Inbound

The non-preferential origin recorded for an inbound parcel forms part of the customs data maintained by VTTI for the goods. The information remains linked to the relevant parcel in the ERP system for as long as the goods remain at the terminal. This enables VTTI to trace the origin information received from the customer throughout the storage period and to use it, where relevant, for customs declarations, reporting and statistical purposes, and in connection with audits or controls by the customs authorities.

The recorded inbound origin may also be relevant when goods are subsequently processed or blended at the terminal. In such cases, the origin information relating to the individual input materials is used, together with the operational and inventory data available in VTTI’s systems, to determine or substantiate the origin of the resulting outbound product.

The origin recorded for an inbound parcel does not automatically determine the origin of a product resulting from processing or blending. The origin of the outbound product must be determined separately by applying the relevant preferential or non-preferential origin rule. Depending on the applicable rule, the origin of the inbound materials may be one of the factors taken into account in that determination.

Where the customer provides origin-related supporting documentation (such as a supplier's declaration or certificate of origin) for an incoming shipment, CS stores that document in the Document Management System (part of VTTI's ERP) with a reference to the respective parcel. The data in the document that is needed in VTTI's business process is registered by CS in the Cargo Documents module in ERP.

CS performs a reasonableness check on the origin-related supporting documentation received from the customer. This check is performed using the applicable checklist and is intended to assess whether the documentation appears complete, meets the applicable formal requirements and can reasonably be linked to the goods concerned.

The reasonableness check is based on the information and documentation available to VTTI and does not constitute an independent origin determination or audit of the origin of the goods.

The checklist for reviewing origin-related supporting documentation is available here.

Preferential tariff treatment may result in a reduced or zero rate of import duty when goods are released for free circulation. Preferential treatment may only be claimed where the goods qualify as originating under an applicable preferential arrangement and the required proof of origin is available and meets the conditions of that arrangement.

The customer is responsible for informing VTTI that preferential tariff treatment is to be claimed and for providing the required origin information and supporting documentation. CS follows the steps below before processing a claim for preferential tariff treatment in an import declaration.

Step 1: Determine whether preferential treatment is available

CS first establishes whether a preferential arrangement applies between the European Union and the country or territory for which preferential origin is claimed. It must also be established whether the product concerned falls within the scope of that arrangement and is eligible for preferential tariff treatment.

CS also verifies whether claiming preferential treatment is relevant in view of the normally applicable import duty rate. Where the standard import duty rate is already zero, a claim for preferential tariff treatment generally provides no immediate financial benefit. However, the preferential origin information and any supporting documentation provided by the customer must still be recorded and retained where relevant.

Step 2: Confirm the preferential origin claimed

The customer must confirm that preferential tariff treatment is to be claimed and indicate:

• the preferential arrangement under which the claim is made;
• the country or territory of preferential origin; and
• the product and shipment to which the claim relates.

VTTI relies on this information when determining the applicable proof requirements. If the information provided is incomplete or inconsistent, CS will request clarification from the customer before proceeding.

Step 3: Identify the required proof of origin

CS determines which form of proof of origin is permitted under the applicable preferential arrangement. The required form and conditions may differ between arrangements and may depend on factors such as the value of the originating products included in the shipment.

The assessment must take into account, where relevant:

• the types of proof permitted under the arrangement;
• any applicable value thresholds;
• the prescribed wording or other formal requirements;
• whether the exporter is permitted to make out the proof; and
• whether the exporter must hold a specific authorisation or registration.

The customer is responsible for providing the required proof and any information or supporting documentation needed to establish that it may be used for the shipment concerned.

Step 4: Perform the reasonableness check

CS performs a reasonableness check on the proof of origin provided by the customer. The purpose of this check is to assess whether the proof:

• is available at the time preferential treatment is claimed;
• appears complete and meets the applicable formal requirements;
• has been issued or made out by an eligible person;
• remains usable for the intended import declaration;
• sufficiently describes or identifies the goods concerned; and
• can reasonably be linked to the relevant shipment and parcel.

The reasonableness check is based on the information and documentation available to VTTI. It does not constitute an independent audit of the exporter’s production process or an independent verification of the originating status of the goods.

Any doubt, ambiguity or apparent error must be followed up in accordance with section 3.5, Follow-up and escalation.

Step 5: Decide whether preferential treatment may be claimed

CS may process the claim for preferential tariff treatment where:

• the goods are eligible for preferential treatment under the applicable arrangement;
• the customer has confirmed the relevant preferential origin;
• the required proof of origin is available; and
• the proof has passed the reasonableness check.

Where the required proof is unavailable, does not appear to meet the applicable requirements or gives rise to material concerns that have not been resolved, VTTI will not claim preferential tariff treatment. The import declaration will then be lodged without a claim for preference, subject to any other instructions or customs treatment applicable to the goods.

Where the customer subsequently provides an acceptable proof of origin, the possibility of claiming preferential treatment after importation may be assessed separately in accordance with the applicable preferential arrangement and customs legislation. VTTI will only support such a claim where the required information and documentation are available and any material concerns have been resolved.