# CertEX
CERTEX is the customs-to-TRACES electronic verification layer: when an import declaration is lodged, customs uses CERTEX to **automatically verify that the required TRACES NT documents (e.g., CHED references) exist and have the correct status** before goods can be released.
# What is “CertEX” and how does the system work? In NL/EU day‑to‑day practice, people often use “CertEX” as an umbrella term for the **digital certificates/official controls workflow** around **(pre‑)notification and border controls**. The core is: - **TRACES NT** is the EU system where consignments that fall under SPS/official controls are **notified** using a **CHED**: - **CHED-P** (plants/plant products), - **CHED-A** (animals), - **CHED-PP** (products of animal origin / POAO), - **CHED-D** (certain goods / food & feed of non‑animal origin, depending on the regime). - In the Netherlands this is commonly referred to as **“GGB”** (Gemeenschappelijk Gezondheidsdocument bij Binnenkomst) — in practice the Dutch naming/handling of the **CHED** workflow. **Process at a glance (end‑to‑end):** 1. **Scope check**: does the commodity/consignment fall under EU “official controls” (phytosanitary, veterinary, high‑risk FNAO, etc.)? 2. **Pre‑notification**: importer/agent creates a **CHED/GGB** in TRACES NT and attaches: - consignment details (origin, destination, HS/commodity code, quantities, packaging), - documents (certificates, analyses, attestations), - logistics (BIP/BCP, ETA, container/vessel/flight data). 3. **Arrival & controls** by NVWA/BCP: - documentary check, - identity check, - (where applicable) physical check / sampling. 4. **Decision**: release / release with conditions / rejection / redirection / destruction / re‑export. 5. **Downstream effect**: release is often a prerequisite for **customs clearance** and onward movement. Important: a **CHED/GGB is consignment‑based**, not “product‑based”. You can’t use one CHED indefinitely for multiple physical shipments. # What does “write‑off/consumption” of CHEDs / GGBs mean? - **partial deliveries** (splitting a lot), - **partial clearance** or phased arrivals, - mismatches between **commercial documents** (B/L, invoice, packing list) and **actual received quantity**, - **re‑allocation** due to repacking, blending, or resale before physical discharge. **How it works (conceptually):** - The CHED/GGB contains a **declared quantity** (mass/units). - Upon release, that quantity may be consumed in one go (fully written off), or (depending on regime/configuration) **partly** used, leaving a **remaining balance** still open. - Authorities/systems ensure you **cannot release/move more** than what was approved under that CHED/GGB. **Why this exists:** - To prevent one approval (one CHED) from being used to “pull through” **multiple consignments** or extra volumes. - For traceability and risk control (especially for SPS/high‑risk goods). **Typical pain points:** - If the CHED is for “1,000 MT” but you want to release 1,050 MT (due to weighing differences or B/L tolerance), you can get blocked and may need a **correction/amendment** or separate handling. - If you want to split a cargo across multiple consignees/warehouses, the administrative chain (and sometimes the CHED structure) must support that. # What is the impact (aimed at the energy product)? Because the energy products sector is broad, the impact is **highly product‑ and route‑dependent**. There are 3 relevant groups. ### A) “Mainstream” energy products (crude, gasoline, diesel, jet, fuel oil, naphtha, LNG/LPG) **Usually no CHED/GGB** is required, because these typically do **not** fall under SPS/official controls (veterinary/phytosanitary/food/feed). **Impact is then indirect:** - If a cargo is combined with **regulated co‑loads** (rare) or there is a regulated element in the chain, it can still create operational delays. - If terminals/warehouses also process SPS flows, there can be **congestion/slot effects**. ### B) Biofuels & feedstocks/agri components (UCO, tallow, certain residues, blends into HVO/FAME chains) Here CHED/GGB **can** be relevant depending on classification: - Is it a fat/oil (incl. waste) that can be considered **feed** or **food**? - Is it an **animal by‑product (ABP)** or subject to veterinary controls? - Is the intended use within the EU considered part of the food/feed chain? **Business impact:** - **Demurrage/laytime risk**: if pre‑notification is not tight or documents don’t match, you may get a hold on release → waiting time. - **Contractual risk**: who is responsible for