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Declaration process

VTTI submits customs declarations solely upon instruction from the relevant customer. These instructions are provided through a nomination. The customer is responsible for providing VTTI with all data and documents (information) required to lodge a complete, correct and timely filed customs declaration. Where appropriate, CS performs reasonableness checks on the information provided by the customer before using that information to prepare and submit the customs declaration.

VTTI holds an Entry in the Declarant's Records (EIDR) authorisation. Pursuant to this authorisation, customs declarations may be lodged by entry in the declarant's records and are deemed to have been accepted by the customs authorities at the moment the goods are entered in the records. VTTI applies the EIDR declaration process to the greatest extent possible for placing goods under the following customs procedures:
  • Release for free circulation;
  • Customs warehousing;
  • Inward processing.

 

VTTI does not apply the EIDR process in the following situations:

  • When goods are placed under the export or re-export procedure;
  • Where the use of the EIDR procedure is not permitted, for example where the release of the goods for free circulation requires the submission of an AGRIM certificate.
EIDR is a customs declaration simplification that allows customs declarations to be lodged by entry in the declarant's records. Where EIDR is not used, VTTI lodges customs declarations directly into the declaration system of the customs authorities. This process is embedded in VTTI's ERP and CMS and is, to a large extent, automated.

The EIDR process consists of the following three steps:

  1. Presentation of the goods;
  2. Entry in the declarant's records;
  3. Submission of the supplementary declaration.

 

Presentation of the goods -  A presentation notification is lodged whenever goods are placed under a customs procedure requiring presentation of the goods. When goods are placed under successive customs procedures. The customs authorities may waive the obligation to lodge a presentation notification. The Dutch customs authorities waive this obligation at the second and further placements, provided that the goods are fully traceable in a single administration. This waiver is referred to as the Chain Arrangement (ketenregeling). The principal advantage of the Chain Arrangement is that physical customs controls (if any) can generally be limited to the arrival of the goods at the terminal when they are placed under the first customs procedure in the chain. 

VTTI applies the Chain Arrangement to the greatest extend possible, i.e. wherever the applicable conditions are met. Under the Chain Arrangement, VTTI lodges a presentation notification when goods first arrive at the terminal. VTTI does not present goods again when they are subsequently placed under another customs procedure within the same chain. For example, VTTI uses the EIDR procedure to place goods under the customs warehousing procedure, followed by IPR, a return to customs warehousing and ultimately release into free circulation. In such a chain of customs procedures, a presentation notification is only lodged when the goods arrive at the terminal and are placed under the customs warehousing procedureY67.

A key condition for the application of the Chain Arrangement is that, at the first link in the chain, sufficient information and supporting documentation are available to enable Customs to perform any controls that may be required at later stages in the chain. For example, where goods are ultimately intended to be released for free circulation, Customs must be able to verify at the first link that all relevant import requirements have been met. Although presentation of the goods is generally waived for subsequent customs procedures within the chain, Customs may nevertheless require the goods to be presented at a later stage in exceptional circumstances.

Entry in the declarant's records - Entry in the declarant's records is the lodging of a customs declaration through an electronic entry in VTTI's records. At the time of entry, the particulars of the declaration must be available in VTTI's systems and thereby at the disposal of the customs authorities. The entry contains all information required for the application of the relevant customs procedure and serves as the basis for the subsequent supplementary declaration.

 


 

The supplementary declaration is lodged via the declaration system of the Customs Authorities, ultimately 10 days after entry into the records.

The processes for lodging a goods presentation message, making an entry into the records, and lodging a supplementary declaration are embedded in VTTI’s ERP and CMS and are, to a large extent, automated based on predefined business rules. The automated process is subject to continuous monitoring and review by CS and CGT.

Automated processing is prevented where required information is missing or where errors, inconsistencies, or discrepancies are detected in customer-provided data or documentation. In such cases, CS and CGT review and resolve the issue before the relevant message, declaration, or entry is submitted or recorded.

 

More information on the automated processes embedded in VTTI’s ERP and CMS is included in the Automation paragraph in this AOIC.



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