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Declaration process

Nomination
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.

Entry in the Declarant's Records (EIDR) 
VTTI holds an Entry in the Declarant's Records (EIDR) authorisation. PursuantEIDR tois thisa authorisation,customs declaration simplification that allows customs declarations mayto be lodged by entry in the declarant's recordsrecords. andDeclarations are deemed to have been accepted by the customs authorities at the moment the goods are entered in the records. The use of EIDR shifts customs controls from pre-release declaration checks to post-clearance verification of the declarant's records, internal controls, and audit trail. Consequently, customs audits place increased emphasis on the completeness, accuracy, and traceability of entries in the records and on the effectiveness of the company's customs compliance framework.

VTTI applies the EIDR declaration processprocess, to the greatest extent possiblepossible, for placing goods under the following customs procedures:procedures r
  • Releaseelease for free circulation;
  • Customscirculation, warehousing;
  • Inwardcustoms warehousing and inward processing.
  

 

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

  • Whenplacing goods are placed under the export or re-export procedure;
  • Whereprocedure, thefor those declarations, a standard export or re-export declaration is submitted electronically. VTTI does also not use of the EIDR procedure in situations where this is not permitted,permitted. forFor exampleexample, in cases where the release of the goods for free circulation requires the submissionpresentation of ana valid 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.Customs. This process is embedded in VTTI's ERP and CMS and is, to a large extent,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 -  Presentation of goods is the legal act of making goods available to Customs for control, while the presentation notification is the electronic message used to inform Customs that the goods have been presented. 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 authoritiesCustoms may waive the obligation to lodge a presentation notification. The Dutch customs authoritiesCustoms 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 placement in the link that all relevant import requirements have been met.

VTTI Althoughapplies the Chain Arrangement to the greatest extend possible, i.e. wherever the applicable conditions are met. Under the Chain Arrangement, VTTI lodges a presentation ofnotification when goods first arrive at the terminal and are placed under the customs warehouse procedure and the goods isare generallynot waivedpresented foragain subsequentwhen they are subsequently placed under another customs proceduresprocedure. withinFor example, goods arriving at the terminal are placed under the customs warehousing procedure, followed by IPR, return to customs warehousing and are ultimately release into free circulation. In this chain, Customsa maypresentation neverthelessnotification requireis only lodged when the goods to be presentedarrive at athe laterterminal stageand inare exceptionalplaced circumstances.under the customs warehousing procedure.


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 customs declaration system ofand themust Customsbe Authorities,submitted ultimatelyno later than 10 days after entrythe goods have been entered into the declarant's records. The reference period is one calendar day, meaning that all goods entered into the records on a particular day must be covered by supplementary declarations submitted 10 days later. For example, goods entered into the records on 1 January must be covered by supplementary declarations submitted on 11 January. Failure to submit a supplementary declaration within the prescribed deadline constitutes a breach of the conditions of the EIDR authorisation. Depending on the circumstances, Customs may require corrective action, impose administrative penalties, increase compliance monitoring, or, in cases of repeated or serious non-compliance, suspend or revoke the authorisation. 

Each supplementary declaration relates to a single entry in the records. VTTI submits multiple supplementary declarations on a given day, depending on the volume of transactions. Supplementary declarations are not required for goods placed under the customs warehousing procedure.

Automation
The processes for lodging a goods presentation message,notification, 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.

Review procedures
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 inof this AOIC.



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