CHED/GGB, documentation, and costs in case of hold/rejection (Incoterms and contract clauses)? - **Loss of flexibility**: “quickly” rerouting to another EU port or changing consignee can be constrained by: - the BCP/entry point in the CHED, - the named importer/consignee, - quantities already (partly) “written off”. ### C) Food/feed of non‑animal origin with elevated risk (e.g., certain oils/seeds/ingredients) If Vitol (or an affiliate) trades/imports these: CHED-D/CHED-PP can apply in specific regimes (increased controls, contaminants, etc.). **Business impact:** - **Planning**: lead times must include BCP capacity, sampling turnaround, and release time. - **Cost**: additional costs for inspections, lab tests, handling, storage. - **Reputation/compliance**: non‑compliance can escalate quickly (rejection/alerts). # Practical do’s & don’ts for trading/ops (where write‑off issues often appear) #### Do's - Ensure **quantities** (B/L/manifest vs CHED) are realistic and aligned with tolerance policy. Customs systems are known to have not implemented these tolerances in their system. To raise with Vemobin/NCO-NCW industry associations. - In contracts, explicitly define: - who files the CHED/GGB, - who pays sampling/inspection/storage, - what happens under partial release or rejection. - If splitting is expected: design the **administrative chain** upfront (single consignee vs multiple; warehousing; resale before/after customs clearance). #### #### **Don’ts** - Don’t try to “fix” the CHED/GGB only upon arrival; for SPS goods **pre‑notification timing** is often strict. - Don’t assume you can freely reallocate volumes once part of a consignment has been released/“written off”. # “Best-effort standard” HS/CN list for commodities ## Quick “screening rule” (practical) - **Ch. 27 (2709/2710/2711)** → **CHED/GGB usually No** - **Ch. 15 (1502, 1511–1514, 1518)** and **Ch. 12 (oilseeds)** → **CHED/GGB often Depends/Yes** - **2207 (ethanol)**, **3826 (biodiesel)** → **Depends** (fuel vs food/feed/ABP chain) Below is a **best‑effort list of EU Combined Nomenclature (CN) commodity code headings / common subheadings** that will *likely* apply to the products mentioned under **A, B, and C**. Focusing on the **CN level (8 digits where reasonably standard)** and keeping it practical for trading/ops screening. > Important: **CHED/GGB (and what you called “CertEX consideration”) is not determined by the CN code alone**. It depends on whether the goods fall under **SPS/official controls** (food/feed/ABP/plant health, “high-risk” regimes, etc.), plus origin/intended use. So: CN codes below tell you “what it is”; CHED tells you “whether it’s controlled”. ## A) Mainstream energy products (typically **CHED/GGB: No**) ### **Crude oil** - **2709 00** — Petroleum oils and oils obtained from bituminous minerals, **crude** ### **Refined petroleum products (broad umbrella used for many products)** - **2710** — Petroleum oils (other than crude) / preparations / waste oils ### **Gas oil / diesel (common CN ranges)** - **2710 19 43 – 2710 19 48** — Gas oils (often used as diesel/gasoil band in EU references) (Note: exact 8‑digit depends on sulphur band / spec.) ### **Jet fuel / kerosene** - **2710 19 21** — Jet fuel - **2710 19 25** — Other kerosene (Both explicitly referenced as kerosene CN codes) ### **Heavy fuel oil** - **2710 19 62 – 2710 19 68** — Heavy fuel oil band used in EU references ### **LPG / petroleum gases** - **2711 12** — Liquefied: propane - **2711 13** — Liquefied: butanes - **2711 12 11 – 2711 19 00** — LPG band referenced in EU taxation tables **CHED/GGB expectation for A:** generally **No** (not SPS/food/feed). ## B) Biofuels & feedstocks (often **CHED/GGB: Depends**) ### **Denatured ethanol (fuel blending / industrial)** - **2207 20 00** — Ethyl alcohol, denatured, of any strength - (Also relevant heading: **2207 10** for undenatured ≥80% vol, but in fuels the denatured line is common.) ### **Biodiesel / FAME / biodiesel blends (broad HS/CN heading)** - **3826 00** — Biodiesel and mixtures thereof (biodiesel heading at HS level; CN splits exist underneath) ### **Tallow (animal fats)** - **1502 10** — Tallow (CN sub-splits exist beneath; used widely for tallow) ### **“UCO / waste oils” (best-effort—classification varies a lot)** - Often ends up under **Chapter 15** (animal/vegetable fats & oils) or “chemically modified / inedible mixtures” categories. - A commonly encountered bucket for chemically modified/inedible mixtures is **1518 00** (note: exact CN depends on product description and lab properties). **CHED/GGB