs points worldwide.

In the Company’s view, the provisions of the UCC legal package are too restrictive because where the risk of incurring a customs debt on goods is low or very low, i.e.: — for temporary (short-term) storage of goods at an approved place, — for the temporary storage of goods in temporary storage facilities, — for the customs warehousing of goods in a customs warehouse securities should not be compulsorily collected.

Filed in Polish · English published by the European Commission

Finnwatch welcomes the planned reform of the UCC and this opportunity to provide feedback. As an NGO that investigates human rights abuses in global supply chains and facilities redress and remedies for victims, we need access to supply chain information. Whereas some pioneering companies are forthcoming with this information, many companies are not.

IPCSA - International Port Community Systems Association would like to thank EU COM for the opportunity to provide the views and further comments and ideas of our industry through this public consultation. We have done this in good conscience. Our members see themselves as a reliable partner in the future of the Customs Union for the upcoming tasks around digitalisation of the supply chain.

ASSUC is the voice of European sugar traders, representing over 60 sugar trading companies across Europe through its membership. ASSUC welcomes the opportunity to provide feedback on the revision of the Union Customs Code and looks forward to the publication of the UCC reform package by the European Commission.

The Association of German Chambers of Commerce and Industry (DIHK) has contributed to this consultation by filling out the related EU-Survey (Contribution ID: a563fa0b-3f0f-43da-9ec7-ce0d8777c9a9 Date: 13/09/2022 11:46:43).

The International Trademark Association (INTA) would like to thank the European Commission for the opportunity to provide feedback on its consultation to the reform of the Union customs legislation. Our detailed comments can be found in the attached document.

Proposal to be considered : implied POA for all customs declarations made by express industry - to be created on UCC level. The concept of implied POA for all e-commerce shipments has been developed under Polish national law. According to art 77a of Polish Customs Law act in the cases referred to in Art.

When crossing the external frontier of the customs territory of the Union, recreational boats must comply with the requirements of the Union Customs Code (UCC). However recreational boats may cross the external frontier of the customs territory of the Union numerous times over the 50 or more year period that they may be in use for.

When crossing the external frontier of the customs territory of the Union, recreational boats must comply with the requirements of the Union Customs Code (UCC). However recreational boats may cross the external frontier of the customs territory of the Union numerous times over the 50 or more year period that they may be in use for.

Master data system for the importer or exporter Proposed addition: The EU must instruct national customs authorities to set up a system of master data that can work with their customs system for import and export.The master data system must be able to automatically transmit the master data to a customs clearance operation created for the same EORI number or an export declaration created for the same EORI number via…

Filed in Danish · English published by the European Commission

UCC CHAPTER 3 — Customs value of goods — Change in freight costs Proposed addition: The EU must charge national customs authorities that “freight cost at EU border” and “freight cost in the EU” can be changed in their customs system Import after the customs declaration has been released for customs purposes.

Filed in Danish · English published by the European Commission

Allocation of freight costs UCC Article 71 — Elements of the transaction value (paragraph 1 (e); and GF Article 138 — Transport costs (paragraph 2). Proposed addition: The EU must lay down rules on how to allocate the transport cost between the ‘cost of freight to the EU border’ and the ‘freight cost in the EU’ of road, maritime and rail transport, following the same principle as the EU has set out the allocation of…

Filed in Danish · English published by the European Commission

Customs courses UCC Article 53 — Conversion of foreign exchange rates and GF Article 146 — Exchange rate conversion when determining the customs value Proposed addition: The EU must instruct national customs authorities that their customs system imports can enter the customs rate itself and convert all the fields of customs clearance from the declared currency into the national currency when actually arriving in the…

Filed in Danish · English published by the European Commission

Freight in customs clearances UCC CHAPTER 3 — Customs value of goods — automatic calculation and allocation of freight costs Proposed addition: The EU must require national customs authorities to include fields for ‘freight cost to EU border’, ‘cost of freight in the EU’, ‘cost of insurance’ and ‘other costs’ (paragraphs 13 to 16 and 20 to 21 of the customs value declaration), as well as their customs system, for…

Filed in Danish · English published by the European Commission

Export or re-export declarations (export declarations) Article 267 UCC — Customs supervision and exit formalities Proposed addition: In the case of transport by road or rail, the carrier or his representative shall send by electronic means all export and/or re-export declarations, together with a summary of the MRNs for the transport operation, to the customs office of exit intended for the transport operation.

Filed in Danish · English published by the European Commission

We are a larger company, with a relatively complete IT environment, we need reasonable time to implement the new Customs Codex. It has been very difficult to get any concrete information about the data and formats in which to communicate, which does not provide us with the best conditions to reach an outward and test of the new system.

Filed in Danish · English published by the European Commission

Article 214 UCC DF Article 178 Accounting requirements Article 214 UCC Accounts 1. Except in the case of the transit procedure or, where otherwise provided, the holder of the authorisation, the holder of the procedure; and all those who carry out an activity involving storage, processing; or the processing of goods or the sale or purchase of goods in free zones; appropriate records in a form approved by the customs…

Filed in Danish · English published by the European Commission

Subject to Article 89 UCC current text: Guarantee for a potential or existing customs debt Article 89 UCC General provisions 2. The customs authorities require a guarantee to be provided for a potential or existing customs debt, this guarantee shall cover import or the amount of export duty and other charges payable in connection therewith; with the import or export of the goods, where the security is guaranteed; 3.

Filed in Danish · English published by the European Commission

Subject to Article 89 UCC current text: Guarantee for a potential or existing customs debt Article 89 UCC General provisions 1. This Chapter shall apply to the provision of security in respect of both: a customs debt which has been incurred as in the case of a customs debt which may have been incurred, unless otherwise specified. 2.

Filed in Danish · English published by the European Commission

Subject to Article 15 UCC: Current text: Representative Article 15 Information for customs authorities 1. Any person directly or indirectly involved in the performance; in the case of customs formalities or controls, the customs authorities shall: request, within a specified time limit, make all necessary documents and information available to those authorities in a appropriate form and provision of all assistance…

Filed in Danish · English published by the European Commission

1. Accounting for special procedures. In Poland, there is no specific time limit within which customs offices are required to clear the procedure, e.g. processing. After the submission of the request for clearance, this sometimes lasts around a year. In this way, the company has seized collateral and this forces companies to hold collateral for several times the amount needed.

Filed in Polish · English published by the European Commission