Crossborder & Centralised Clearance Authorizations
Business Case for Centralised Clearance within VTTI
Executive question
The aim of this position paper is to answer the following key question:
To what extent does the introduction of Centralised Clearance create opportunities for VTTI to redesign its customs operating model and establish a more centralised customs function within the EU?
Current state assessment
Footprint:
- In which EU member-states is VTTI currently involved in customs activities?
- Which legal entities currently act as declarant / representative in customs declarations?
- Which entities currently hold customs and excise authorisations?
- Which customs IT systems are currently used?
- Which customs brokers are currently used by which entities, in which countries?
Governance:
- Where are customs decisions currently taken?
- What responsibilities are handled locally?
- On which terminals doe we currently have customs staff? How many FTE per terminal?
- What responsibilities are coordinated centrally?
- At a first glance, the current setup seems to have a decentralized focus, with a limited, supporting and coordinating role at HQ level. What is the rationale behind the existing setup? Is the current model for instance driven by:
- Legal requirements?
- Operational considerations?
- Historical acquisitions or other historical reasons?
- Tax considerations?
- other?
Understanding centralised clearance
What is centralised clearance?
- UCC concept
- Supervising customs office
- Presentation customs office
- Data-sharing between Member States
Which customs procedures can be covered by CC?
- Import?
- Export?
- Transit?
- Customs warehouse?
- Inward Processing?
- Other?
Conditions and limiatations:
- What are the legal requirements
- Authorisations
- Compliance standards
- Record keeping
- Practical:
- Different national implementations
- Availability of IT systems
- Data quality
- Business:
- Need for local operational knowledge
- Interaction with terminal operations
Future state scenarios for VTTI
- Implementation of CC could potentially allow for a more centralized customs function. What are the pros and cons of a more centralized setup for VTTI?
- Are there other perspectives that need to be considered? Excise? CIT? VAT? Legal? Financial? Operational?
Outline different scenarios:
- Current model
- Hybrid model (certain functions centralised at HQ, other remain at terminal)
- Centralized declaration model (one EU customs center, declarations filed from one location, limited local operational support)
- Customs centre of excellence (all centralized under 1 team)