Inbound
3.1 Non-preferential origin
3.1.1 Registration of non-preferential origin for inbound parcels
When sending a nomination for an inbound shipment, the customer must provide the non-preferential country of origin of the product. This information is required before the goods can be accepted at the terminal. VTTI does not permit the discharge of product for which the non-preferential country of origin is unknown.
When CS registers the incoming parcel in the terminal’s ERP system, the non-preferential country of origin stated in the nomination is recorded with the relevant parcel. The recorded origin remains linked to the parcel and forms part of the origin audit trail maintained in the ERP system.
CS performs a reasonableness check to assess whether the country of origin provided by the customer is consistent with the other information and documentation available for the shipment. This includes, where relevant, the product information, transport documentation and any origin-related supporting documentation provided by the customer. The check is based on the information available to VTTI and does not constitute an independent determination of the origin of the goods.
If the non-preferential country of origin has not been provided, or if the origin information gives rise to doubt or appears inconsistent with other information or documentation available, CS will request clarification and, where necessary, correction or additional supporting documentation from the customer. The product will not be accepted at the terminal until the non-preferential country of origin has been identified and any material concerns have been adequately addressed.
3.1.2 Purpose and use of non-preferential origin information registered upon receipt
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 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.
3.1.3 Receipt and storage of supporting documentation
Where the customer provides supporting documentation in relation to the non-preferential origin (such as a certificate of origin or a supplier's declaration) 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. CS records the relevant document data in the Cargo Documents module in ERP.
3.1.4 Reasonableness check
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.
3.1.5 Follow-up and escalation
If the reasonableness check gives rise to any doubt, ambiguity or apparent error, CS will request clarification, correction or additional supporting documentation from the customer. The documentation will not be relied upon for customs purposes until any material concerns have been adequately addressed.
Where the matter cannot be resolved by CS or requires further customs expertise, CS will involve the terminal’s customs specialist. Depending on the complexity, potential financial impact or wider compliance implications of the matter, the terminal’s customs specialist may request support from CGT.
VTTI will not rely on the origin information or supporting documentation concerned for customs or compliance purposes while material concerns remain unresolved.
3.2 Preferential origin
3.2.1 Receipt and storage of supporting documentation
Where the customer provides supporting documentation in relation to the preferential origin (such as an origin statement or an origin declaration) 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.
3.2.2 Reasonableness check
Upon receipt of the goods, CS verifies the normally applicable import duty rate, referred to as the “MFN rate”, and whether a proof of preferential origin has been provided. If the MFN rate is 0%, the goods are released for free circulation without claiming preferential tariff treatment.
If the MFN rate exceeds 0% and a proof of preferential origin is available, CS performs a reasonableness check. As part of this check, CS assesses whether a preferential arrangement applies between the European Union and the stated country or territory of origin, whether the product concerned is eligible for preferential tariff treatment, which form of proof is required under the arrangement and whether the proof provided appears to meet the applicable 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 audit of the production process, supply chain or originating status of the good.
The checklist for reviewing origin-related supporting documentation is available here.
3.2.3 Follow-up and escalation
In principle, VTTI does not store goods eligible for preferential tariff treatment under the customs warehouse procedure. Where the proof of origin passes the reasonableness check, VTTI claims preferential tariff treatment and the goods are released for free circulation.
If no proof of origin is available, the proof does not appear to meet the applicable requirements or material concerns remain unresolved, preferential tariff treatment will not be claimed.
Any doubt, ambiguity or apparent error identified during the reasonableness check is followed up with the customer. CS requests clarification, correction or additional supporting documentation as appropriate and does not rely on the proof of origin while material concerns remain unresolved.
Where the matter cannot be resolved by CS or requires further customs expertise, CS involves the terminal’s customs specialist. Depending on the complexity, potential financial impact or wider compliance implications of the matter, the terminal’s customs specialist may request support from CGT.