expectation for B:** **Depends**, and this is where most surprises happen: - If it’s treated as **food/feed** or **animal by-product (ABP)** related, or under a **high‑risk** regime → CHED/GGB can become **Yes**. - If it’s clearly an **industrial fuel component** with no SPS relevance → often **No**, but you still need to confirm case-by-case. ## C) Food/feed of non‑animal origin with elevated controls (often **CHED/GGB: Yes/Depends**) You didn’t name specific products in C earlier (only “certain oils/seeds/ingredients”), so here are the **most typical CN families** that come up for edible oils / oilseeds that can be subject to official controls depending on origin/risk regimes: ### **Vegetable oils (examples)** - **1507** — Soya-bean oil - **1508** — Groundnut oil - **1511** — Palm oil - **1512** — Sunflower/safflower/cotton-seed oil - **1513** — Coconut (copra), palm kernel or babassu oil - **1514** — Rapeseed/colza/mustard oil (Exact 8‑digit depends on crude/refined/fractions.) ### **Oilseeds (examples)** - **1201** — Soybeans - **1205** — Rapeseed/colza seed - **1206** — Sunflower seed - **1207** — Other oil seeds and oleaginous fruits **CHED/GGB expectation for C:** commonly **Yes/Depends** because food/feed items can fall under: - mandatory pre‑notification regimes for certain origins/commodities, - increased controls (contaminants, residues, etc.). (Again: whether CHED is required is not “because of the CN code”, but because of the **regulatory status** of that commodity/origin/use.) # Detailed considerations ## A) Mainstream energy products (typical **CHED/GGB consideration: NO**)
Product familyLikely EU CN / HS headingsCHED/GGB (CertEX consideration)
**Crude oil****2709 00** (petroleum oils, crude)**No** (not SPS/food/feed)
**Refined petroleum products (broad bucket)****2710** (petroleum oils other than crude; preparations; etc.)**No**
**Jet / kerosene**Typically under **2710**; common EU references include **2710 19 21** (jet fuel) and **2710 19 25** (other kerosene)**No**
**LPG / petroleum gases (propane/butane etc.)****2711** (petroleum gases and other gaseous hydrocarbons; incl. liquefied propane/butanes)**No**
(These are energy products; in normal cases they do not fall under CHED categories.) ## B) Biofuels & feedstocks (typical **CHED/GGB consideration: DEPENDS**)
Product familyLikely EU CN / HS headingsCHED/GGB (CertEX consideration)Why “depends”
**Biodiesel / FAME / biodiesel blends****3826 00** (biodiesel and mixtures) **Depends**Generally industrial/energy, but classification & controls can be affected by documentation/intended use and any specific EU measures.
**Denatured ethanol (fuel ethanol)****2207 20 00** (denatured ethyl alcohol)**Depends (often No)**Usually not CHED, but if consignment is treated within food/feed controls or special regimes, checks can differ.
**Tallow / animal fats****1502** (tallow)**Depends (often Yes if ABP-related)**Can fall into **animal by‑product / veterinary** logic depending on grade/intended use and accompanying certification.
**Used cooking oil (UCO) / inedible mixed oils**Frequently screens under **1518 00** (inedible mixtures/preparations of animal/vegetable fats/oils; chemically modified; etc.)**Depends (often Yes)**UCO is explicitly discussed in SPS contexts as HS **1518** in trade/SPS notifications; whether CHED applies depends on the specific control regime and use.
**Practical takeaway for B:** for **UCO (1518)** and **tallow (1502)** you should treat CHED/GGB as a **live risk** until proven otherwise for that exact cargo (origin, documentation, intended use, importer status, BCP requirements). ## C) Food/feed of non-animal origin (typical **CHED/GGB consideration: YES / DEPENDS**) These are the common CN families for **vegetable oils and oilseeds** (often used in food/feed chains, and therefore most likely to interact with “official controls” workflows, potentially via **CHED‑D** depending on specific risk lists and origin).
Product familyLikely EU CN / HS headingsCHED/GGB (CertEX consideration)
**Vegetable oils (edible / crude/refined variants)****1507** (soybean oil), **1511** (palm oil), **1512** (sunflower/cottonseed etc.), **1513** (coconut/palm kernel), **1514** (rapeseed/colza/mustard)**Yes/Depends**
**Oilseeds****1201** (soybeans), **1205** (rapeseed/colza), **1206** (sunflower), **1207** (other oil seeds/oleaginous fruits)**Yes/Depends**
# Recources [The EU Single Window Environment for Customs - Taxation and Customs Union](https://taxation-customs.ec.europa.eu/eu-single-window-environment-customs_en)